Anti-Money Laundering (AML) Policy
This AML Policy outlines the framework and procedures that BogartCasino has established to comply with all relevant AML laws and regulations. It demonstrates our unwavering commitment to preventing money laundering and terrorist financing by fostering a culture of compliance and vigilance throughout our organization. We recognize that the landscape of financial crimes is continually evolving, and as such, we are committed to regularly updating our policies and procedures to stay ahead of emerging threats.
1. Legal and Regulatory Framework
BogartCasino, owned and operated by INTERNATIONAL RADICAL INVESTMENT SOCIEDAD ANONIMA, functions under the legal jurisdiction of Costa Rica. Additionally, it holds a license in Curaçao under Licence GLH-OCCHKTW0703302016 issued by Gaming Services Provider N.V. BogartCasino adheres to the AML regulations and guidelines set forth by these jurisdictions, as well as international standards. The company is committed to complying with all relevant laws to prevent money laundering and terrorist financing, ensuring that all operations are conducted with the highest level of integrity and transparency.
2. AML Compliance Officer
BogartCasino has appointed an AML Compliance Officer who is responsible for overseeing the implementation of this AML Policy, ensuring compliance with relevant regulations, and reviewing the effectiveness of AML procedures.
3. Customer Due Diligence (CDD)
3.1 Identification and Verification: BogartCasino conducts thorough customer due diligence (CDD) on all customers to verify their identity using reliable and independent sources. This includes obtaining identification documents, such as passports or national ID cards, and verifying the accuracy of the information provided.
3.2 Enhanced Due Diligence (EDD): Enhanced due diligence is performed for customers presenting higher risk, including politically exposed persons (PEPs) and customers from high-risk jurisdictions. This includes obtaining additional information and approval from senior management before establishing a business relationship.
3.3 Ongoing Monitoring: BogartCasino continuously monitors customer transactions and account activity to detect any unusual or suspicious patterns that may indicate money laundering or terrorist financing.
4. Reporting Suspicious Activity
4.1 Internal Reporting: Employees of BogartCasino are required to report any suspicious transactions or activities to the AML Compliance Officer immediately upon identification.
4.2 External Reporting: BogartCasino will file suspicious activity reports (SARs) with relevant authorities as required by law and cooperate fully with law enforcement agencies in any investigation related to money laundering or terrorist financing.
5. Record Keeping
BogartCasino maintains comprehensive records of all transactions, customer identification and verification documents, and SARs for a period as required by applicable laws and regulations.
6. Employee Training
All employees of BogartCasino receive regular training on recognizing and handling transactions and activities that may be related to money laundering or terrorist financing. Training programs are updated regularly to ensure compliance with current laws and best practices.
7. Risk Assessment and Management
7.1 Risk Assessment: BogartCasino conducts periodic risk assessments to identify and evaluate the risks of money laundering and terrorist financing associated with its business activities. Factors considered in the risk assessment include customer profiles, transaction volumes, geographic locations, and products offered.
7.2 Risk Mitigation: Based on the risk assessment, BogartCasino implements risk-based controls and mitigation measures, including:
- Enhanced Transaction Monitoring: Utilizing automated systems to monitor transactions in real-time for unusual patterns or behaviors indicative of money laundering.
- Transaction Limits and Controls: Setting transaction limits based on customer risk profiles and conducting enhanced scrutiny for transactions exceeding predetermined thresholds.
- Enhanced Due Diligence: Applying enhanced due diligence measures for high-risk customers, including additional verification steps and ongoing monitoring.
- Suspicious Activity Reporting: Establishing clear procedures for reporting suspicious activities internally and externally to relevant authorities promptly.
8. Definition of Money Laundering
Money Laundering refers to the process by which criminals disguise the original ownership and control of the proceeds of criminal conduct by making such proceeds appear to have derived from a legitimate source. This includes activities such as:
- Placing illicit funds into the financial system
- Layering transactions to obscure the audit trail
- Integrating laundered funds back into the economy as legitimate wealth
9. Compliance Review
The AML Compliance Officer conducts periodic reviews of BogartCasino’s AML Policy and procedures to assess their effectiveness and make any necessary updates or improvements.
BogartCasino is committed to maintaining a strong AML compliance framework to protect its business and the broader financial system from the risks of money laundering and terrorist financing. This AML Policy is regularly reviewed and updated to reflect changes in regulatory requirements and evolving best practices.
