Introduction
Mmk121 is a remote gaming operator committed to preventing money laundering and the financing of terrorism. This policy establishes our approach to AML and CFT compliance in line with Curaçao law and international standards, including oversight by the competent supervisory authority.
Scope and Applicability
This policy applies to all customers, business relationships, employees and contractors of Mmk121 involved in services related to online gaming and related payment activities. It governs onboarding, ongoing due diligence, monitoring, reporting and governance of AML/CFT controls.
Regulatory Framework
- National Ordinance on the Prevention and Combating of Money Laundering and Terrorist Financing NOIS
- National Ordinance on the Reporting of Unusual Transactions NORUT
- Guidelines issued by the Financial Intelligence Unit FIU Curaçao
- FATF principles and international standards applicable to financial crime prevention
Risk Based Approach and Risk Assessment
- Mmk121 employs a risk based approach to AML/CFT. Risk assessments are conducted on onboarding and reviewed at regular intervals
- AML risk is categorized as customer, product, interface and geographical risk
- Enhanced due diligence is applied where risk indicators indicate elevated ML/FT risk
Customer Due Diligence and Ongoing Monitoring
During onboarding, the identity of the customer is verified prior to establishing a business relationship. We collect and verify data including name, date of birth, nationality and residential address, and government issued identification. We determine the purpose and intended nature of the business relationship and establish a risk profile. Ongoing monitoring includes review of transactions and customer data, with updates triggered by material changes.
Enhanced Due Diligence
EDD is applied to high risk customers such as politically exposed persons or customers from high risk jurisdictions, customers using complex ownership structures, or where funds appear inconsistent with stated sources. EDD requires additional documentation regarding source of funds and wealth and approval by senior compliance personnel.
Identification Data and Documentation Requirements
- Minimum data: full name, date of birth, nationality, residential address, identification number
- Documents: passport or national ID, and proof of address (utility bill or official correspondence)
- Additional documents as needed: secondary IDs, photographs for identity confirmation, and evidence of source of funds such as payslips, bank statements, trust deeds or equivalent documents
Sanctions, PEP Screening and Third-Party Reliance
All customers undergo sanctions and PEP screening at onboarding and on an ongoing basis. We engage only FATF-compliant third party service providers for identity or documentation verification, under contractual controls and audit trails.
Record Keeping and Data Retention
All relevant KYC, transaction and risk information are securely stored for at least five years and are available to authorities upon lawful request. Records are maintained with appropriate access controls and data protection measures.
Reporting and Internal Controls
Suspicious activity, including unusual transactions, is reported to the FIU Curaçao promptly and confidentially in accordance with NORUT. We maintain internal reporting channels and procedures for escalation, investigation and remediation of suspicious activity.
Training, Governance and Oversight
Staff receive ongoing AML/CFT training. The Director has ultimate responsibility for the AML policy, with a designated compliance function overseeing policy implementation, risk assessment, control design and periodic review. Governance includes defined roles, responsibilities and escalation pathways for risk management.
Confidentiality and No Tipping Off
All information relating to AML monitoring, investigations and reporting is treated as confidential. Internal communications with the FIU and regulators are safeguarded, and customers are not informed of investigations or internal decisions unless required by law.
Policy Review and Updates
The AML/CFT policy and related procedures are reviewed regularly to reflect regulatory changes and emerging risk. Changes are approved by the Board or its designated authority and implemented through updated procedures.
Policy Availability
A condensed version of this policy is available for user awareness. The full policy is accessible upon legitimate request by regulators, partners or institutional stakeholders.