AML and KYC Policy
Last updated: January 7th, 2023
For Cash Deposits and Cash Withdraws
The (AML) Anti-Money-Laundering policy of www.tiger.game
Introduction: www.tiger.game is operated by "iTiger B.V." and has its office at Abraham Mendez Chumaceiro Blvd. 03, Willemstad, Curaçao. Company Registration number 161.788.
The objective of the AML Policy: We seek to offer the highest security to all our users and customers on www.tiger.game. For that, three-step account verification is done to ensure the identity of our customers. The reason behind this is to prove that the registered person's details are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into the accord that different safety measures must be accepted depending on the nationality and origin, the way of payment, and withdrawal.
www.tiger.game also puts reasonable measures in place to control and limit AML risk, including dedicating the appropriate means.
www.tiger.game is committed to high standards of (AML)Anti-Money-Laundering according to the EU guidelines, and compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
The AML program of www.tiger.game is designed to be compliant with:
EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”.
EU: “Regulation 2015/847 on information accompanying transfers of funds”.
EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods.
BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash.
Definition of money laundering
Money Laundering is understood as:
- The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, to conceal or disguise the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person or companies action;
- The concealment or disguise of the true nature, source, location, disposition, movement, rights concerning, or ownership of, property, knowing that such property is derived from criminal activity or an act of participation in such activity;
- The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such activity;
- Participation in, association to commit, attempts to commit and aiding, abetting, facilitating, and counseling the commission of any of the actions referred to in points before;
Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
Organization of the AML for www.tiger.game
In accordance with the AML legislation www.tiger.game has appointed the “highest level” for the prevention of ML: The full management of "iTiger B.V." are in charge.
Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.
The AMLCO is placed under the direct responsibility of the general Management:
AML policy changes and implementation requirements:
Each major change of www.tiger.game AML policy is subject to approval by the general manager of "iTiger B.V." and the Anti-money-laundering compliance officer.
Three-step Verification
The 1st verification:
Every user and customer must do step one verification to withdraw. Regarding the choice of payment, the amount of payment, the amount of withdrawal, the option of withdrawal, and the nationality of the user/customer, step one verification must be done first. Step one verification is a document the user/customer must complete. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender, and complete address.
The 2nd verification:
Step two verification must be done by every user who deposits over 2000$ (two thousand Dollars) or withdraws over 2000$ (two thousand Dollars), or sends another user over 1000$ (one thousand Dollars). The withdrawal, tip, or deposit will be held until step two verification is done. Step two verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must take a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification; depending on the country, the variety of accepted IDs may differ. There will also be an electronic check if the filled-in Data from the step one verification is correct. The electronic check will check via two different databanks to ensure the given information matches with the filled document and the name from the ID: If the electronic test fails or is not possible, the user/customer is required to send in a confirmation of his current residence. A certificate of registration by the government or a similar document is required.
The 3rd verification:
Step three verification must be done by every user who deposits over 5000$ (five thousand Dollars) or withdraws over 5000$ (five thousand Dollars), or sends another user over 3000$ (three thousand Dollars). Until step three verification is done, the withdrawal, tip, or deposit will be held. For step 3, a user/customer will be asked for a source of wealth.
Customer identification and verification (KYC)
The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles:
A copy of your passport, ID card, or driving license, each shown alongside a handwritten note mentioning six randomly generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out all information besides the date of birth, nationality, gender, first name, second name, and picture to secure their privacy.
Please note that all four corners of the ID have to be visible in the same image, and all details must be readable besides the ones named above. We might ask for all details if necessary.
If necessary, an employee may do additional checks based on the situation.
Proof of Address
Proof of address will be done via different electronic checks using two databases. If an electronic test fails, the user/customer can make a manual proof.
A recent utility bill was sent to your registered address, issued within the last three months, or an official document made by the government that proves your state of residence.
To make the approval process as speedy as possible, please ensure the document is sent with a clear resolution where all four corners of the paper are visible, and all text is readable.
For example, an electricity bill, water bill, bank statement, or any governmental post addressed to you.
If necessary, an employee may do additional checks based on the situation.
Source of funds
If a player deposits over five thousand euros, there is a process of understandings the source of wealth (SOW)
Examples of SOW are:
- Ownership of business
- Employment
- Inheritance
- Investment
- Family
The origin and legitimacy of that wealth must be clearly understood. If this is not possible, an employee may ask for an additional document or proof.
The account will be frozen if the same user deposits this amount in one go or multiple transactions that amount to this. An email will be sent to them manually to go through the above and the information on the website itself.
www.tiger.game also asks for a bank wire/credit card further to ensure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
The basic document for step one
The basic document will be accessible via the setting page onwww.tiger.game. Every user has to fill out the following information:
- First name
- Second name
- Nationality
- Gender
- Date of Birth
The document will be saved and created by an AI; an employee may do additional checks if necessary based on the situation.
