Las Atlantis Casino is devoted to preventing money laundering, implementing an anti-money
laundering infrastructure with specialized controls and systems designed specifically to
facilitate the use of our platform in anti-money laundering schemes.
Our Las Atlantis Casino AML Policy is designed to establish our compliance with the required
AML
standards and as such includes the following:
- Appointing a proper Money Laundering Compliance Officer (AMLCO) with adequate
knowledge and seniority in the field and appropriate accountability to manage and
monitor compliance oversight through the use of legitimate and appropriately fitting
regulations, rules, legislation, and proper industry guidelines. Being one of the
pivotal points of our operations, any and all AML measures are a direct
responsibility of the Las Atlantis Casino management. An AMLCO is thus assigned to
supervise and enforce such measures within the system. The AMLCO position implies
direct subordination to the general management.
- Instituting and managing a money laundering and terrorist financing risk assessment
through the use of a specifically established Risk-Based Approach (RBA). The scopes
of AML Compliance Officer duties include overseeing an artificial intelligence
algorithm designed to detect and report any suspicious activities performed by
users. Within the general risk management strategy, such reports are subject to
multiple further checks by the AMLCO and other employees if required.
- Utilizing the AI detection system reinforced by data science measures intended to
identify unusual behavior patterns that may indicate fraudulent intent, including,
but not limited to depositing and withdrawal without betting, using multiple bank
accounts for transfers, and radical gaming pattern changes. Establishing the fact
whether the same user is still in possession of the account is a part of such
measures as well.
- Conducting an Enterprise-Wide Risk Assessment (EWRA) procedure to establish risks
Las Atlantis Casino can be prone to, along with possible countermeasures. The
results of
the assessment were implemented in the process of creating this AML Policy, focusing
on risk sources such as services, offers, users, transactions, third parties,
legislation of different jurisdictions, and other emerging risks. EWRA is conducted
annually to enable us to respond to risks arising from general World Wide Web
activities, as well as industry requirements, expectations and guidance.
- Instituting and managing the identification, due diligence and if the occasion
requires, proper Know Your Clients (KYC) procedure on any client that has been
suspected of being risk-based. This may also include enhanced due diligence
procedures on clients that have been presenting a higher risk, i.e. Politically
Exposed Persons (PEP) etc. For more information – see our dedicated KYC
page.
- Instituting and managing customer activity monitoring procedures and risk-based
systems.
- Instituting various procedures for reporting any relevant suspicious client activity
both internally and to the proper law enforcing authorities. All the employees
involved with monetary operations are duly instructed as per how to detect and
report suspicious transactions. The reports are contemplated by the AML team
according to an established protocol. The results of such contemplation include a
decision on whether the suspected account needs to be suspended or terminated and
whether FIU needs to be informed on the issue, pursuant to the provisions of Law of
18 September 2017 on the prevention of money laundering limitation of the use of
cash.
- Managing and maintaining any relevant and applicable records for the minimum
required time. We do not share any of the user’s data with third parties except for
cases stated in our Privacy Policy. An AML authority of an affected state can
request and obtain such data from us on the grounds of money laundering prevention
by enforcing compliance to the law of such state.
- Implementing the proper awareness education on all relevant employees, assuring that
all procedural requirements are met. The employees undergo regular training on AML,
diversified to match the needs of every department involved. Conducting such
training sessions is a direct responsibility of our AML officers. The internal
network of Las Atlantis Casino contains the guidelines and instructions for every
employee
involved into the process of enforcing this Policy. The data received or otherwise
emerging from AML activities shall be encrypted and stored for 10 years online and
offline after the transactions or other actions took place. We conduct frequent
internal audit to maintain the fulfillment of the provisions of this Policy.
Las Atlantis Casino has implemented a risk-based Counter Financing of Terrorism (CFT)
approaches
and procedure when facing any potential AML risk.
In addition, Las Atlantis Casino has established specialized CFT internal controls, aimed to
track
and conduct any relevant procedures towards CFT issues in a manner which overrules any other
operating task, business or strategy.
Las Atlantis Casino is prohibited from making transactions with any companies, individuals
and/or
countries that are listed on the prescribed sanctions lists.