Anti-Money Laundering Policy

1. Introduction & Regulatory Framework

1.1 Purpose of This Policy

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy establishes the framework and procedures that Jackpot Wheel Casino ("the Casino," "we," "us," "our") has implemented to prevent our services from being used for money laundering, terrorist financing, or other illicit financial activities.

1.2 Regulatory Compliance

This policy is designed to ensure compliance with:

• Kahnawake Gaming Commission (KGC) Regulations: Our licensing authority's AML/CTF requirements
• Financial Action Task Force (FATF) Recommendations: International standards for combating money laundering and terrorist financing
• Bank Secrecy Act (BSA): US anti-money laundering legislation where applicable
• USA PATRIOT Act: Enhanced AML measures and customer identification requirements
• Office of Foreign Assets Control (OFAC) Regulations: Sanctions and prohibited parties screening
• FinCEN Guidance: Financial Crimes Enforcement Network requirements for gaming operators

1.3 Scope of Application

This policy applies to:

• All customers and prospective customers of Jackpot Wheel Casino
• All employees, contractors, and third-party service providers
• All financial transactions processed through our platform
• All jurisdictions in which we operate

2. Policy Statement & Objectives

2.1 Zero Tolerance Statement

Jackpot Wheel Casino maintains a zero-tolerance policy toward money laundering and terrorist financing. We are committed to:

• Preventing our services from being used for money laundering or terrorist financing
• Identifying and verifying the identity of all customers
• Monitoring transactions for suspicious activity
• Reporting suspicious activities to relevant authorities
• Maintaining comprehensive records of all transactions and customer information
• Training all staff on AML/CTF procedures and obligations
• Cooperating fully with law enforcement and regulatory authorities

2.2 Key Objectives

Prevention

Implement robust controls to prevent criminals from using our platform for illicit purposes.

Detection

Employ sophisticated monitoring systems to identify potentially suspicious transactions and patterns of behavior.

Reporting

Promptly report suspicious activities to appropriate authorities as required by law.

Compliance

Maintain full compliance with all applicable AML/CTF laws, regulations, and industry best practices.

2.3 Money Laundering & Terrorist Financing Defined

Money Laundering

Money laundering is the process of concealing the origins of illegally obtained money, typically by means of transfers involving legitimate businesses or foreign banks. The three stages of money laundering are:

• Placement: Introducing illicit funds into the financial system
• Layering: Concealing the source of funds through complex transactions
• Integration: Making laundered funds appear legitimate

Terrorist Financing

Terrorist financing involves providing financial support to individuals or organizations involved in terrorist activities. Unlike money laundering, the funds may originate from legitimate sources but are used for illegal purposes.

3. Risk Assessment & Management

3.1 Risk-Based Approach

We employ a risk-based approach to AML/CTF compliance, meaning we allocate resources and implement controls based on the level of risk associated with different customers, products, transactions, and jurisdictions.

3.2 Risk Categories

Customer Risk Factors

• High-Risk Customers:
  • Politically Exposed Persons (PEPs)
  • Customers from high-risk jurisdictions
  • Customers with complex ownership structures
  • Customers conducting unusually large or frequent transactions
  • Customers with patterns suggesting structuring (avoiding reporting thresholds)
• Medium-Risk Customers:
  • Customers with moderate transaction volumes
  • Non-resident customers
  • Cash-intensive businesses
• Low-Risk Customers:
  • Domestic customers with verified identity
  • Customers with stable, predictable transaction patterns
  • Regulated entities and public companies

Geographic Risk Factors

Higher scrutiny is applied to customers from jurisdictions identified as high-risk by FATF or subject to international sanctions, including:

• Countries with weak AML/CTF frameworks
• Countries subject to OFAC sanctions
• Jurisdictions known for high levels of corruption or organized crime
• Countries designated as non-cooperative by FATF

Transaction Risk Factors

• Large cash transactions or cash equivalents
• Transactions with no apparent economic purpose
• Rapid movement of funds in and out of accounts
• Structuring transactions to avoid reporting thresholds
• Transactions inconsistent with customer profile

3.3 Enhanced Due Diligence (EDD)

For high-risk customers or transactions, we implement Enhanced Due Diligence measures, including:

• Additional identity verification documents
• Source of funds and source of wealth verification
• More frequent monitoring and review
• Senior management approval for account opening and transactions
• Restrictions on transaction types or limits

4. Know Your Customer (KYC) Procedures

4.1 Customer Identification Program (CIP)

Our Customer Identification Program ensures that we know the true identity of every customer before allowing them to use our services.

