1. Policy Objective
zamba.bet is fully committed to preventing money laundering and combating the financing of terrorism in all jurisdictions in which it operates. This Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy is established in accordance with the Anti-Money Laundering and Counter-Terrorist Financing Regulations issued by the Anjouan Offshore Financial Authority (AOFA), the applicable Anti-Money Laundering laws of the Union of Comoros, and the recommendations of the Financial Action Task Force (FATF). zamba.bet is committed to complying with all applicable regulatory requirements and international standards aimed at preventing money laundering, terrorist financing, and other financial crimes.
2. Obligations
- Appointment of MLRO: zamba.bet shall appoint a senior executive as the Money Laundering Reporting Officer (MLRO), responsible for fulfilling duties prescribed by law and regulation, overseeing AML strategy, reporting suspicious activity, and ensuring compliance. The Money Laundering Reporting Officer (MLRO) shall act independently and shall not be subject to any commercial, operational, or financial influence. The MLRO is granted full authority to access all customer records, transaction data, and internal systems necessary to perform AML/CFT duties. The MLRO is authorized to suspend customer accounts, freeze transactions or funds, and submit reports directly to the Financial Intelligence Unit (FIU) and the Anjouan Offshore Financial Authority without prior approval from management.
- Suspicious Activity Reporting: Any suspicion of money laundering must be reported to the MLRO. Employees must not inform the customer and must await instructions from the competent authority. All suspicious activity reports shall be escalated to the MLRO, who is responsible for submitting Suspicious Activity Reports (SARs) to the Financial Intelligence Unit (FIU) and, where required, notifying the Anjouan Offshore Financial Authority (AOFA) in accordance with applicable laws and regulations.
- Customer Identification and Verification (KYC): Implementation of a comprehensive Know Your Customer policy, including document verification, automated tools, and risk assessment.
- Secure Player Registry: Maintenance of a secure and up-to-date database of all players, accessible only to authorized personnel.
- Document Retention: Retention of identification and transaction records in accordance with applicable legislation, for required periods, with secure storage.
- No Cash Transactions: Operations are conducted exclusively without the use of physical cash.
- Transaction Monitoring: All transactions are recorded and periodically reviewed for unusual patterns, social responsibility indicators, and potential fraud.
- High-Risk Customers: Maintenance of a register of high-risk customers and Politically Exposed Persons (PEPs), subject to Enhanced Due Diligence (EDD) and more frequent reviews.
- Suspicious Transactions: Monitoring to prevent money laundering and terrorist financing; suspicious transactions are reported immediately to the authorities.
- Fraud Detection and Response: In cases of suspicion, the risk and fraud department may request additional documentation; the account will be suspended pending verification, and authorities may be notified.
- Sanctions Screening: zamba.bet shall screen all customers, beneficial owners, and relevant counterparties against applicable international sanctions lists, including the United Nations Security Council Sanctions Lists, at the time of onboarding and on an ongoing basis. Any positive or potential sanctions match shall result in immediate account suspension and escalation to the MLRO for further investigation and reporting.
3. Training and Awareness
Initial and ongoing training is provided to relevant teams, covering personal responsibilities, KYC, activity monitoring, recordkeeping, reporting of suspicious transactions, management of high-risk accounts (including PEPs), and EDD. Training materials are updated regularly.
4. Customer Due Diligence (CDD/EDD)
A risk-based approach is applied to CDD (verification of identity, address, and relevant data). For high-risk customers (including PEPs), EDD is conducted, including enhanced identity verification, source-of-funds checks, continuous monitoring, and in-depth analysis.
Source of Funds and Source of Wealth: For high-risk customers and politically exposed persons (PEPs), zamba.bet shall obtain and verify information regarding both the source of funds and the source of wealth. Source of funds refers to the origin of the specific funds used for transactions on the platform, while source of wealth refers to the customer's overall financial background and economic activities. Enhanced Due Diligence shall not be completed until satisfactory evidence has been obtained.
5. Monitoring and Reporting
Real-time monitoring systems with predefined risk scenarios are used to detect suspicious activity. The MLRO submits Suspicious Activity Reports (SARs) to the authorities promptly and confidentially. zamba.bet expressly prohibits any activity related to the financing of terrorism. Terrorist financing refers to the provision, collection, or use of funds for the purpose of supporting terrorist acts or organizations. All transactions shall be monitored to detect indicators of terrorist financing, and any suspicion shall be immediately reported to the MLRO for escalation to the FIU and AOFA as required.
6. Recordkeeping and Data Protection
Records are securely retained for legally required maximum periods, with restricted access and compliance with data protection laws (GDPR and other applicable regulations). zamba.bet shall retain all AML, KYC, and transaction records for a minimum period of five (5) years from the date of account closure or the completion of the transaction, whichever is later. Records shall be stored securely and made available promptly to competent authorities upon request.
7. Audits and Reviews
Regular internal AML audits are conducted, documented, and reviewed by senior management. The policy is updated periodically to reflect regulatory and technological changes.
Enterprise-Wide AML Risk Assessment: zamba.bet shall conduct an enterprise-wide AML/CFT risk assessment at least annually. The assessment shall identify and evaluate risks related to customers, products, jurisdictions, payment methods, and transaction patterns. The results shall be documented, reviewed by senior management, and used to enhance AML controls and procedures.
8. Cooperation with Authorities
Full cooperation is provided to administrative, law enforcement, and judicial authorities in the prevention and detection of unlawful activities.
9. Politically Exposed Persons (PEPs)
Identification and monitoring of PEPs, their family members, and close associates, with appropriate EDD measures.
10. Customer Declarations
Customers must declare the legitimacy of their funds. zamba.bet may investigate the source of funds and retain amounts suspected of being linked to illegal activities.
11. Deposits and Withdrawals
- Transactions must be conducted in approved currencies.
- Minimum deposit amounts are defined by zamba.bet and communicated to players.
- Payment accounts must be held in the customer's name; ownership may be verified.
- Withdrawals should preferably be made using the same method as the deposit; where not possible, bank transfer may be used.
- On the first withdrawal, the following will be required: government-issued photo ID with date of birth; proof of address; proof of ownership of the payment method.
- Player accounts must not be used as bank accounts; where deposits or withdrawals occur without gambling activity, zamba.bet may request clarification before processing.