AML/CFT Policy
AML/CFT Policy
AML/CFT Policy
AML/CFT Policy

Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy

Legal Entity: INTERNATIONAL RADICAL INVESTMENT SOCIEDAD ANÓNIMA

License: Anjouan Gaming License Authority (AGLA)

License No. ALSI-202509042-FI1

Effective Date: Immediately

1. Introduction

BogartCasino.ag is firmly committed to preventing its sportsbook and casino operations from being used for money laundering (ML) or the financing of terrorism (FT). This AML/CFT Policy is implemented in accordance with:

  • The KYC & AML Code of Conduct for Anjouan Internet Gaming Operators
  • Anjouan Gaming License Authority (AGLA) regulations
  • Financial Action Task Force (FATF) Recommendations
  • UN and OFAC sanctions lists
  • International best practices in remote gaming compliance

BogartCasino adopts a risk-based approach, complete due diligence procedures, continuous monitoring, and strict reporting obligations. This policy applies to all employees, contractors, affiliates, and third-party service providers.

2. Regulatory Framework

BogartCasino.ag complies with:

  • The AML/CFT laws of the Autonomous Island of Anjouan
  • AML guidance issued by Anjouan Licensing Services Inc.
  • FATF global standards
  • UN Security Council and OFAC sanction
  • Industry standards for online gaming integrity

This policy is reviewed and updated to reflect changes in AGLA directives and international AML/CFT trends.

3. Core Principles

BogartCasino adheres to the following AML/CFT pillars:

  • Risk-Based Approach (RBA)
  • Verification of customer identity
  • Ongoing monitoring of transactions and behavior
  • Timely reporting to regulatory authorities
  • Internal controls, training, and accountability
  • Record retention for the legally required duration
  • Zero tolerance for ML/FT activities

AML POLICY

4. Risk Assessment

BogartCasino conducts ongoing risk assessments covering:

  • Customer profiles
  • Geographic exposure
  • Payment channels
  • Betting patterns and product risk
  • Sanctioned or high-risk jurisdictions

A full AML/CFT risk assessment is performed annually and whenever operational changes occur.

5. Customer Due Diligence (CDD)

5.1 Mandatory Verification Triggers (AGLA-Required)

BogartCasino must verify customer identity:

  • At first withdrawal — regardless of amount
  • Or when cumulative deposits reach USD $10,000
  • Or anytime suspicious activity is detected

5.2 Required CDD Information

  • Full name
  • Date of birth
  • Residential address
  • Nationality
  • Valid government-issued photo ID
  • Proof of address (issued within 6 months)
  • Phone and email verification

5.3 Verification Methods

  • Certified document copies
  • Electronic identity checks
  • Cross-referencing independent source

If verification cannot be completed, the account may be suspended or closed.

6. Enhanced Due Diligence (EDD)

EDD is required for high-risk customers, including:

  • Politically Exposed Persons (PEPs)
  • Customers from high-risk jurisdictions
  • Complex or unusually large transactions
  • Activity inconsistent with known customer profile

EDD may include:

  • Source-of-funds (SOF) verification
  • Source-of-wealth (SOW) documentation
  • Additional identity documents
  • Senior management approval
  • Enhanced and frequent monitoring

7. Ongoing Monitoring

BogartCasino continuously monitors:

  • Rapid deposit–withdraw cycles
  • Unusual or complex transactions
  • Structuring transactions to avoid $10,000 reporting
  • Use of anonymizing tools (VPNs, TOR, proxies)
  • Multiple accounts or identity inconsistencies
  • High-risk payment behaviors
  • Inconsistent betting patterns

Automated monitoring tools flag relevant activity for manual review by the Compliance Department.

8. Suspicious Activity Reports (SAR)

BogartCasino must file a SAR:

  • Within 24 hours of detecting suspicious activity

SARs include:

  • Full customer details
  • Description of suspicious activity
  • Supporting evidence

Customers must not be informed of SAR filings (“no tipping off”).