4.2 Required Customer Information

At a minimum, we collect and verify the following information for all customers:

Individual Customers

• Full Legal Name: As it appears on government-issued identification
• Date of Birth: To verify age and identity
• Residential Address: Physical address (not P.O. Box)
• Nationality & Country of Residence: For sanctions screening and jurisdiction verification
• Government-Issued Identification Number: Passport, driver's license, or national ID number
• Contact Information: Email address and phone number

Business/Corporate Customers (if applicable)

• Legal business name and any trade names
• Business registration number
• Principal place of business
• Business type and nature of activities
• Identity of beneficial owners (individuals owning 25% or more)
• Identity of authorized signatories and representatives
• Corporate documentation (articles of incorporation, business licenses)

4.3 Beneficial Ownership

For any entity accounts, we identify and verify the identity of beneficial owners—individuals who ultimately own or control 25% or more of the entity, or who exercise significant control over the entity.

4.4 Politically Exposed Persons (PEPs)

We screen all customers against PEP databases to identify individuals who hold or have held prominent public positions. PEPs present a higher risk of corruption and require enhanced due diligence, including:

• Senior management approval before account opening
• Enhanced verification of source of funds and wealth
• More intensive ongoing monitoring
• Periodic review of the relationship

PEP Categories

• Domestic PEPs: Individuals in prominent positions in their home country
• Foreign PEPs: Individuals in prominent positions in foreign countries
• International Organization PEPs: Individuals in senior positions at international organizations
• Family Members & Close Associates: Individuals related to or closely associated with PEPs

5. Customer Verification Requirements

5.1 Identity Verification Process

Before a customer can make their first withdrawal, we require submission of verification documents to confirm identity, address, and payment method ownership.

5.2 Required Verification Documents

5.3 Document Submission Methods

• Upload Portal: Secure document upload through customer account
• Email: Send to verification@jackpot-wheel-casino.us (encrypted transmission)
• Customer Support: Submit via live chat (files are encrypted)

5.4 Verification Timeline

• Standard Review: Documents reviewed within 24-48 hours of submission
• Additional Information Requested: If documents are unclear or insufficient, we'll contact you within 48 hours
• Approval Notification: You'll receive confirmation once verification is complete

5.5 Enhanced Verification

In certain circumstances, we may require additional verification, including:

• Source of Funds Documentation: Evidence of how funds used for gambling were obtained (payslips, business income, investment statements)
• Source of Wealth Documentation: Evidence of overall financial standing (tax returns, property deeds, inheritance documents)
• Video Verification: Live video call to confirm identity
• Notarized Documents: Certified copies of documents
• Additional References: Bank references or professional references

5.6 Ongoing Verification

Verification is not a one-time process. We may request updated documents or additional information:

• When documents expire (e.g., passport expiration)
• When customer information changes (e.g., address change)
• When transaction patterns change significantly
• Periodically as part of our ongoing due diligence (typically every 2-3 years for active accounts)
• When required by regulatory authorities

6. Transaction Monitoring & Reporting

6.1 Automated Monitoring Systems

We employ sophisticated automated transaction monitoring systems that analyze all customer transactions in real-time and identify potentially suspicious patterns or activities.

