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Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy – ace-bet.net 🔒

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy – ace-bet.net 🔒

Last updated: 25 October 2025

This page sets out the official Anti-Money Laundering and Know Your Customer framework for ace-bet.net. The policy protects users and partners, deters illicit finance, and aligns our operations with internationally recognized standards. It is written to meet EEAT (Experience, Expertise, Authoritativeness, Trustworthiness) and YMYL (Your Money or Your Life) expectations by providing clear definitions, robust controls, and verifiable procedures. ✅

📌 Scope, Purpose, and Applicability

This policy applies to all products, pages, communications, and payment-related processes of ace-bet.net, including account creation, deposits, withdrawals, user-to-user transfers, promotional credits, and dispute resolution. It applies to all personnel, contractors, payment partners, and service providers who support our services.

🧭 Regulatory Alignment & Best-Practice References

  • FATF Recommendations (risk-based AML/CFT approach, CDD/EDD, ongoing monitoring, reporting, record retention).
  • Directive (EU) 2015/849 and Directive (EU) 2018/843 (AMLD4/AMLD5) regarding AML/CFT obligations.
  • Regulation (EU) 2015/847 on information accompanying transfers of funds.
  • Applicable national laws, sanctions regimes, and supervisory guidance relevant to users’ locations and our payment partners.
  • Data protection principles consistent with GDPR for privacy, security, and data minimization.

🧾 Definitions

  • Money Laundering (ML): Converting, transferring, concealing, or disguising the origin of property known to be derived from criminal activity, or assisting persons involved in such activity to evade legal consequences.
  • Customer Due Diligence (CDD/KYC): Identifying and verifying customers, understanding the purpose of the relationship, and applying ongoing monitoring.
  • Enhanced Due Diligence (EDD): Additional checks for high-risk customers, jurisdictions, products, or behaviors.
  • Source of Funds (SoF) / Source of Wealth (SoW): Evidence that explains the origin and legitimacy of deposited funds and overall wealth.
  • Suspicious Transaction/Activity Report (STR/SAR): A formal report submitted to a Financial Intelligence Unit (FIU) when ML/TF is suspected.

🏛️ Governance & Accountability

  • Senior Management sets tone-from-the-top, approves policy, allocates resources, and oversees effectiveness.
  • AML Compliance Officer (AMLCO) designs controls, supervises monitoring, investigates alerts, escalates cases, and liaises with authorities.
  • First Line (Operations & Support) executes CDD/EDD, enforces payment rules, and flags anomalies.
  • Internal Audit performs independent, periodic reviews, testing, and recommendations.

🛠️ Policy Maintenance & Change Control

Material updates undergo a documented risk impact assessment and approval by Senior Management and the AMLCO. Prior versions are archived for auditability.

🧩 Risk-Based Approach (RBA) & EWRA

ace-bet.net conducts an Enterprise-Wide Risk Assessment (EWRA) at least annually. The EWRA evaluates inherent risks across products, delivery channels, user types, geography, transactional patterns, sanctions exposure, and emerging typologies. EWRA outcomes define thresholds, rules, EDD triggers, and monitoring frequencies.

🪪 Tiered Customer Verification (KYC)

Account verification follows a tiered structure. Certain actions may be paused until the required tier is completed.

  • Tier 1 – Basic Profile (required before any withdrawal)
    • Full name, date of birth, gender, nationality, country of usual residence, full address.
    • Automated database checks. If unavailable or mismatched, a proof of address is required.
  • Tier 2 – Advanced ID Verification
    • Triggered when cumulative deposits or withdrawals reach 2,000 (USD/EUR or equivalent).
    • Valid government ID photographed next to a random 6-digit code written by the user, plus a live selfie for match verification.
    • Where e-verification fails, provide a recent proof of address (utility bill/bank statement/official letter issued within the last 3 months) showing full name and address. All four corners must be visible and text readable.
  • Tier 3 – Source of Funds / Source of Wealth (SoF/SoW)
    • Triggered when cumulative deposits/withdrawals reach 5,000 or when peer-to-peer transfers reach 3,000.
    • Acceptable SoF/SoW: employment payslips, audited business accounts, investment statements, inheritance documents, tax filings, or notarized evidence of asset sales.

🌍 Geographic Risk Categorization

  • Low Risk: Tiers and thresholds as described above.
  • Medium Risk: Lower thresholds of 1,000 for Tier 2 and 2,500 for Tier 3; crypto-to-fiat conversions may be treated as medium risk.
  • High Risk: Service may be restricted or prohibited; jurisdiction lists are reviewed against sanctions and regulatory advisories.

