Last updated: 22 August 2022 🛡️
This document sets out the official AML & KYC framework for services available at rirabetbet.com (“the Platform”). The purpose is to provide a secure and transparent environment, aligned with internationally recognized standards, to help prevent money laundering, terrorist financing, fraud, and other illicit financial activity. By registering and using the Platform, users acknowledge and accept this Policy and agree to cooperate with all due diligence requirements. ✅
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Scope, Objectives, and Core Principles
This Policy applies across the customer lifecycle, including onboarding, deposits and withdrawals, monitoring, record retention, reporting, and relationship termination. Controls are implemented under a risk-based approach (RBA) that scales with product, channel, geography, and user risk. 📘
- Prevention: deter the introduction of illicit funds into the financial system.
- Detection: identify unusual patterns via continuous monitoring and data analytics.
- Remediation: place holds, suspend activity, request additional evidence, and report to competent authorities where required.
- Privacy by design: collect the minimum necessary data and protect it with appropriate safeguards. 🔒
Regulatory Baseline and References
The Platform endeavors to align with internationally accepted AML expectations. The following resources are cited for high-level reference and do not supersede applicable local law:
| Source | Subject |
|---|---|
| Directive (EU) 2015/849 | Prevention of the use of the financial system for money laundering or terrorist financing. |
| Regulation (EU) 2015/847 | Information accompanying transfers of funds. |
| Sanctions Frameworks | Restrictive measures on listed persons/entities; controls on dual-use items. |
| Data Protection Principles | Fair processing, necessity, proportionality, security of personal data. |
Key Definitions
Money laundering includes converting, transferring, concealing, acquiring, possessing, or using property known to be derived from criminal activity, and participating, assisting, or facilitating the foregoing. It remains an offense even when the predicate conduct occurs in another jurisdiction. ⚖️
Governance and Accountability
- Senior management oversight: ultimate responsibility for the effectiveness of the AML/KYC framework.
- AML Compliance Officer (AMLCO): responsible for policy implementation, training, monitoring, investigations, and liaison with competent authorities; reports directly to senior management.
- Change control: material policy changes require AMLCO and senior management approval prior to implementation. 🧭
Customer Due Diligence (CDD) and KYC
The Platform applies multi-step verification. The depth of checks increases with risk and transactional thresholds.
Step 1: Core Registration
- Collection of first and last name, date of birth, country of usual residence, gender, and full address.
- Step 1 is mandatory prior to any withdrawal and forms the baseline for subsequent monitoring. 📝
Step 2: Identity Verification (≥ USD 2,000 or equivalent in deposits/withdrawals)
- Submission of an official photo ID (passport, national ID, or driver’s license) displayed next to a handwritten note with a six-digit random code.
- Electronic checks against two independent databases to validate consistency with Step 1 data.
- If e-verification is inconclusive, a proof of residence issued by a competent authority is required.
- Deposits, tips, or withdrawals remain on hold until Step 2 is completed. ⏳
Step 3: Source of Wealth/Funds (≥ USD 5,000 or P2P transfers ≥ USD 3,000)
- Enhanced due diligence to establish Source of Wealth (SoW) and Source of Funds (SoF).
- Illustrative SoW: employment income, business ownership, investments, inheritance, or verified family support.
- Transactions remain on hold until Step 3 is completed and validated. 🧾
Document Standards
- Photo ID: all four corners visible; details clearly legible. Users may redact nonessential fields, except name, date of birth, nationality, gender, and photograph. Additional details may be requested where necessary.
- Selfie check: a separate live photo may be required to prevent impersonation.
- Proof of Address (PoA): recent utility bill, bank statement, or government letter issued within the last 90 days, with all text readable and all corners visible.
