سیاست AML/KYC | ضدپولشویی

Domain: ace-bet90.com | Title: ace bet 90 | Last updated: 22 August 2022 ✅

Welcome to the official AML/KYC framework of ace-bet90.com. This document sets out the governance, controls, and operational standards applied to prevent money laundering (ML), financing of terrorism (FT), and related financial crime across all services offered via our platform. The policy is designed to align with risk-based compliance expectations and internationally recognized guidance to help protect customers, payment partners, and the integrity of the financial system. 🛡️

Important notice: Nothing in this page constitutes legal advice. Local laws and regulatory expectations may vary by jurisdiction. Users remain responsible for ensuring that their use of this website is lawful in their country of residence.

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1) Policy Objective & Scope

The objective of this AML/KYC Policy is to establish a clear framework for:

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) proportional to risk.
Three-step identity verification prior to withdrawals and at risk thresholds.
Ongoing monitoring of accounts, transactions, and customer behavior patterns.
Record keeping for investigative audit trails.
Timely reporting of unusual and suspicious activity to competent authorities, where applicable.

This policy applies to all customers, visitors, employees, contractors, affiliates, and payment/intermediary partners that interact with ace-bet90.com.

2) International Compliance Alignment

Our AML control environment is designed with reference to the following internationally recognized standards and guidance:

EU Directive (EU) 2015/849 (AMLD4) and subsequent amendments on preventing the use of the financial system for ML/FT.
EU Regulation (EU) 2015/847 on information accompanying transfers of funds.
Sanctions and restrictive measures applicable to designated persons, entities, goods, and technologies.
Risk-based approach recommended by global standard setters for ML/FT prevention.

Where required, we incorporate additional safeguards consistent with local laws and partner-bank/payment service provider (PSP) requirements.

3) Definition of Money Laundering

Money laundering refers to activities intended to conceal the illicit origin of assets by converting, transferring, layering, or integrating them into the legitimate economy. This includes:

Converting or transferring property knowing it derives from criminal activity, to disguise its origin or assist others in evading legal consequences.
Concealing the nature, source, location, disposition, movement, or ownership of illicit property.
Acquiring, possessing, or using property with knowledge of its illicit origin at the time of receipt.
Participation in, attempting, aiding, abetting, facilitating, or counselling any of the above.

ML is considered unlawful even if the predicate offense occurred in another country.

4) Governance, Roles, and Responsibilities

Senior Management Accountability: Oversight of AML/KYC strategy, resource allocation, and approval of material policy changes.
AML Compliance Officer (AMLCO): Responsible for implementation, internal reporting, suspicious activity assessments, and liaison with external authorities, where applicable.
First Line (Operations & Support): Executes CDD/KYC, applies risk controls, and escalates red flags.
Second Line (Compliance): Monitors effectiveness, advises on EDD, maintains policies, and performs thematic reviews.
Third Line (Internal Audit): Independently audits AML/KYC controls and issues periodic assurance reports.

5) Customer Due Diligence (KYC)

We apply a three-step verification framework. All withdrawals require at least Step 1 completion. Higher thresholds trigger Steps 2 and 3. Controls may be applied earlier based on risk.

Verification Step	Trigger	What We Collect	Purpose
Step 1: Basic KYC	Required for withdrawals; may be requested at registration	First & last name, date of birth, country of residence, gender, full address	Identity screening, age validation, residency checks
Step 2: ID Verification	Single or cumulative deposits ≥ $2,000 or withdrawals ≥ $2,000	Photo of a valid government ID with a handwritten note showing a 6-digit random code; face photo; electronic data checks; if needed, proof of address (utility bill/bank statement ≤ 3 months or official government letter)	Document authenticity, selfie-match, address confirmation
Step 3: Source of Wealth (SoW)	Deposits ≥ $5,000, withdrawals ≥ $5,000, or peer transfers ≥ $3,000	Evidence of funds/wealth: employment income, business ownership, investments, inheritance, or family support; bank wire/credit card verification	Assess legitimacy of funds and affordability

Image quality rules: All four corners of the ID must be visible and text must be readable. Customers may redact sensitive fields except date of birth, nationality, gender, first and last name, and the photo. Additional documents may be requested where required by risk.

6) Risk-Based Approach & Jurisdictional Controls

We categorize geographies by risk and adapt thresholds accordingly:

Region 1 – Low risk: Thresholds as listed in the table above.
Region 2 – Medium risk: Lowered thresholds: Step 2 at ≥ $1,000 deposit/withdrawal or ≥ $500 peer tip; Step 3 at ≥ $2,500 deposit/withdrawal or ≥ $1,000 tip. Crypto-to-fiat conversions may also be treated as medium risk.
Region 3 – High risk: Access may be restricted or blocked. Lists are reviewed and updated periodically to reflect the evolving risk landscape.

Accounts may be temporarily on hold at any step until verification is completed. Where SoW is unclear or unsupported, additional evidence will be requested, or access may be limited. ⚠️

7) Transaction Monitoring & Controls

We employ layered monitoring and analytics to detect anomalies such as:

Rapid cycles of deposits and withdrawals without meaningful activity.
Mismatched payment instruments or repeated attempts with third-party cards.
Frequent currency/jurisdiction changes, device fingerprint anomalies, or behavioral outliers.
Use of multiple accounts by the same person or coordinated activity that suggests collusion.