💳 Payment Method Controls

  • The same method used for deposit must be used for withdrawal at least up to the deposited amount, mitigating ML risks.
  • Third-party cards or accounts are prohibited. The account name must match the verified user name.
  • Structuring deposits/withdrawals to evade thresholds triggers EDD and may result in restrictions or closure.

🔎 Ongoing Monitoring & Three Lines of Control

  • First Line: We partner with reputable PSPs that operate effective AML/KYC controls at onboarding and at transaction time.
  • Second Line: Rules-based and machine-assisted monitoring overseen by the AMLCO. Red flags include rapid deposit-withdrawal cycles, inconsistent behavior, currency switching, account-takeover signals, and counterparties in high-risk locations.
  • Third Line: Manual case reviews of suspicious/high-risk users; STR/SAR filings to the competent FIU as required by law.

📈 Control Thresholds at a Glance

Control Layer Trigger Required Actions
CDD Tier 1 Account creation / before first withdrawal Profile data + automated checks; proof of address if needed
CDD Tier 2 Deposit or withdrawal ≥ 2,000 Government ID + handwritten 6-digit code + selfie; PoA if e-checks fail
EDD Tier 3 Deposit/withdrawal ≥ 5,000 or P2P ≥ 3,000 SoF/SoW evidence; enhanced screening and manual review
Monitoring All customers Rules + ML models; sanctions checks; case management & STR/SAR where applicable

🧩 Acceptable SoF/SoW Examples

  • Employment income (recent payslips, HR letter, tax statements).
  • Business ownership (audited accounts, corporate registry extracts).
  • Investments (brokerage statements, dividend records, proof of asset liquidation).
  • Inheritance or gifts (probate documents, notarized deeds, bank confirmations).

🚨 Detection, Escalation, and STR/SAR

  • Staff must promptly escalate atypical activity to the AML team via secure channels.
  • The AML team evaluates alerts, documents rationale, and files STR/SAR with the relevant FIU where legally required.
  • “Tipping-off” is prohibited; customers are not notified about STR/SAR submissions where law so mandates.

🧰 Procedures & Playbooks

Operational playbooks translate this policy into step-by-step procedures, including minimum CDD standards, sanctions screening, EDD triggers, case escalation, account restrictions, and communication templates. First withdrawals require transactional activity of at least 70% of deposited funds to deter circular flows.

🧾 Record-Keeping

  • KYC records are retained for at least 10 years after the business relationship ends.
  • Transaction records are retained for at least 10 years after execution or termination, whichever is later.
  • Records are stored securely with encryption at rest and in transit, using both online and offline safeguards.

🧑‍🏫 Training & Awareness

  • Mandatory AML induction for new hires and periodic refresher training for finance, risk, operations, and support staff.
  • Case-based learning on typologies such as smurfing, mule accounts, synthetic identities, and crypto on/off-ramp risks.
  • Training effectiveness is monitored via KPIs, quality assurance, and audit findings.

🧪 Internal Audit & Continuous Improvement

  • Internal Audit conducts regular reviews of AML controls, data quality, and case handling timeliness.
  • Metrics such as false-positive ratios, case turnaround time, and post-investigation actions inform improvement plans.

🧱 Data Protection & Privacy 🔐

  • We collect the minimum data necessary for lawful AML/KYC and service provision; data are not sold.
  • Information may be shared only when required by law or for the prevention/detection of financial crime.
  • We respect data subject rights under applicable privacy laws, including access, rectification, restriction, and objection.

🚫 Zero-Tolerance for Violations

  • Accounts linked to forged documents, stolen payment instruments, account-takeover, or unjustified flows may be restricted or terminated.
  • Confirmed ML/TF or fraud is reported to competent authorities without prior notice, as permitted by law.

📫 Contact

If you have questions about this AML/KYC Policy, wish to exercise privacy rights, or need to report suspicious activity, please reach out via the “Contact Us” page on ace-bet.net. 💬

⚠️ Compliance Notice

Use of ace-bet.net constitutes acceptance of this AML/KYC Policy. Failure to provide requested documentation or to pass verification may result in delayed withdrawals, rejected transactions, or account restrictions. We reserve the right to update this document to reflect evolving regulations, supervisory expectations, and best practices.

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