- Payment method mirroring: withdrawals follow the original deposit method up to the deposited principal to mitigate third-party risk. 🔁
Risk Segmentation and Thresholds
Users are segmented by jurisdiction, payment rails, activity patterns, and sanctions screening results. Classification can change over time.
| Risk Tier | Baseline Controls | Trigger Thresholds |
|---|---|---|
| Low | Standard three-step verification; periodic monitoring. | Step 2 at ≥ 2,000; Step 3 at ≥ 5,000 (USD equivalent). |
| Medium | Earlier EDD triggers; crypto-to-fiat conversions reviewed in this tier. | Step 2 at ≥ 1,000; Step 3 at ≥ 2,500; P2P at ≥ 500/1,000. |
| High | Restricted or prohibited onboarding; periodic list review. | Permissibility determined by applicable law and policy. |
Ongoing Transaction Monitoring
- First line of control: use of trusted Payment Service Providers operating robust AML programs to intercept suspicious deposits before crediting. 🏦
- Second line of control: internal monitoring that combines automated analytics with manual review. Any interaction about payment instruments or account changes triggers appropriate due diligence.
- Third line of control: manual enhanced reviews for higher-risk users and filing of reports with the Financial Intelligence Unit (FIU) when warranted. 🚨
Behavioral Analytics and Interventions
- Identification of patterns such as rapid deposit–withdrawal cycling with minimal play, use of mismatched payment instruments, sudden changes in location/currency/device, and anomalies in session behavior.
- Where lawful origin cannot be reasonably established, the account may be restricted or frozen pending resolution. 🧊
Reporting Suspicious Activity (SAR)
Staff follow documented internal procedures that specify when and how to escalate unusual activity. Following analysis, the AML team may file a report with the relevant FIU and/or terminate the business relationship. All personnel are obligated to notify the AML function of atypical transactions that cannot be attributed to a legitimate source of income. 📮
Enterprise-Wide Risk Assessment (EWRA)
An organization-level AML risk assessment is conducted at least annually to evaluate inherent and residual risks across products, user segments, transactions, delivery channels, and geographies. Outcomes inform control design, resourcing, and staff training. 📊
Recordkeeping
- Identity data: retained for at least 10 years after the end of the business relationship.
- Transaction records: retained for at least 10 years after execution or relationship termination, whichever is later.
- Security: data stored securely, encrypted, and access-controlled on a need-to-know basis. 🗄️
Data Protection and Privacy
Personal data is not sold and is disclosed only where legally required, for AML/CTF prevention and detection, or to comply with applicable sanctions obligations. Users should consult Platform privacy communications for more information on data subject rights. 🔐
Enforcement and Consequences
- Failure to complete required verification results in holds on deposits, tips, or withdrawals until compliance steps are completed.
- Use of third-party payment instruments, identity misrepresentation, or attempts to bypass controls may lead to immediate suspension and regulatory reporting.
- Additional documentation may be requested at any time based on cumulative risk. ⚠️
User Responsibilities
- Provide accurate, current information and promptly respond to compliance requests.
- Use payment methods issued in the same name as the verified account holder.
- Cooperate with SoW/SoF checks when thresholds are met. ✅
Acceptable Evidence for Source of Wealth/Funds
- Employment: recent payslips or a verified employment contract.
- Business ownership: corporate filings, dividend statements, or audited accounts.
- Investments: brokerage statements or bank confirmations.
- Inheritance/Gifts: probate documentation or notarized gift statements.
Cash Handling and Additional Controls
Where cash deposits or withdrawals are supported, stricter identification, up-to-date PoA, and thorough SoF reviews apply to address the elevated risk. 💵
Payments Integrity
- Method mirroring: withdrawals must follow the original deposit route up to the deposited principal.
- Name matching: the name on the payment instrument must match the verified account holder’s name. 🔎
Training and Awareness
- Mandatory AML training for staff in finance/compliance, reflecting current regulatory expectations.
- Induction modules for new employees covering red flags and reporting channels.
- Periodic refreshers and scenario-based exercises under AMLCO supervision. 🎓
Internal Audit
Independent internal audit missions periodically assess AML control effectiveness and issue recommendations for continuous improvement. 🧩
Policy Review and Conflicts
- This Policy is reviewed at least annually and updated upon material regulatory or risk changes.
- Where conflicts arise, the stricter requirement prevails. 📑
Contact
For questions about your verification status, SoW/SoF requirements, or to report suspicious activity, contact: [email protected] 📧
Important Notes
- This Policy is an integrity safeguard and does not constitute an invitation to engage in high-risk financial behavior.
- If uncertain about the legitimacy of funds or how to complete documentation, contact support and avoid submitting sensitive data through untrusted channels. 🧠