Monitoring operates on three lines of control:

First line: Trusted PSPs with robust KYC/AML pre-filters mitigate a majority of suspicious inflows.
Second line: Our support and compliance teams conduct due diligence whenever a customer requests transactions or payment features and review escalations generated by automated systems.
Third line: Manual, case-by-case reviews for higher-risk or flagged customers, with escalation to appropriate authorities where required.

Method matching: Withdrawals must, where feasible, use the same method and instrument used for the initial deposit up to the deposited amount. Remainders may be paid via approved alternatives, subject to risk checks.

8) Suspicious Activity Reporting (SAR)

We maintain internal procedures that guide staff on when and how to escalate unusual activity for review by the AMLCO. After analysis, the AML team may:

File a report with the relevant Financial Intelligence Unit (FIU), where applicable.
Request additional KYC/SoW documentation.
Restrict, suspend, or terminate the business relationship.

Staff are obliged to promptly report any activity they cannot reasonably attribute to a lawful source. 🚨

9) Record Keeping

Identification data: Stored for at least 10 years after the business relationship ends.
Transaction records: Kept for at least 10 years after the transaction or end of relationship.
Security: Records are retained securely using encryption and access controls in both online and offline vaults, consistent with data-protection requirements.

10) Data Protection & Privacy

We process personal data strictly for compliance, risk management, fraud prevention, and service delivery. Data is not sold to third parties. Information may be disclosed only when legally required, to comply with sanctions, or to prevent ML/FT and related crime. We follow applicable data-protection principles, including purpose limitation, storage minimization, accuracy, and integrity/confidentiality. 🔒

11) Staff Training & Awareness

Mandatory AML training for all relevant personnel, refreshed to reflect regulatory changes and emerging typologies.
Onboarding education for new hires on KYC/CDD, EDD, red flags, and escalation.
Continuous learning through case studies and thematic workshops led by AML specialists.

12) Internal Audit & Testing

Independent audit evaluates the design and operating effectiveness of AML/KYC controls, reviews escalations and SAR decisions, and issues recommendations for remediation and continuous improvement. Findings are tracked until closure.

13) Payment Integrity & Methodology

Only payment methods registered to the customer are permitted. Third-party cards or accounts are prohibited.
Where required by risk, bank wires or card verifications may be requested to corroborate identity and SoW.
Failed or reversed transactions may be investigated; limits and cooling-off periods can be applied.

14) Prohibited & Restricted Activities

Use of stolen or forged identification documents.
Acting on behalf of another person without disclosure and authorization.
Structuring transactions to evade thresholds or surveillance.
Use of VPNs/Proxies to misrepresent location where this conflicts with our risk controls or legal obligations.

15) Enterprise-Wide Risk Assessment (EWRA)

We conduct an annual EWRA covering products, customer types, delivery channels, transaction patterns, and geographic exposure. Outputs inform risk appetite, control enhancements, and training priorities. Results are reviewed by senior management and used to calibrate monitoring models.

16) Customer Support & Communication

Customers can contact us for AML/KYC queries, verification assistance, or to challenge a screening decision. We strive to respond in a timely and professional manner.

Purpose	Channel	Notes
General AML/KYC inquiries	[email protected]	We may require you to respond from your registered email for security.
Appeals / Complaints	[email protected]	Provide your user ID, timestamps, and any supporting documents.

17) Thresholds & Practical Examples

Example A: A customer deposits $2,200. Step 2 ID verification is required before withdrawals proceed.
Example B: A customer receives family support documented by a bank statement and notarized letter. This may satisfy SoW for Step 3 if consistent with profile.
Example C: Multiple deposits from different third-party cards will be declined and reviewed for potential misuse.

18) Policy Changes

Material changes to this AML/KYC Policy are reviewed by senior management and the AMLCO. We may update thresholds, documentary requirements, or monitoring parameters without prior notice if risk conditions warrant. Customers should review this page periodically for the most current version. 🔁

Quick Reference Table

Topic	Baseline Control	Notes
Withdrawals	Require Step 1 KYC	Identity must be verified before funds are released.
Step 2 Trigger	≥ $2,000 deposit/withdrawal	ID + selfie + PoA where needed; enhanced checks may apply.
Step 3 Trigger	≥ $5,000 deposit/withdrawal or ≥ $3,000 peer transfer	Acceptable SoW: salary, business, investments, inheritance, family.
Method Matching	Withdraw via original funding method	Up to the amount deposited; additional risk checks on remainders.
Record Retention	≥ 10 years	From end of relationship or transaction date, whichever is later.

19) Fair Treatment & Accessibility

We aim to apply controls consistently and without bias. Where feasible, we provide clear guidance during verification to minimize delays. If you believe a decision was made in error, contact support for a review. 😊

20) Final Provisions

By accessing and using ace-bet90.com, you acknowledge and agree to comply with this AML/KYC Policy and any associated procedures. Breaches may result in account restrictions, reporting to competent authorities, and termination of services.

Stay safe, verify promptly, and help us keep the platform secure for everyone. 💼🔍