Betway (“the Company,” “we,” “our,” or “us”) is committed to preventing the use of our services for money laundering and terrorist financing. This Anti-Money Laundering (“AML”) Policy outlines our protocols and procedures designed to comply with all applicable laws and regulations, detect suspicious activities, and report such activities to the relevant authorities. This policy applies to all users, employees, agents, and independent contractors of Betway.
1. Purpose and Scope
- Purpose:
The purpose of this AML Policy is to ensure that Betway:- Complies with all applicable AML and Countering the Financing of Terrorism (CFT) laws and regulations.
- Implements best practices to prevent, detect, and report money laundering, terrorist financing, or other criminal activities.
- Maintains a robust and dynamic AML framework that fosters a culture of compliance.
- Scope:
This policy applies to all aspects of our operations, including interactions with customers through our website sierraclubvotes.org, as well as our employees, partners, and independent contractors. Every stakeholder who participates in our Services must adhere to the standards and procedures set out in this policy.
2. Regulatory Framework
Betway’s AML Policy is informed by and designed to comply with relevant international and local regulatory requirements, including but not limited to:
- Financial Action Task Force (FATF) recommendations
- Applicable AML/CFT laws in New Zealand
- Any other related regulations or guidelines enforced by local or international authorities
3. Customer Identification and Verification (KYC)
To prevent money laundering and terrorist financing, we have adopted a “Know Your Customer” (KYC) program that includes:
- Customer Identification Program (CIP):
- We require all customers to provide valid identification documents before granting them access to our services (e.g., driver’s license, passport, national ID).
- We verify the identification data through reliable, independent sources, and may request additional documents or information if needed.
- Risk-Based Approach:
- Customers may be classified as low, medium, or high risk based on various factors (e.g., transaction history, source of funds, geography).
- Enhanced due diligence (EDD) measures are applied to customers considered high risk, which may involve additional identity verification or background checks.
- Ongoing Monitoring:
- We continuously monitor customer accounts and activities for unusual or suspicious behavior.
- Account activity that deviates from a customer’s historical patterns or declared source of funds is flagged for further review.
4. Record Keeping
Betway maintains comprehensive records of all customer identification and transactional data as required by applicable laws and regulations. These records include:
- Copies of identification documents
- Account application forms
- Transaction history and logs
- Correspondence and communications with the customer
All records are retained securely for a minimum period specified by law or as reasonably necessary for business or legal requirements.
5. Suspicious Activity Reporting (SAR)
- Identification of Suspicious Transactions:
Employees, agents, and independent contractors are trained to identify red flags or unusual activities that could signify money laundering or terrorist financing, such as:- Structuring of transactions to evade reporting thresholds
- Large or frequent cash deposits inconsistent with a customer’s profile
- Multiple accounts under the same name or controlled by the same individual
- Transactions involving high-risk jurisdictions identified by international bodies
- Internal Reporting:
Any suspicious activity must be reported immediately to Betway’s AML Compliance Officer (or designated compliance personnel) for further evaluation. - External Reporting:
If, after investigation, the AML Compliance Officer deems the activity suspicious, Betway will file a Suspicious Activity Report (SAR) with the relevant financial intelligence unit or other local regulatory authorities, in accordance with applicable laws.
6. Training and Awareness
Betway regularly trains its employees, agents, and independent contractors on AML/CFT regulations and best practices. Training covers:
- Relevant local and international AML regulations
- Methods and patterns of money laundering and terrorist financing
- Identification of suspicious transactions and customer activities
- Proper escalation and reporting procedures
- Record-keeping requirements
Periodic refresher training ensures that our team stays informed about evolving threats and regulatory changes.
7. AML Compliance Officer
Betway designates an AML Compliance Officer responsible for the oversight of this AML Policy. The Compliance Officer’s duties include:
- Developing and updating internal AML/CFT policies and procedures
- Ensuring compliance with relevant laws, regulations, and reporting obligations
- Serving as the main point of contact with law enforcement and regulatory authorities
- Overseeing employee training programs
- Conducting ongoing monitoring and audits of AML processes
8. Risk Assessment and Review
- Risk Assessment:
We conduct periodic risk assessments to evaluate the effectiveness of our AML framework. This includes identifying emerging risks, evaluating customer data, and assessing new products or services. - Policy Review and Updates:
We review this AML Policy on a regular basis to ensure alignment with current regulations and industry best practices. Any modifications are approved by senior management and communicated to relevant personnel.
9. Non-Compliance and Disciplinary Actions
Failure to comply with the AML Policy may result in disciplinary action, up to and including termination of employment or contract. In certain circumstances, non-compliance can also result in legal or regulatory penalties for both the individual and the Company.
10. Contact Information
If you have any questions or concerns about this AML Policy, or if you need to report suspicious activities, please contact our AML Compliance Officer or reach out to our support team:
- Email: [email protected]
- Address: 94 Bryce Street, Hamilton Central, Hamilton 3204, New Zealand
