1.1 OVERVIEW
Money laundering, terrorism financing and proliferation financing (ML/TF/PF) are serious international matters and it is important that bet365 takes appropriate steps to ensure that such criminal activities are identified and prevented.
Money laundering relates to transactions and activities funded by the proceeds of crime. This includes attempting to disguise the origin, movement or ownership of such funds.
Terrorist financing can be defined as the provision or collection of funds, by any means, directly or indirectly, for the purpose of being used to support terrorist acts or organizations.
Proliferation financing relates to the act of providing funds or financial services for use in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer, stockpiling of, or otherwise in connection with the possession or use of chemical, biological, radiological or nuclear weapons, including the provision of funds with the means to deliver such weapons and other related goods and technology.
bet365 has both a legal and social responsibility to detect and prevent money laundering activity, proliferation and terrorism financing through the provision of regulated services.
All functions performed by any of bet365’s permanent foreign establishments are conducted in compliance with the applicable anti-money laundering, counter-terrorism and counter proliferation financing (AML/CTF/CPF) legal obligations for Brazil, regardless of where these procedures are carried out.
This document outlines bet365’s AML/CTF/CPF programme according with the regulatory requirements set out by Ordinance SPA/MF No. 1,143/2024, Council for Financial Activities Control (COAF) Resolution No. 31/2019, No. 36/2021 and No. 40/2021, Ordinance SPA/MF No. 1,330/2023 and Law No. 14,790/2023.
This document should be considered in conjunction with the Terms and Conditions.
1.2 RISK ASSESSMENT
bet365 applies a risk-based approach to its ML/TF/PF risk assessment process when identifying, mitigating and managing the risk of abusing the services offered by the Company in order to launder money or finance terrorism or proliferation.
As such, based on a comprehensive understanding of its users, business and employees, bet365 undertakes a regular internal ML/TF/PF risk assessment and implements effective mitigation measures proportionate to the assessed risk, taking into consideration the complexity of the business and customer base.
This is achieved by identifying the specific risks posed, determining how these risks can be mitigated by internal controls and subsequently establishing the residual risks that remain.
1.3 CUSTOMER DUE DILIGENCE
bet365 implements robust customer due diligence measures, which include verifying the identity of their customers, assessing ML/TF/PF risks and conducting ongoing monitoring of activity and transactions.
bet365 may choose to apply enhanced due diligence measures at their discretion.
1.3.1 IDENTIFICATION
All accounts are subject to bet365’s standard verification process in order to confirm the user’s identity. The process involves validating and verifying a number of personal details.
If users do not successfully complete these checks or provides incorrect/misleading information, restrictions are applied to the account.
1.3.2 SCREENING
In accordance with regulations, bet365 has processes in place to identify users that could fall into one of the following categories:
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Politically Exposed Persons (PEP), including the relatives and close associates (RCAs) of PEPs
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Sanctioned individuals
The screening process employed by bet365 seeks to successfully identify users so that the appropriate action may be taken in relation to the management of the business relationship.
1.3.3 ONGOING DUE DILIGENCE MEASURES
All users who hold a bet365 account are subject to standard ongoing due diligence and monitoring processes throughout the lifetime of the business relationship.
bet365 takes proactive measures to ensure that the information it holds on file is up-to-date, and so we may request users to provide us with updated information from time to time.
1.4 REPORTING
bet365 has an obligation to report suspicions relating to money laundering and terrorist financing activity, as defined within Article 27 of Ordinance SPA/MF No 1,143/2023 to COAF as soon as practicable.
bet365’s authorised person is responsible for the submission of these reports and for ensuring that the related processes for the identification and investigation into suspicious activity are being carried out.
1.5 EMPLOYEES
As part of the AML/CTF/CPF policy, bet365 assesses the potential risk posed by employees to the business and implements appropriate mitigation measures including ongoing employee training and employee due diligence checks.
1.6 RECORD KEEPING
bet365 deems proper record keeping processes as key to support in the detection, prevention and ultimate reporting of ML/TF/PF activity.
The internal systems used by bet365 create extensive, auditable transaction logs of all activity occurring on user accounts.
bet365 retains all user transactional information and identification documents for a period of at least five years after the last activity of the user on the platform, as required by Law No. 9,613/1998 and Ordinance SPA/MF No. 1,143/2023. These records are retained securely in electronic form.