This Anti-Money Laundering Policy (hereinafter the "Policy") is aimed to govern the activities of Wiraon B.V. (hereinafter the "Company") against money laundering, terrorist financing, or any other illegal or fraudulent activity. In this Policy you can read about what the Company does to comply with current anti-money laundering legislation and how these measures impact you as a user (hereinafter the "Website"). The Company has the right to change or revise this Policy. It is your responsibility to review this Policy from time to time to learn about any changes that enter into force. By continuing using the Website after the changes take effect constitutes your agreement with the revised Policy. 

  1. Implementation of this Policy.

    The Company applies this Anti-Money Laundering program in the following ways:

    • The Company may require verification of the customers (hereinafter the “Users” or “User”) of the Website;
    • The Company uses risk categories, established by the Financial Action Task Force (FATF), to evaluate whether a User presents a risk of money laundering, terrorist financing, or any other activity prohibited by the applicable legislation;
    • The Company constantly monitors all transactions made by its users via the Website;
    • The Company applies training for its employees to keep in touch with all modern approaches to combating money laundering.
  2. Risk Categories

    The Company uses risk categories approach, established by FATF to determine whether or not each of Users present a risk of being involved in a money laundering scheme.

    These risk categories are:

    2.1. Country/Geographic risk

    When a User registers an account on the Website, his or her place of residence/domicile (hereinafter the "Jurisdiction") must be considered as a matter of priority. At first, the Company checks whether the jurisdiction is on the European Commission's list of "high-risk third countries with strategic deficiencies" (see "sources"). Then, the Company checks whether or not the jurisdiction is presented in the list of "high-risk and other monitored jurisdictions", presented by FATF. Furthermore, the Company conducts its own monitoring of the jurisdictions based on the following parameters:

    • Legal environment;
    • Political environment;
    • A country's economic structure;
    • Cultural factors and the nature of civil society;
    • Sources, location and concentration of criminal activity (if any).

    2.2. User risk

    The Company checks each User's activity on the Website on the absence or presence of one or more factors that may provide grounds to place this User in the "high-risk" category. These factors are: a) enormous or high spenders (or extremely high spenders for this market); b) suspicious activity of the User (suspicious activity, use of several devices to authorize on the Company in a short time-frame, use of one IP address by several Users, use of the User's device by other Website Users); c) whether the user in question is a Politically Exposed Person (PEP) in the meaning of the European Union Directive 2015/849 and the Council.

    2.3. Transaction risk

    The Company makes every effort to eliminate any transaction risk(s) identified by FATF: a) The Company does not accept transactions from anonymous payment instruments; b) The Company does not allow funds to be transferred from one user's account to another user's account; c) The Company does not accept cash from users; d) The Company may accept only reputable electronic wallets from well-reputable jurisdictions; e) The Company does not allow to have additional accounts and does not accept deposits from payment instruments that are not owned by the User.

  3. Verification

    The Company may require a User Verification in the following circumstances:

    a) The total amount of transactions made by a User through the Company reaches or exceeds USD/EUR 10000;

    b) During the risk consideration process, it is determined that a User falls within one or more risk categories (see "risk categories");

    c) The User's activity contains one or more factors that give grounds to suspect a User in the usage of the Website in a manner that breaches the Rules of the Website (including Terms and Conditions, Privacy Policy and other related);

    d) In any other cases, when the Company considers it is a necessary measure to request a User Verification.

    While User Verification, the Company will request the following documents from the User:

    • A copy or a photo of the user's identification document;
    • A photo of the payment card used or intended to be used in making deposits on the Website. It is important that the name of the cardholder must match the name of the user who passes the verification. CVV code and payment card number (except first six and last four digits) may be hidden or covered. The cardholder's name must not be hidden or covered in any way;
    • A photo of the user holding the documents required for the verification process (may be with the requested information, written by hand (the e-mail of the user, used when registering an account; the date of the photo request and the confirmation code);
    • If applicable, include a bank statement, a letter from User’s duty station or place of employment, and a tax bill;
    • If applicable, User’s address confirmation. It may be a utility bill, a phone bill, or other documents that, in accordance with the jurisdiction's legal and regulatory requirements, are sufficient to confirm the User's address;
    • Any other documents or information that the situation may require;
    • The Company reserves the right to request a video interview with the User in order to confirm the information.