Risk management
To deal with the different risks and states of wealth in other regions, www.tiger.game will categorize every nation into three risk regions.
Region one: Low risk
For every nation from region one, the three-step verification is done as described earlier.
Region two: Medium risk
For every nation from region two, the three-step verification will be done at lower deposit, withdrawal, and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand Dollars), withdrawing 1000$ (one thousand Dollars), or tipping another user/customer 500$ (five hundred Dollars.) Step three will be done after depositing 2500$ (two thousand five hundred Dollars), withdrawing 2500$ (two thousand five hundred Dollars), or tipping another user/customer 1000$ (one thousand Dollars). Also, users from a low-risk region that change the cryptocurrency to any other currency will be treated like users/customers from a medium-risk region.
Region three: High risk
Regions of high risk will be banned. High-risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.
Additional measurements
In addition, an AI that is overseen by the AML compliance officer will look for any unusual behavior and report it right away to an employee of www.tiger.game.
According to a risk-based few and general experience, the human employees will recheck all checks done by the AI or other employees. They may redo or do additional checks according to the situation.
In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behavior like Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account for Deposit and Withdraw, nationality changes, currency changes, behavior and activity changes, as well as checks, if an account is used by its original owner.
Also, a User must use the same method for Withdraw as he used for the Deposit, for the initial Deposit amount to prevent any Money Laundering.
Enterprise-wide risk assessment
As part of its risk-based approach, www.tiger.game has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to www.tiger.game and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines, such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions, and other qualitative and emerging risks.
The identification of AML risk categories is based on www.tiger.game understanding of regulatory requirements, regulatory expectations, and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.
The EWRA is reassessed yearly.
Ongoing transaction monitoring
AML-Compliance ensures that “ongoing transaction monitoring” is conducted to detect unusual or suspicious transactions compared to the customer profile.
This transaction monitoring is conducted on two levels:
1) The first Line of Control:
works solely with trusted Payment Service Providers, who all have effective AML policies to prevent the large majority of suspicious deposits onto www.tiger.game from taking place without proper execution of KYC procedures onto the potential customer.
2) The second Line of Control:
www.tiger.game makes its network aware so that any contact with the customer, player, or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular, these include:
- Requests for the execution of financial transactions on the account;
- Requests in relation to means of payment or services on the account;
Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of www.tiger.game at all times.
Also, all transactions must be overseen by employees over watched by the AML compliance officer, who the general manager overwatches.
The transactions submitted to the customer support manager, possibly through their Compliance Manager, must also be subject to due diligence.
Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment of the knowledge of the customer (KYC), their financial behavior, and the transaction counterparty.
An automated system will do these checks while an Employee cross-checks them for additional security.
The transactions observed on customer accounts for which it is difficult to understand the lawful activities and origin of funds must rapidly be considered atypical (as they are not directly justifiable).
Any www.tiger.game staff member must inform the AML division of any atypical transactions they observe and cannot attribute to a lawful activity or source of income known to the customer.
3) The third Line of Control:
As a last line of defense against AML, www.tiger.game will do manual checks on all suspicious and higher-risk users to entirely prevent money laundering.
If fraud or Money Laundering is found, the authorities will be informed.
Reporting of Suspicious transactions www.tiger.game
In its internal procedures, www.tiger.game describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analyzed within the AML team by the precise methodology described in the internal procedures.
Depending on the result of this examination and on the basis of the information gathered, the AML team:
- will decide whether it is necessary or not to send a report to the FIU by the legal obligations provided in the Law of 18 September 2017;
- will determine whether or not it is necessary to terminate the business relations with the customer.
Procedures
The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures available on the Intranet site ofwww.tiger.game.
Record keeping
Records of data obtained for identification must be kept for at least ten years after the business relationship has ended.
Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.
These data will be stored safely and encrypted offline and online.
Training
www.tiger.game employees will make manual controls on a risk-based approval for which they get special training.
The training and awareness program is reflected by its usage:
- A mandatory AML training program by the latest regulatory evolutions for all in touch with finances
- Academic AML learning sessions for all new employees This training program's content must be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML specialist working in “iTiger B.V.” AML team. Internal audit regularly establishes missions and reports about AML activities. All data given by any user/customer will be kept secure and will not be sold or provided to anyone else. Only if forced by law or to prevent money laundering may data be shared with the AML authority of the affected state. www.tiger.game will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC) If you have any questions about our AML and KYC Policy, please contact us: If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us:Auditing
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