Anti-Money Laundering Policy

 

1. Introduction

 

1.1. This Anti-Money Laundering Policy is issued by 3-102-940387 SRL (the "Company", "We", "Us", "Our", "Website", “Yoho Slot”), a company registered and established under the laws of Costa Rica, with registration number 3-102-939097, and a registered address at Provincia de Puntarenas 06, Canton 11, Garabito, Jaco, 61101, Costa Rica.

 

1.2. We, as an Online Casino Operator, a potentially vulnerable industry to the threats of Money Laundering (the “ML”) and Terrorist Financing (the “TF”), understand and recognize the threat of the ML and TF to national and international security around the world.

 

1.3. The Company is fully committed to complying with all applicable Anti-Money Laundering (the “AML”) laws and regulations. We are committed to establish procedures to prevent and combat Money Laundering, Terrorist Financing, Fraud or any other criminal purpose through the misuse of Our Services.

 

1.4. This AML Policy is developed in alignment with international standards established by the Financial Action Task Force (the “FATF”) and applicable regulatory requirements and national legislation on Anti-Money Laundering. The AML Policy is designed to effectively prevent money laundering, terrorist financing, and other fraudulent activities by adhering to the highest legal and regulatory requirements.

 

1.5. The standards outlined in this AML Policy are based on the following legal frameworks, providing a robust and internationally recognized foundation for the procedures implemented to prevent the misuse of services offered by the Company:

 

• EU AML Directive: Directive (EU) 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 money laundering or terrorist financing;
• Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006 (Text with EEA relevance);
• Anjouan Money Laundering (Prevention) Act 008 of 2005;
• Various Regulations: Imposing sanctions or restrictive measures against persons, embargoes on certain goods and technology, including dual-use goods.

 

The Company’s AML program, including the procedures maintained for the prevention of the misuse of its services, is fully compliant with these regulations.

 

1.6. To comply with Anti-Money Laundering regulations, the Company has appointed a Compliance Officer to ensure compliance with this AML Policy, procedures and relevant AML legislation within the Company and the provision of the Services.

 

1.7. The Company has also put in place Know Your Customer (KYC) programs as an essential element for service, risk management and control procedures.
Such programs include:

• Customer Registration/Acceptance;
• Customer Identification/Verification;
• On-going Monitoring of Client’ activity;
• Risk Management;
• Reporting of suspicious activities to respective authorities.

 

1.8. All Company Clients will acknowledge, undertake and agree to the following terms regarding their use of the Website, entering into trading activities with Company as a Company Client:

• The Client will comply (throughout the time as a Company client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities;
• The Company will operate under certain obligations known as “know-your-customer” obligations which grant Company the right to implement anti-money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity;
• The Client agrees to lend full cooperation to the Company with respect to anti-money laundering efforts. This involves providing information that Company requests regarding Player Account, Website usage etc. to help Company perform its duties as dictated by applicable laws, regardless of jurisdiction;
• The Company reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices;
• The Company reserves the right to suspend or terminate any trading activity if there is reason to believe that services are used for activities that are deemed unlawful or fraudulent;
• The Company has the right to use Client information for the investigation and/or prevention of fraudulent or otherwise illegal activities;
• The Company has the right to share Client information with:
• Investigative agencies or any authorized officers who are helping Company to comply with applicable law, including anti-money laundering laws and know-your-customer obligations;
• Organizations that help Company provide the services it offers to its Clients;
• Government, law enforcement agencies and courts;
• Regulatory bodies and financial institutions.

 

2. Know Your Customer Procedure

 

2.1. The Company undertakes to monitor the Clients' activities in their Player Accounts to detect transactions that deviate from normal or expected Client behavior or to identify other suspicious activity.

 