    3.1. Additional verification

    The Company may implement additional verification processes in the following circumstances:

    a) The user meets the definition of a Politically Exposed Person (PEP). A politically exposed person is defined as a natural person who is or has been entrusted with prominent public functions, which include the following: (a) heads of government, heads of state, ministers, and deputy or assistant ministers; (b) members of parliament or similar legislative bodies; (c) members of political party governing bodies; (d) members of supreme courts, constitutional courts, or other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances; (e) members of courts of auditors or central bank boards; (f) ambassadors, chargés d'affaires, and high-ranking officers in the armed forces; (g) members of State-owned enterprise administrative, management, or supervisory bodies; and (h) directors, deputy directors, and members of an international organization's board or equivalent function.

    b) If the User's country of residence is defined by the European Commission as a "third country with strategic deficiencies" or is on the FATF's list of "high-risk and other monitored jurisdictions";

    c) In other cases, when additional verification is required by law or at the request of authorities, financial institutions, etc.

    In addition to the standard verification, when applying additional verification, the Company requires to submit the document(s) or data on the source of the user's income in accordance with the jurisdiction's legal and regulatory requirements when using additional verification. In the event of additional verification, the final approval on the verification will be done by Senior management of the Company.

    For the purposes of this Policy, the Company reserves the right to collect additional user identification data. Furthermore, if a) a user refuses to pass verification; and/or b) the Company has reasonable grounds to suspect that a user is using the Company for illegal purposes and the user does not provide evidence to the contrary, the Company may inform appropriate government authorities on such case. Additionally, the Company may suspend the User's account until the user passes a verification processes or provides the document(s) or information requested by the Company.

  4. Record Keeping period

    For a period of 5 (five) years, the Company may keep a record of the verification data of the Website's Users, as well as the transaction data (the history of the transactions and their supporting evidence) in easily accessible form. Please refer to the Privacy Policy for more information on the storage of personal data of Website users.

  5. Activity Monitoring

    The company constantly monitors all of the users' transactions to ensure that they meet the following requirements:

    • In case of a banking transaction or transaction from the banking card, the account/card holder's name must be the same as it was when the account was registered (or, if the name was changed, the actual name displayed on the user's account).
    • If a deposit is made from a payment instrument to which funds cannot be withdrawn, the withdrawal may be made to the user's banking account or to another payment instrument if it is reasonably possible to ascertain that this payment instrument truly belongs to the user in question.

    The Company constantly monitors all user activity as well as their transactions to ensure that they are free of money laundering methods. These methods are:

    • Placement.

    At this point, the funds are converted into other financial instruments such as banking accounts, checks, money transfers, or used to purchase expensive items that can then be resold. The funds can then be invested in banks and other non-banking institutions (for example, money exchange institutions). To avoid any suspicions from the Company's side, a money-laundering entity may conduct several placements rather than placing the entire sum in one operation. This is known as "smurfing" or "structuring".

    • Layering.

    The funds are moved or transferred to other accounts or financial instruments. This procedure is designed to conceal the source of the funds and prevent the identification of the person who performs various financial operations. The movement of funds and changes in their form complicates the process of monitoring funds.

    • Integration.

    The funds are being returned to the financial system under the guise of lawfully obtained funds, with the ultimate goal of eventual integration into the financial system.

    5.1. Suspicious activity prevention

    All operations on funds depositing must be checked on so-called "fitting of cards" (the use of several cards through different payment agents recommended by the Company, obtaining a specific error code when making a payment, the use of cards issued by different emitters in different regions), the use of a different payment instrument in a short period of time (cards, banking transactions, electronic wallets), the User opposition or unwillingness to verify any of payment instrument, mismatch of the User key elements of geographic location (citizenship/residency, Internet provider, IP address geolocation, mobile carrier provider, BIN number of the card etc.), principal opposition to make any phone or video call, non-provision by user of his/her photo of him/her with the identification document in hands (upon request), matching of the user`s device ID (telephone, tablet, computer) with the device ID of another account in our system.

  6. Training of the staff on current AML procedures

    The staff of the financial department, that has the responsibility of the User withdrawal and depositing transactions, and the compliance department, that has the responsibility of document verification, are constantly monitoring the legislation and applicable practices of international organizations for any changes in the legislation; and keeping track of the business environment and practices of our partners and other organizations, engaged in combating money laundering. On regular basis the Company conducts training courses and revisions to internal procedures, considering potential changes in FATF recommendations and "Big Four" practices. Every three months, the Company conducts personnel attestation in order to check the knowledge and competencies required to effectively perform the functions relating to CTF/AML/KYC procedures and applicable practices, as well as to check the knowledge of current legislation in the field.

  7. References

    Here you can find the source list (but not limited to) for this Policy. Additional legislation or documents may be applied.

    • The Forty Recommendations and Special Recommendations on Terrorism Financing ("FATF Recommendations");
    • Risk-based approach guidance for the casinos (RBA for Casinos), issued by FATF;
    • Directive 2015/849 of the European Union and Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing;
    • Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies;
    • The Prevention and Suppression of Money Laundering Activities Amending Law 13(Ι) of 2018 of the Republic of Cyprus;
    • FATF list of High-risk and other monitored jurisdictions: