Last updated: 01.08.2023

Introduction

http://amerio.bet/, a registered trademark that is operated and administered by the company Millhouse B.V. registered in Curacao with company registration number 164290, having its registered address at Schottegatweg Oost 10 Unit 1-9, Bon Bini Business Center, Willemstad, Curaçao, licensed to conduct online gaming operations by the Government of Curaçao under the Curaçao eGaming, license No. 1668/JAZ. Millhouse B.V. for the provision of online games of chance.

The objective of the AML Policy: We seek to offer the highest security to all of our users and customers on http://amerio.bet/; for that, three-step account verification is done to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into the accord that depending on the nationality and origin, the way of payment, and withdrawal, different safety measures must be taken.

http://amerio.bet/ also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

http://amerio.bet/ is committed to high standards of anti-money laundering (AML) according to the EU guidelines and compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of http://amerio.bet/ is designed to be compliant with:

EU: “Directive 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.”
EU: “Regulation 2015/847 on information accompanying transfers of funds”
EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash

Definition of money laundering

Money Laundering is understood as:

The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, to conceal or disguise the illegal origin of the property, or helping any person who is involved in the commission of such an activity to evade the legal consequences of that people or companies action;
The concealment or disguise of the true nature, source, location, disposition, movement, and rights concerning, or ownership of, property, knowing that such property is derived from criminal activity or an act of participation in such activity;
The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such activity;
Participation in, association to commit, attempts to commit and to aid, to abet, facilitate, and counseling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for http://amerio.bet/

Following the AML legislation, http://amerio.bet/ has appointed the “highest level” for the prevention of ML: The entire management of Millhouse B.V. is in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general management.

AML policy changes and implementation requirements

Each significant change of http://amerio.bet/ AML policy is subject to approval by the general management of Millhouse B.V. and the Anti-money laundering compliance officer.

Three step Verification

Step one verification:

Every user and customer must do step one verification to withdraw. Regarding the choice of payment, the amount of payment, the amount of withdrawal, the option of withdrawal, and the nationality of the user/customer, step one verification must be done first. Step one verification is a document that the user/customer himself must fill out. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender, and full address.

Step two verification:

Step two verification must be done by every user who deposits over 2000$ (two thousand Dollars) or withdraws over 2000$ (two thousand dollars). Until step two verification is done, the withdrawal or deposit will be on hold. Step to validation will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification; depending on the country, the variety of accepted IDs may be different. There will also be an electronic check if the filled-in Data from the step one verification is correct. The electronic check will check via two various databanks to ensure the given information matches with the filled document and the name from the ID: If the electronic test fails or is not possible, the user/customer is required to send in confirmation of his current residence. A certificate of registration by the government or a similar document is required.

Step three verification:

Step three verification must be done by every user who deposits over 5000$ (five thousand Dollars) or withdraws over 5000$ (five thousand Dollar). Until step three verification is done, the withdrawal or deposit will be on hold. For step 3, a user/customer will be asked for a source of wealth.

Customer identification and verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card, or driving license, each shown alongside a handwritten note mentioning six randomly generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information besides the date of birth, nationality, gender, first name, second name, and picture. To secure their privacy.

Please note that all four corners of the ID have to be visible in the same image, and all details have to be readable besides the names above. We might ask for all details if necessary.

An employee may do additional checks if necessary, based on the situation.

Proof of Address

Proof of address will be done via different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manually proof.

A recent utility bill sent to your registered address, issued within the last three months, or an official document made by the government that proves your state of residence.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible and all text is readable.

For example, an electricity bill, water bill, bank statement, or any governmental post addressed to you.

An employee may do additional checks if necessary, based on the situation.

Source of funds

If a player deposits over five thousand euros, there is a process of understandings the source of wealth (SOW)

Examples of SOW are:

Ownership of business
Employment
Inheritance
Investment
Family

The origin and legitimacy of that wealth must be clearly understood. If this is not possible, an employee may ask for an additional document or proof.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and information on the website itself.

http://amerio.bet/ also asks for a bank wire/credit card to further ensure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

Basic document for step one

The primary document will be accessible via the setting page on http://amerio.bet/. Every user has to fill out the following information:

First name
Second name
Nationality
Gender
Date of Birth

The document will be saved and created by an AI; an employee may do additional checks if necessary based on the situation.