6.2 Monitored Activities

Our systems monitor for various risk indicators, including:

Deposit Patterns

• Unusually large deposits compared to customer profile
• Frequent deposits just below reporting thresholds (structuring)
• Deposits from multiple payment sources
• Rapid succession of deposits and withdrawals
• Deposits followed immediately by withdrawal requests with minimal or no gaming activity

Withdrawal Patterns

• Withdrawal requests immediately after deposits
• Withdrawals to different payment methods than deposits
• Withdrawals to third-party accounts
• Frequent withdrawal cancellations and re-requests
• Large withdrawals inconsistent with gaming activity

Gaming Activity Patterns

• Minimal gaming activity relative to transaction volume
• Unusual betting patterns (e.g., betting on all outcomes in roulette)
• Gaming activity inconsistent with stated occupation or income level
• Sudden dramatic changes in betting behavior

Account Behavior Patterns

• Multiple accounts associated with same identity or payment method
• Account accessed from multiple geographic locations in short time periods
• Use of VPN or anonymizing services
• Unusual login patterns or device changes

6.3 Reporting Thresholds

Currency Transaction Reports (CTRs)

Where required by jurisdiction, we file Currency Transaction Reports for:

• Single transactions exceeding $10,000 (or equivalent)
• Multiple transactions totaling over $10,000 in a 24-hour period by the same customer

Suspicious Activity Reports (SARs)

We file Suspicious Activity Reports when we detect:

• Transactions or patterns with no apparent lawful purpose
• Transactions designed to evade reporting requirements
• Use of our services to facilitate criminal activity
• Transactions involving proceeds from illegal activities
• Any transaction or activity raising suspicion of money laundering or terrorist financing

6.4 Internal Alert Investigation

When our systems generate an alert:

1. Alert is reviewed by our compliance team within 24 hours
2. Customer account and transaction history are analyzed
3. Additional information may be requested from the customer
4. Account may be temporarily restricted pending investigation
5. Decision is made: clear alert, continue monitoring, or escalate to senior management
6. If warranted, a Suspicious Activity Report is filed with authorities
7. Investigation is documented and retained

7. Suspicious Activity Detection & Reporting

7.1 Red Flags & Indicators

Our staff are trained to recognize potential indicators of money laundering or terrorist financing, including:

Customer Behavior Red Flags

• Customer reluctant to provide identification or verification documents
• Customer provides suspicious, false, or stolen identification
• Customer provides contradictory information
• Customer is evasive or refuses to explain source of funds
• Customer has no knowledge of transaction details or appears to be a front for someone else
• Customer makes unusual inquiries about AML policies or reporting requirements
• Customer attempts to develop personal relationships with staff to avoid scrutiny

Transaction Red Flags

• Transactions inconsistent with customer's known legitimate business or personal activities
• Structuring transactions to avoid reporting thresholds
• Transactions with no apparent economic, business, or lawful purpose
• Use of multiple accounts or identities for no apparent reason
• Frequent deposits followed by immediate withdrawal requests
• Minimal gaming activity between deposits and withdrawals
• Customer requests to process third-party deposits or withdrawals

Geographic Red Flags

• Transactions involving high-risk jurisdictions
• Customer's stated location differs from IP address or payment method origin
• Transactions routed through multiple countries with no clear purpose
• Use of payment methods registered in high-risk jurisdictions

7.2 Staff Reporting Obligations

All employees are required to:

• Report any suspicious transactions or activities to the Money Laundering Reporting Officer (MLRO) immediately
• Document observations in writing with as much detail as possible
• Maintain strict confidentiality—not discuss suspicions with customers or unauthorized personnel
• Continue to process normal transactions unless instructed otherwise (to avoid "tipping off")

7.3 Money Laundering Reporting Officer (MLRO)

Our designated MLRO is responsible for:

• Receiving and investigating internal suspicious activity reports
• Determining whether to file Suspicious Activity Reports (SARs) with authorities
• Maintaining liaison with law enforcement and regulatory authorities
• Overseeing AML/CTF compliance program
• Ensuring staff training and awareness
• Reviewing and updating AML policies and procedures

7.4 Filing Suspicious Activity Reports (SARs)

When suspicious activity is identified, our MLRO will:

