AML Policy
AML Policy
I. Introduction
Novatrix SRL (“Company”) is an entity that organises special games of chance through electronic communication. Being licensed by the Tobique Gaming Commission, the Company is committed to full compliance with legal and regulatory requirements to detect and prevent money laundering and other crimes through its services. The Company reports directly to the Tobique Gaming Commission regarding any activity that may be connected to money laundering or predicate offences. This policy provides an overview of the AML procedures and controls the Company adheres to.
II. Company Risk Profile
Based on our business model, the risk of money laundering and terrorist financing is minimal compared to financial institutions.
- Cash is not accepted; only credit cards, e-wallets, and other licensed instruments may be used for deposits and withdrawals.
- The average transaction value is relatively small.
- Since only RNG games are offered, Company services cannot realistically be used as a laundering tool.
- The only potentially vulnerable stage is the layering stage, which is mitigated through daily screening measures.
III. Customer Onboarding
1. Mandatory Registration Details
To register, a customer must provide:
- First name
- Last name
- Address
- City and postal code
- Country
- Email address
- Date of birth
- Password and confirmation
- Account currency
- Mobile phone number
2. Restrictions on Unregistered Customers
Unregistered players cannot and are not allowed to play for real money. No online transaction (deposit or withdrawal) is accepted or processed in cash.
3. Email Verification
Upon completing registration, customers receive a welcome email with a link granting access to their accounts. This verifies the customer’s email.
4. Restricted Countries
Registration is prohibited for residents of:
- The Bahamas
- Botswana
- Cambodia
- Ethiopia
- Pakistan
- Panama
- Sri Lanka
- Syria
- Trinidad and Tobago
- Tunisia
- Yemen
- Saudi Arabia
- USA
- North Korea
- Iran
- Hong Kong
- China
- Other restricted or sanctioned countries per FATF/UN guidance
5. Age Restriction
Customers under 18 are denied account creation.
IV. Customer Due Diligence (CDD)
1. Required Documents
- POI: Proof of Identity
- POA: Proof of Address
- POPA: Proof of Payment Account
- SOWD: Source of Wealth Declaration
2. CDD Trigger Events
CDD is applied when:
- A transaction (single or linked) reaches USD 10,000 or more
- Customer performs small deposits followed by unusually large deposits
- Customer attempts to create multiple accounts
- Customer returns after 6+ months inactivity and their IP/transaction pattern changes
3. Additional Measures (per staff decision)
- Selfie
- Selfie with POI
- Selfie with handwritten note
- Video verification
- Liveness or biometric checks
4. Document Acceptance Criteria
- POI: All data must match the Player Details tab; document must be valid and readable.
- POA: Must match the Player Details tab and be issued within the past 90 days.
- POPA: All data must match the Payment Systems Debts tab.
- Scanned copies are not accepted.
V. Enhanced Due Diligence (EDD) & Monitoring
1. Purpose
Enhanced Due Diligence is applied when additional verification is required to confirm legitimacy of customer funds.
2. Required EDD Documents
- Source of Wealth
- Source of Funds
3. EDD Triggers
- Customer classified as high-risk and SOW/SOF not yet obtained
- Customer is a PEP or related to a PEP
4. Acceptable SOW Types
Examples include:
- Salary
- Company profits
- Sale of shares/investments
- Property sale
- Company sale
- Inheritance
- Loans
- Gifts
- Fixed deposits
- Gambling winnings
- Pension
- Mining revenue
VI. Payout Management
- Account ownership check: Payout must go to same person and same source of funds.
- Wagering check: Deposits must be used for stakes.
- Activity check: Frequent changes to linked bank accounts trigger suspension pending explanation.
- Collusion check: Suspicious p2p-style transfers trigger payouts freeze until the provider confirms no collusion.
VII. Politically Exposed Persons (PEPs) & Sanctioned Individuals
A PEP is a person entrusted with public office. Family and close associates also qualify.
Screening Procedure
Company conducts OSINT-based manual screening via:
If customer might be a PEP
- Request POI, POA, and selfie
- AML unit reviews the account
- If confirmed as PEP:
- Apply EDD
- Senior management approval required
- Enhanced monitoring if relationship continues
Screening must occur within 30 days from start of CDD.
Sanction List Screening
Checked through:
- EU Consolidated List
- UN Security Council list
- OFAC list
If customer is a potential sanctioned individual:
- Account and funds are frozen
- Internal report sent to MLRO
- MLRO files report if confirmed
Active customers are reviewed monthly.
VIII. MLRO (Money Laundering Reporting Officer)
MLRO duties include:
- Staying updated with AML/CTF legislation
- Ensuring implementation of procedures
- Providing staff training
- Maintaining risk assessments
- Reviewing internal reports
- Filing STRs to Tobique Gaming Commission
Suspicious incidents must be reported within 5 business days.
IX. Record Keeping
The following are maintained for 5 years:
- Identification records (ID copies, bank statements, references)
- Transaction records (method, performer, destination, authorization, volume)
X. Staff Training
Periodic training ensures staff understand AML obligations.
XI. Employee Hiring
New employees undergo background checks and interviews. All new staff receive AML training.