2.2. To ensure safety and security in these areas, the Company has implemented the Client Activity Monitoring Measures:

• Preventing the creation of multiple accounts - The Company has created internal monitoring procedures and specialized software tools, which are continuously updated and improved, to detect and prevent the creation of multiple accounts by the same individual. Each time a Client initiates a withdrawal request, the system automatically conducts verification to identify any linked or duplicate accounts, in accordance with established detection protocols. If such accounts are identified, all related accounts may be closed at the Company’s discretion, and the Client may be permanently prohibited from registering new accounts.
• Monitoring of unusual transactions - if the Client makes unusual deposits that trigger system alerts, the Company will contact the Client to obtain an explanation for the unusual activity. If the Client fails to provide a satisfactory explanation or the required documentation, the Company will suspend the Player Account until the required information is provided. If the Client fails to provide the requested information within the individually determined period of time, the Player Account will be permanently closed. In addition, the Compliance Officer may report a suspicious transaction to the relevant authorities.
• Monitoring the Withdrawal of Funds - the Company allows withdrawing funds only to the original source - the Client's account from which the deposit was made. In individual cases, the Company may withdraw the Client's funds to another Client's account or to a third party account provided that the Client submits sufficient information and documentation at the Company's request to justify such withdrawal.
• Usage of third-party services - The Company partners with the third-party service provider to securely verify the identity of its Clients, ensuring compliance with regulatory requirements and safeguarding against fraud. SumSub offers a streamlined process for document verification, identity checks, and anti-money laundering (AML) compliance, allowing the Company to maintain a high level of trust and security while delivering a seamless user experience. This collaboration ensures that only legitimate players can access the platform, protecting both the Company and its Customers.

 

3. Risk Management

 

3.1. The Company has implemented a thorough verification and risk management strategy to ensure compliance with anti-money laundering and fraud prevention regulations. This policy integrates a comprehensive three-step verification process with continuous risk assessment procedures.

 

3.2. The Company applies continuous risk management measures throughout the entire period of its relations with Client. The Company checks the Сlient's identity against known databases of persons associated with criminal activity, prohibited persons, terrorism, politically exposed persons, etc. This risk assessment also includes an analysis of the Client's background, country of origin, source of funds and transaction patterns.

 

3.3. For Clients or transactions identified as high-risk - due to the size of the transaction, frequency of activity or unclear sources of funding - the Company applies enhanced due diligence. This may include more thorough checks or even a ban on deposits from high-risk regions. The decision to apply these measures is made at the Company's discretion.

 

3.4. The Company is obliged not only to establish the identity of its Clients, but also to monitor Player Account activity to determine those transactions that do not conform with the normal or expected transactions for that customer or type of account. Our Know Your Client (KYC) procedure constitutes a core feature of services’ risk management and control procedures. The intensity of KYC programs beyond these essential elements is tailored to the degree of risk.

 

3.5. When the Client's activity reaches certain financial thresholds - the enhanced verification shall be applied. The rule applies regardless of whether the deposit/withdrawal is made in a single transaction or in several transactions that seem to be related. At this step, the Client is required to provide a photo of their official identity document along with a document confirming the Client's residential address. The Company will verify the validity of the information provided via third party service SumSub. Funds related to the transaction will remain suspended until the verification is completed.

 

3.6. The Client must provide the requested documents and information within the time requested by the Company. Until all required information has been submitted, We reserve the right to suspend withdrawals and/or temporarily restrict access to your Player Account. Failure to provide the requested documents within the specified timeframe, or refusal to do so, may result in permanent Player Account closure.

 

3.7. For large volume transactions and for Clients, Clients are required to complete the third level of verification, which includes providing detailed documentation of the source of funds. This is a mandatory requirement under applicable EU anti-money laundering legislation. The Company reserves the right to suspend or block the transaction until such verification is completed to its satisfaction.

 

3.8. The Company reserves the right, at its sole discretion and at any time, to request verification of a Player’s identity and/or Source of Funds (SOF), in order to ensure compliance with its internal Know Your Customer (KYC) and Anti-Money Laundering (AML) policies, as well as applicable legal and regulatory obligations. Such verification may include, without limitation, submission of government-issued identification documents, proof of residence, bank statements, payslips, tax returns, or other documents deemed necessary by the Company to reasonably establish the lawful origin of funds used for gambling activities. Failure to provide sufficient documentation or to pass the verification procedure may result in suspension of the account, withholding of withdrawals, or permanent account closure, at the Company’s sole discretion.

 

3.9. By integrating these stages of verification with risk management procedures, the Company ensures that all Client activity is monitored and controlled in accordance with the highest standards of compliance, thereby minimizing the risk of illegal activity. Based on the outcome of such screenings, the Company reserves the right to reject, suspend, or terminate any Player Account or transaction at its sole discretion, particularly where a risk of financial crime or regulatory breach is identified. More details on the player verification process can be found in the KYC Policy.

 

4. Contact Us

 

4.1. Should You have any questions about this Anti-Money Laundering Policy, please contact Our Support Team: support@yohoslot.com . We are always happy to help.