1. Conduct thorough investigation and document findings
2. Determine whether activity meets the threshold for SAR filing
3. Prepare detailed SAR with all relevant information
4. File SAR with appropriate authorities within required timeframes (typically 30 days)
5. Maintain confidential records of SAR and investigation
6. Continue monitoring the customer's account as appropriate

SAR Content includes:

• Customer identifying information
• Description of suspicious activity
• Dates and amounts of transactions
• Payment methods used
• IP addresses and device information
• Any other relevant details that may assist law enforcement

8. Record Keeping & Data Retention

8.1 Record Retention Requirements

We maintain comprehensive records of all customer information, transactions, and compliance activities for the periods required by law and regulation.

8.2 Retention Periods

8.3 Records Maintained

Our comprehensive record-keeping includes:

• Customer Information: All KYC/verification documents, addresses, contact information, correspondence
• Transaction Data: Complete details of all deposits, withdrawals, wagers, wins, bonuses
• Account Activity: Login history, IP addresses, device information, account changes
• Compliance Activities: Due diligence reviews, risk assessments, investigations, SAR filings
• Third-Party Information: Details of payment processors, verification services, other service providers

8.4 Data Security & Access Control

All AML records are:

• Stored securely with encryption and access controls
• Accessible only to authorized personnel on a need-to-know basis
• Protected against unauthorized access, alteration, or destruction
• Backed up regularly to prevent data loss
• Available for review by regulators and law enforcement upon request

8.5 Record Retrieval

We maintain systems that allow rapid retrieval of records for:

• Internal investigations and compliance reviews
• Regulatory examinations and audits
• Law enforcement requests
• Legal proceedings

9. Sanctions Screening & Compliance

9.1 Sanctions Programs Monitored

We screen all customers and transactions against international sanctions lists, including:

• OFAC (Office of Foreign Assets Control): US sanctions programs
• UN Security Council: United Nations sanctions lists
• EU Sanctions: European Union restrictive measures
• HMT (UK Treasury): UK financial sanctions
• Other Jurisdictional Lists: As applicable to our operations

9.2 Screening Processes

Initial Screening

• All customers screened against sanctions lists at account registration
• Name, date of birth, address, and nationality checked
• Matches are reviewed immediately by compliance team
• Account registration blocked if positive match confirmed

Ongoing Screening

• Customer database rescreened daily against updated sanctions lists
• Alerts generated for new matches
• Accounts frozen immediately upon confirmed match
• Authorities notified as required

Transaction Screening

• Payment originators and beneficiaries screened
• Geographic locations of transactions monitored
• Suspicious routing patterns flagged

9.3 Prohibited Jurisdictions

We do not accept customers from or process transactions involving:

• Countries subject to comprehensive OFAC sanctions (e.g., Iran, North Korea, Syria, Cuba)
• Regions subject to sectoral sanctions or embargoes
• Territories on FATF's list of non-cooperative jurisdictions
• Any jurisdiction where our operations would violate applicable law

9.4 Response to Sanctions Matches

Upon confirmed match to a sanctions list:

1. Account is immediately frozen—no deposits or withdrawals permitted
2. Senior management and legal counsel are notified
3. Appropriate authorities are contacted (e.g., OFAC if US sanctions match)
4. We await guidance from authorities on asset disposition
5. No information is provided to customer (to avoid tipping off)
6. Detailed records of actions taken are maintained

10. Staff Training & Awareness

10.1 Training Program

All employees receive comprehensive AML/CTF training appropriate to their role and responsibilities.

10.2 Training Components

Initial Training (All Staff)

• Overview of money laundering and terrorist financing
• Regulatory framework and legal obligations
• Company AML/CTF policies and procedures
• Red flags and indicators of suspicious activity
• Reporting obligations and procedures
• "Tipping off" prohibitions
• Sanctions compliance
• Consequences of non-compliance

Role-Specific Training

• Customer Service: Customer identification, red flag recognition, reporting procedures
• Compliance Team: Advanced investigation techniques, SAR filing, regulatory liaison
• Finance Team: Transaction monitoring, payment screening, record-keeping
• Management: Risk assessment, policy oversight, regulatory obligations

10.3 Training Frequency

• New Hires: AML training within first 30 days of employment
• Annual Refresher: All staff complete updated training annually
• Ad Hoc Updates: Training when regulations change or new risks emerge
• Specialized Training: As needed for staff in high-risk roles

10.4 Training Records

We maintain detailed records of all training activities, including:

• Names of employees trained
• Dates and duration of training
• Training content and materials
• Assessment results or completion certificates
• Trainer credentials

10.5 Culture of Compliance

Beyond formal training, we foster a culture of compliance through:

• Regular communications and reminders about AML obligations
• Management setting a tone of commitment to compliance from the top
• Recognition and rewards for effective compliance practices
• Clear consequences for compliance failures
• Open channels for employees to raise concerns or ask questions

11. Cooperation with Authorities

11.1 Regulatory Cooperation

We maintain a cooperative relationship with regulatory and law enforcement authorities and respond promptly to all legitimate requests for information.

11.2 Information Sharing

We provide information to authorities including:

• Proactive Reporting: Filing SARs and CTRs as required
• Responsive Disclosure: Providing records in response to subpoenas, court orders, or formal requests
• Regulatory Examinations: Facilitating on-site visits and audits by licensing authorities
• Law Enforcement Requests: Cooperating with criminal investigations

11.3 Legal Process Requirements

For requests outside of routine regulatory supervision, we generally require:

• Valid subpoena, warrant, or court order
• Verification of requesting authority's identity and jurisdiction
• Sufficient detail to identify requested records
• Compliance with applicable legal procedures

11.4 Confidentiality & Privacy Balance

We balance our cooperation obligations with customer privacy rights:

• We do not voluntarily disclose customer information except as required by law
• We challenge overly broad or improper requests through appropriate legal channels
• We maintain confidentiality of investigations and reports as required by law
• We comply with all "tipping off" prohibitions in AML legislation

12. Enforcement & Consequences

12.1 Violations & Penalties

Customers found to be involved in money laundering, terrorist financing, or other illicit activities face severe consequences:

Immediate Actions

• Account suspension or closure
• Freezing of all funds
• Cancellation of pending transactions
• Forfeiture of bonuses and winnings
• Filing of Suspicious Activity Report

Legal Consequences

• Report to law enforcement authorities
• Cooperation with criminal investigations
• Asset seizure or freezing
• Criminal prosecution (money laundering carries penalties of up to 20 years imprisonment and substantial fines)
• Civil penalties and asset forfeiture

12.2 Non-Compliance with Verification

Customers who fail to comply with verification requirements will have:

• Account access restricted
• Deposits blocked
• Withdrawals suspended until verification complete
• Account closure if verification not completed within 90 days
• Funds forfeited if verification requirements are not met (as permitted by law)

12.3 Provision of False Information

Providing false, misleading, or fraudulent information or documents results in:

• Immediate account closure
• Forfeiture of all funds and winnings
• Permanent ban from our services
• Report to law enforcement for fraud and identity theft
• Potential criminal prosecution

12.4 Employee Accountability

Employees who fail to comply with AML obligations face:

• Disciplinary action up to and including termination
• Potential personal criminal liability for willful violations
• Civil penalties for regulatory violations

Policy Review & Updates

Regular Review

This AML/CTF Policy is reviewed and updated:

• At least annually
• When regulations change
• When new risks are identified
• Following regulatory examinations or audits
• After significant incidents or compliance failures

Continuous Improvement

We are committed to maintaining and improving our AML/CTF program through:

• Regular risk assessments
• Monitoring regulatory developments and industry best practices
• Investing in technology and training
• Learning from incidents and near-misses
• Engaging with regulators and industry peers

Contact for AML Matters

For questions regarding this policy or to report concerns:

• Money Laundering Reporting Officer: mlro@jackpot-wheel-casino.us
• Compliance Department: compliance@jackpot-wheel-casino.us