Pin-Up Anti-Money Laundering Policy

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Money Laundering

Money laundering is a specific process of legalizing money that has been obtained through illegal means, such as illegal terrorist activities or through drug trafficking or any other illegal activity. The perpetrators try to launder the money obtained in this way by maximizing it or moving it to places where it does not attract much attention.

Combating Money Laundering

This term is of two natures – legal and financial, and carries the essence of certain legal control measures from various financial institutions to prevent and detect in time illegal activities related to illegally obtained money. The fight against money laundering has an effective program: 

  • Enables the transfer of information between certain authorities; 
  • Allows the identification of customers; 
  • Record and report suspicious activities.


Employees who are involved in the online (remote) provision of gambling entertainment are obliged to timely report and provide appropriate reports if they have information regarding violations that come to them during the performance of their duties. This includes: 

  • Suspicion; 
  • Accurate knowledge with the presence of evidence; 
  • Grounds that a person is engaged in illegal activities, including money laundering.

These points can be considered reasonable suspicions, which must be reported to the relevant authorities in a timely manner, especially important before entering into business relations with customers, for this purpose legal checks are regularly carried out on any monetary transactions.

Special Rules

The seller of online gambling entertainment is obliged to ensure compliance with all requirements and provide its services in accordance with the gambling license of Curaçao, which is valid in the international market.

Crime, Irregularities and AML Policy

All anti-money laundering policies are based on a set of practices and principles: 

  • We regularly evaluate the operation of our systems and controls; 
  • We train all our staff who are involved in the operation; 
  • We assess all risks and RBI at least once a year;
  • We take full responsibility for ensuring that we combat money laundering;
  • We act legally, objectively and independently.

Risk Management

We adhere to the Money Laundering Regulations 2007 (the “Money Laundering Regulations 2007”, the “Act”) as required by UK law. This policy provides a sound approach that is based on analyzing all possible risks by taking individual steps to help mitigate the risks associated with money laundering. What we do to do this: 

  • Monitor and optimize all available controls; 
  • Accounting for all actions taken and for what purpose;
  • Implementing procedures to manage assessed risks; 
  • Identifying any risks.

Suspicious Activity

Where suspicious transactions or any other activity is detected, such as customer profiles whose deposits differ from the standard elements. For this purpose, we identify users and carry out due diligence: identity verification via passport, bank statements, utility bills.

Suspicious Activity Reports

As part of our quality approach to security, we produce regular suspicious activity reports. Bookmaker ensures that any employee is required to report to the risk assessment team if there is evidence or reasonable suspicion that a user or users are linked to money laundering or financial terrorism. If a company employee knew about what was going on and had evidence, but did not report it, this is also a reason for criminal prosecution. To maximize confidentiality, OPA escalations should always be in handwritten form, not by email address. 

If a customer has been involved in illegal activity, an employee of the gaming platform may not disclose information that is related to the OPA while the investigation is active.

Operating Procedure

Any transactions related to the withdrawal of won funds on the gaming platform are carried out after the employees check the spending of clients and the gaming process itself, in order to identify suspicious activity in time.

It is recommended to use the same payment method for withdrawals as for deposits.

The history of all deposits and other monetary transactions of each customer is checked to confirm that there are no suspicious payments.

Withdrawal Procedure

In order to approve money transfers to customers, the platform must answer a few mandatory questions before encouraging the withdrawal of won funds: 

  • Has the user placed bets and how regularly? 
  • Does the payment method belong to the customer who applied for the withdrawal? 
  • Can it be considered that the transactions and bets of the customer are in line with the expectations of the user?

Escalation Process

It is crucial for the company to comply with all applicable policies regarding ROB and the escalation of any suspicious customer activity, as this helps to ensure stability and ensure no financial losses.

Senior Management

If it is found that illegal activity has been observed but the necessary action has not been taken, senior management will be held responsible.

Specialist for Reporting Money Laundering

Our company employs a specialist who has been appointed by the IODE – Nikos Lazos, [email protected], +35780077001, who is directly responsible for preventing the detection of any illegal activity related to money laundering. This specialist is also responsible for the fulfillment of the gaming platform’s obligations under the Proceeds of Crime Act 2000 and separately for the OPA related to the systems located in Malta. In order to perform its duties properly, the IODE has the right to act independently and to have constant access to all resources that may contribute to the fulfillment of professional duties.

Staff Training

All employees who are involved in the operation of the gaming platform are required to undergo mandatory training to ensure that they are fully informed of their responsibilities regarding the submission of regular reports on money laundering or any other suspicious customer activity. All employees are also aware that breach of these obligations may result in criminal and administrative liability.