Risk management

To deal with the different risks and different states of wealth in other regions on the earth http://amerio.bet/ will categorize every nation into three distinct regions of risk.

Region one: Low risk

For every nation from region one, the three-step verification is done as described earlier.

Region two: Medium risk

For every nation from region two, the three-step verification will be done at lower deposit, withdrawal, and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand dollars) and withdrawing 1000$ (one thousand Dollars). Step three will be done after depositing 2500$ (two thousand five hundred dollars) and withdrawing 2500$ (two thousand five hundred dollars). Also, users from a low-risk region that change the cryptocurrency to any other currency will be treated like users/customers from a medium-risk region.

Region three: High risk

Regions of high risk will be banned. High-risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.

Additional measurements

In addition, an AI that the AML compliance officer oversees will look for any unusual behavior and report it right away to an employee of http://amerio.bet/.

According to a risk-based few and broad experience, the human employees will recheck all checks which are done bevor by the AI or other employees and may redo or do additional reviews according to the situation.

In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behavior like Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account for Deposit and Withdraw, nationality changes, currency changes, behavior and activity changes, as well as checks, if an account is used by its original owner.

Also, a user has to use the same method for Withdraw as he used for Deposit for the amount of the Initial Deposit to prevent any Money Laundering.

Enterprise-wide risk assessment

As part of its risk-based approach, http://amerio.bet/ has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to http://amerio.bet/ and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines, such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and commerce, and other qualitative and emerging risks.

The identification of AML risk categories is based on http://amerio.bet/ understanding of regulatory requirements, regulatory expectations, and industry guidance. Additional safety measures are taken to take care of the other risks the world wide web brings with it.

The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

1) The first Line of Control:

http://amerio.bet/ works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the large majority of suspicious deposits onto http://amerio.bet/ from taking place without proper execution of KYC procedures onto the potential customer.

2) The second Line of Control:

http://amerio.bet/ makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular, these include:

Requests for the execution of financial transactions on the account;
Requests concerning means of payment or services on the account.

Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of http://amerio.bet/ at all times.

Also, all transactions must be overseen by employees overwatched by the AML compliance officer, who the general manager overwatches.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager, must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment concerning the knowledge of the customer (KYC), their financial behavior, and the transaction counterparty.

These checks will be done by an automated system, while an Employee crosschecks them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must, therefore, rapidly be considered atypical (as they are not directly justifiable).

Any http://amerio.bet/ staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known to the customer.

3) The third Line of Control:

As the last line of defense against AML http://amerio.bet/ will do manual checks on all suspicious and higher-risk users to entirely prevent money laundering.

If fraud or Money Laundering is found, the authorities will be informed.

Reporting of Suspicious transactions on http://amerio.bet/

In its internal procedures, http://amerio.bet/ describes in precise terms the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analyzed within the AML team following the precise methodology fully described in the internal procedures.

Depending on the result of this examination and based on the information gathered, the AML team:

will decide whether it is necessary or not to send a report to the FIU, by the legal obligations provided in the Law of 18 September 2017;
will decide whether or not it is necessary to terminate the business relations with the customer.

Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Intranet site of http://amerio.bet/.

Record keeping

Records of data obtained for identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

These data will be safe and encrypted, stored offline and online.

Training

http://amerio.bet/ human employees will make manual controls on a risk-based approval for which they get special training.

The training and awareness program is reflected by its usage:

A mandatory AML training program following the latest regulatory evolutions for all in touch with finances
Academic AML learning sessions for all new employees

The content of this training program has to be established by the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML specialist working in the amerio.bet AML team.

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security

All data given by any user/customer will be kept secure and will not be sold or provided to anyone else. Only if forced by law or to prevent money laundering data may be shared with the AML authority of the affected state.

http://amerio.bet/ will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

Contact us

If you have any questions about our AML and KYC Policy, please get in touch with us by email: http://amerio.bet/

If you have any complaints about our AML and KYC Policy or the checks done on your Account and your Person, please get in touch with us by email: info@amerio.bet

FelixGaming / Spinachos