9. Currency Transaction Reports (CTR)

BogartCasino must report:

  • Any transaction or linked transactions exceeding USD $10,000

This applies to deposits, withdrawals, transfers, and currency conversions.

10. Internal Controls & AML Compliance Officer

BogartCasino appoints a qualified Money Laundering Reporting Officer (MLRO) with responsibility for:

  • Enforcing AML/CFT procedures
  • Reviewing alerts and approving escalations
  • Filing SARs/CTRs
  • Ensuring compliance with AGLA directives
  • Maintaining AML/CFT records
  • Overseeing training programs

Internal controls ensure:

  • Segregation of duties
  • Restricted access to sensitive data
  • Independence of the Compliance function

11. Employee Training

Mandatory AML/CFT training is provided:

  • At onboarding
  • Annually
  • When regulations change
  • After internal incidents or breaches

Training includes:

  • AML/CFT red flags
  • CDD/EDD procedures
  • SAR/CTR reporting obligations
  • Sanctions list interpretation
  • Responsible gaming interaction

12. Cybersecurity & Data Protection

BogartCasino maintains industry-standard security measures:

  • Secure servers with restricted physical access
  • Encryption, firewalls, intrusion-detection systems
  • Anti-malware and anti-fraud systems
  • Continuous vulnerability testing

Security incidents must be reported to AGLA within 24 hours.

13. Record Keeping

BogartCasino retains all AML/CFT records for:

  • A minimum of 5 years after account closure
  • Longer if required by law or if an investigation is ongoing

Records include:

  • CDD/EDD documentation
  • Verification logs
  • Transaction histories
  • Monitoring alerts
  • SAR/CTR filings
  • Audit reports
  • Training logs

Records must be secure, confidential, and accessible to regulators upon request.

COUNTER-FINANCING OF TERRORISM (CFT) POLICY

14. Definition

Terrorist financing may involve lawful or unlawful funds used to facilitate terrorist activities. BogartCasino monitors customer activity for both financial and behavioral indicators.

15. CFT Risk-Based Approach

Heightened screening applies to:

  • Sanctioned jurisdictions
  • Conflict-prone regions
  • Transactions with no clear economic purpose
  • Use of anonymizing technologies (VPNs, crypto mixers)

16. CFT Monitoring

Additional scrutiny applies to:

  • Sanctioned countries
  • Conflict zones
  • Individuals linked to terrorism-related concerns
  • Complex patterns without legitimate economic rationale

16. CFT Monitoring Measures

BogartCasino monitors:

  • High-velocity deposits or withdrawals
  • Sudden changes in behavior or transaction size
  • Accounts attempting to evade verification
  • Use of anonymity tools or obscure payment methods

CFT monitoring applies the same risk-based methodology, thresholds, and escalation procedures as the AML monitoring controls outlined in Section 7 of this Policy.

17. CFT Investigation & Reporting

If terrorist financing is suspected:

  • A CFT investigation is immediately opened
  • A SAR is filed within 24 hours
  • Accounts may be suspended or frozen
  • Customer is not notified
  • Authorities are fully cooperated with

18. CFT Documentation & Zero Tolerance

All CFT records are maintained for minimum 5 years.

BogartCasino enforces a zero-tolerance policy:

  • Immediate account closure
  • Reporting to authorities
  • Permanent exclusion from the platform

19. Independent AML/CFT Audits

BogartCasino undergoes:

  • Annual independent AML/CFT audits, as mandated by AGLA
  • Random inspections if requested by the regulator

Findings are used to strengthen internal AML/CFT controls.

20. Continuous Improvement

BogartCasino continuously updates:

  • Monitoring systems
  • Data analytics
  • Sanctions databases
  • Policies and procedures
  • Staff training

This ensures ongoing alignment with AGLA directives and global best practices.