ANTI-MONEY LAUNDERING (AML) POLICY – CHICKEN ROAD GAME (UK)

1. Introduction

Chicken Road Game (“we,” “us,” “the Company”) is committed to ensuring that our services are not exploited for money laundering, terrorist financing, or other criminal activities. This AML Policy outlines the controls and procedures implemented to detect, prevent, and report suspicious financial transactions, in accordance with UK legislation and the requirements of the UK Gambling Commission.

2. Legal and Regulatory Framework

  1. Money Laundering Regulations 2017: Core set of rules for AML compliance in the UK.
  2. Proceeds of Crime Act 2002 (POCA): Outlines criminal offenses regarding money laundering.
  3. Terrorism Act 2000: Addresses activities that could finance terrorism.
  4. UK Gambling Commission guidance: Additional sector-specific requirements.
  5. FATF Recommendations: International best practices.

This Policy is subject to periodic review and updates to ensure alignment with any changes in law or official guidance.

3. Core AML Principles

  1. Know Your Customer (KYC)

    • We verify each player’s identity to prevent the creation of anonymous or fictitious accounts.
    • Depending on the risk level, we may request further documentation (e.g., passport/ID, proof of address, evidence of source of funds).

  2. Risk-Based Approach

    • We categorize customers and transactions by risk (e.g., standard vs. higher risk).
    • High-risk profiles (e.g., Politically Exposed Persons or transactions from jurisdictions with a high risk of money laundering) are subject to Enhanced Due Diligence (EDD).

  3. Transaction Monitoring

    • We maintain systems to monitor player deposits, withdrawals, and in-game transactions for unusual activity.
    • If suspicious indicators are detected, we may hold or suspend the transaction pending further checks.

  4. Suspicious Activity Reporting

    • If we suspect money laundering or terrorist financing, we file a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
    • We must refrain from tipping off the customer (i.e., we cannot inform them about the SAR).

  5. Staff Training

    • Employees receive AML training periodically, covering how to spot red flags, how to escalate concerns internally, and the relevant legal requirements.

4. Customer Identification (KYC)

4.1 Account Registration

  • Players must provide personal information (name, date of birth, address) upon signup.
  • If required, we also collect supporting documents (e.g., ID copy, address proof) to fulfill legal verification and ensure compliance with age restrictions.

4.2 Ongoing Customer Due Diligence

  • We perform periodic reviews and update customers’ risk assessments if certain thresholds or unusual patterns appear.
  • Accounts may be temporarily suspended if a player fails to provide requested KYC documents.

5. Enhanced Due Diligence (EDD)

  • High-Risk Indicators: Large or complex transactions, origin from high-risk countries, Politically Exposed Persons (PEPs).
  • Additional Checks: We may require further documentation (e.g., proof of source of wealth) or impose higher-level approval.

6. Transaction Monitoring

  • Automated Alerts: Our systems detect potential anomalies such as multiple small deposits, frequent high-value transactions, or abrupt changes in deposit patterns.
  • Manual Review: The AML Compliance team reviews flagged transactions to determine if further action (e.g., SAR filing) is needed.

7. Reporting Suspicious Activity

  1. Internal Escalation
    • Employees must promptly report any unusual player behavior or transaction to the AML Compliance Officer.
  2. Filing SAR
    • If the Compliance Officer deems a suspicion valid, we submit a Suspicious Activity Report (SAR) to the NCA without informing the player (tipping-off prohibition).

8. Record Keeping

  • Retention: We store relevant AML records (KYC documents, transaction logs, SAR copies) for at least five years from the end of a customer relationship or transaction, or any longer period required by law.
  • Access Control: Only authorised staff members have access to these records, which we may disclose to regulators or law enforcement if legally mandated.

9. Politically Exposed Persons (PEPs) and High-Risk Jurisdictions

  • For PEPs and individuals affiliated with high-risk regions, we apply Enhanced Due Diligence measures (EDD).
  • We may opt to discontinue or refuse a player’s activities if we are not satisfied with the documentation provided or deem the risk too high.

10. Staff Training and AML Compliance Officer

  • Training: All relevant employees undergo AML training at least annually or whenever regulations change.
  • Compliance Officer: A designated AML Officer oversees policy implementation, monitors compliance with the AML framework, and serves as the main contact for regulatory agencies.

11. Non-Compliance and Disciplinary Action

  • Employees who disregard or violate AML procedures may face disciplinary measures (including termination).
  • Customers found to be engaging in money laundering or related fraud face account closure, confiscation of funds, and a potential SAR being filed.

12. Ongoing Review of the AML Policy

  • Chicken Road Game regularly reviews this Policy (at least once a year) to ensure it remains current with updated laws, regulations, and the evolving risk environment.
  • Updates will be disseminated to all staff and, where relevant, published on our website.

13. Contact Information

  • Chicken Road Game – AML Compliance Department
  • [Mailing Address, United Kingdom]
  • [Phone Number]
  • [Email Address]

If you have questions about our AML measures or wish to report suspicious activity, please contact us at the above details.