High Risk Jurisdictions

Clients who reside in high risk jurisdictions for suspected money laundering or any other suspicious activity may be subject to regular enhanced checks. For the time being, we provide below a list of current high risk jurisdictions which has been compiled by the GFMDB: 

  • Afghanistan; 
  • Algeria; 
  • Angola; 
  • Bosnia and Herzegovina; 
  • Ecuador; 
  • Guyana; 
  • Iraq; 
  • Lao People’s Democratic Republic; 
  • Myanmar; 
  • Panama; 
  • Papua New Guinea; 
  • Syria; 
  • Uganda; 
  • Yemen; 
  • Iran; 
  • Democratic People’s Republic of Korea.


Our company can ensure that we have an audit log, so that when financial investigations are necessary, we can help law enforcement agencies find out the truth. The following areas can be found in our accounting policies: 

  • All designated employees report to senior management; 
  • Training records are maintained for all employees and for incidental monetary transactions; 
  • Storing identification and verification information on all active customers; 
  • OPA loya of internal and external recipients; 
  • Information and reports on which staff members have monitored compliance with any particular OPA.

Verification Procedures for New Clients

During the recruitment procedure for new staff, the company carries out a number of procedures to ensure that the prospective employee is of legal age. Identification and credentials are also verified and we use several independent sources to perform this verification.

Protecting Our Equipment From Internal Crime and Misuse

To minimize the likelihood of misuse of one of our key assets, we allocate the most valuable assets in advance. Our gaming company’s service equipment is shared with Unicept Malta, as this allows for visitor access control, testing procedures, means of destroying confidential documents, lockable cabinets and a security service.

Compliance and Risk Committee

In the near future, we plan to organize a Compliance and Risk Committee consisting of the CODM, the Compliance Officer and the Director. This committee will meet at least quarterly or as needed.

Checking the Solvency and Reputation of the Companies We Deal With

When cooperating with any suppliers, we check and promote the principles of professional and business ethics at all possible levels. When selecting suppliers with whom we want to start cooperation, we pay attention to the following criteria: 

  • Willingness to ensure a high level of quality of the product provided; 
  • Compliance with the requirements of all necessary NAPs; 
  • Financial stability; 
  • Commitment to a broader corporate responsibility program.

Any potential supplier is subject to an approval process and any information they provide is thoroughly vetted.

Our Responsibilities Under the Proceeds of Crime Act

We apply all relevant policies and procedures that relate to the Proceeds of Crime Act 2002.

Internal Accounting

Below we provide an overview of the basic principles of “know your client”, how regulatory requirements and laws are monitored. 

  • Regardless of how often a customer actively visits our gaming platform we keep all records for at least 6 years even after we have ended the relationship with the customer; 
  • Records of money laundering investigations and suspicious activity reports will be retained for 6 years after the investigation has been completed; 
  • Any data regarding money transfers and transactions will also be retained for 6 years.

Compliance With Collusion Prevention and Data Protection Requirements

Users who wish to visit our gaming platform sign a user agreement stating that any fraud is strictly unacceptable and if detected, all user accounts will be immediately blocked without the possibility of further recovery. 

Payment IQ service and our company employees have access to users’ payment information in order to further protect all data related to user accounts for payments.

Know Your Customer


If you agree to the terms and conditions, you automatically authorize us to carry out absolutely any checks that may be required or requested by a third party, for example to verify customer contact and personal data. During the verification process, we may prohibit you from withdrawing your winnings from the platform’s game balance. 

  • If we discover false or misleading information, we have the right to terminate your account and game account immediately;
  • If our company is unable to verify that the user is of legal age, we also have the right to restrict the operation of the gaming account.

Purpose of the Policy

Our company has the right to request the user to confirm its services in the following situations: 

  • Violation of the terms and conditions stipulated in the Company’s terms and conditions; 
  • If you are suspected of money laundering, fraud, criminal or terrorist financial activity; 
  • If the documents that you have provided to prove your identity are questionable; 
  • Any other situation that may affect the Company’s operations; 

If the above information is found, the Company may ask you to provide details or copies of the following documents: 

  • Place and address of permanent residence; 
  • Full and correct full name; 
  • Full date of birth; 
  • Permanent Citizenship; 
  • Identification number; 
  • What copies of documents can exactly fit: 
  • Passport; 
  • Customer ID; 
  • National ID card; 
  • Photographs of the user with their passport uncovered; 
  • Photographs of the front of the bank card; 

Also, in some cases, the company may ask you to provide documents that can prove your sources of income that you use for betting or gaming. 


  • Due Diligence (Due Diligence): The Company’s customers must be subject to the Due Diligence process and records must be kept.
  • Anonymous Accounts. Any nominee or anonymous accounts are prohibited; 
  • Duplicate/Multiple Accounts. The use of parallel accounts as gambling expense sharing is also discouraged; 
  • Influential Political Persons (IDPs). The Company has the right to respond to any attempts by political persons or their family members to start gambling on the platform. 

We also reserve the right to unilaterally reject customer applications or terminate cooperation with such without explanation or clarification in case of violations of the “Know Your Customer” policy.