Anti-Money Laundering (AML) Policy
This AML Policy outlines the procedures and framework Bogart Casino has implemented to ensure compliance with applicable AML laws and regulations. We are committed to preventing money laundering and terrorist financing by fostering a culture of compliance and vigilance across our organization. Recognizing the evolving nature of financial crimes, we continuously update our policies to stay ahead of emerging threats.
1. Legal and Regulatory Framework
Bogart Casino, owned by INTERNATIONAL RADICAL INVESTMENT SOCIEDAD ANONIMA, operates under the jurisdiction of Costa Rica and is licensed by Gaming Services Provider N.V. under Curaçao Licence GLH-OCCHKTW0703302016. Our operations adhere to AML guidelines from these jurisdictions and international standards, ensuring transparency, integrity, and compliance with all relevant laws to combat money laundering and terrorist financing.
2. AML Compliance Officer
We have designated an AML Compliance Officer to oversee the implementation of this policy, ensure regulatory compliance, and review the effectiveness of our AML procedures.
3. Customer Due Diligence (CDD)
3.1 Identification and Verification: We conduct thorough customer due diligence by verifying customers' identities using reliable sources, such as passports or national ID cards, to ensure the accuracy of the provided information.
3.2 Enhanced Due Diligence (EDD): High-risk customers, such as politically exposed persons (PEPs) or those from high-risk regions, undergo enhanced due diligence, requiring additional information and senior management approval before establishing business relationships.
3.3 Ongoing Monitoring: Customer transactions and account activities are continuously monitored to detect unusual or suspicious patterns indicative of money laundering or terrorist financing.
4. Reporting Suspicious Activity
4.1 Internal Reporting: Employees are required to report any suspicious activity immediately to the AML Compliance Officer.
4.2 External Reporting: Suspicious Activity Reports (SARs) are submitted to relevant authorities as required, and we fully cooperate with law enforcement in investigations involving money laundering or terrorist financing.
5. Record Keeping
All customer information, verification documents, transactions, and SARs are retained for the legally required period to ensure compliance.
6. Employee Training
Employees receive ongoing training on identifying and managing suspicious activities. Training programs are updated regularly to reflect changes in laws and best practices.
7. Risk Assessment and Management
7.1 Risk Assessment: We conduct periodic risk assessments to identify potential money laundering risks based on customer profiles, transaction volumes, geographic locations, and products offered.
7.2 Risk Mitigation:Based on risk assessments, we implement controls such as:
- Enhanced Transaction Monitoring: Automated systems monitor transactions in real-time for unusual patterns.
- Transaction Limits and Controls: Limits are set according to customer risk profiles, with extra scrutiny on transactions above certain thresholds.
- Enhanced Due Diligence: Additional verification steps and ongoing monitoring are applied to high-risk customers.
- Suspicious Activity Reporting: Clear procedures are in place for reporting suspicious activities to internal and external authorities.
8. Definition of Money Laundering
Money laundering refers to the process by which criminals disguise the ownership and origin of illegal funds, making them appear legitimate. This typically involves:
- Placement: Introducing illicit funds into the financial system.
- Layering:Obscuring the audit trail through complex transactions.
- Integration:Reintroducing laundered funds into the economy as legitimate assets.
9. Compliance Review
The AML Compliance Officer conducts regular reviews of the AML policy and procedures to ensure their effectiveness and make necessary updates.
Bogart Casino remains committed to maintaining a robust AML framework to safeguard our business and the financial system from the risks of money laundering and terrorist financing. Our AML policy is reviewed and updated regularly to align with evolving regulations and best practices.
