AML & KYC Compliance at Lodi291
Introduction
At Lodi291, we are committed to ensuring the highest level of security for all users by implementing a robust Anti-Money Laundering (AML) policy. Operated by Platinum Technology N.V., based in Willemstad, Curacao, we take necessary measures to protect our customers from fraudulent activity. Our AML policy complies with international standards, including EU directives and regulations, to prevent money laundering and promote secure financial transactions on our platform.
Objective of the AML Policy:
Lodi291 aims to provide a safe and secure environment for all users by conducting a thorough, three-step account verification process. This process ensures that each user’s identity is verified, preventing the use of stolen or unauthorized deposit methods. Our goal is to verify that the details provided during registration are correct, safeguarding our platform against money laundering (ML) activities.
We also tailor safety measures based on the nationality, origin, and payment methods of our users. This approach allows us to address the unique risks associated with various payment systems, ensuring comprehensive AML compliance.
To effectively limit ML risks, Lodi291 takes proactive steps, dedicating necessary resources and controls to monitor and mitigate such risks. We ensure that our AML practices are in line with the most stringent international regulations, keeping our platform secure for all users.
Compliance with International Standards:
Lodi291’s AML program aligns with key international guidelines and regulations, including:
- EU Directive 2015/849: Prevention of the use of the financial system for money laundering
- EU Regulation 2015/847: Information accompanying transfers of funds
- EU Sanctions and Restrictive Measures: Measures against persons and embargoes on certain goods and technologies
- Belgium’s Law of 18 September 2017: Prevention of money laundering and the limitation of cash use
By following these directives, Lodi291 ensures compliance with the best practices for AML and reinforces its commitment to maintaining a secure and trustworthy platform for all users.
Definition of Money Laundering
Money laundering refers to a series of illegal activities aimed at concealing the origin of assets derived from criminal acts. It typically involves the following actions:
Conversion or Transfer of Property: This occurs when property, especially money, is transferred or converted, knowing it originates from criminal activities. The purpose is to hide the illegal source of the property or assist individuals involved in the crime to evade legal consequences.
Concealment or Disguise: It involves hiding or disguising the true nature, source, location, or ownership of property, all while knowing that the property was acquired through criminal activity.
Acquisition, Possession, or Use of Property: This refers to acquiring, possessing, or using property, knowing that it was derived from criminal activity or aiding such activity at the time of receipt.
Participation and Facilitation: Engaging in or supporting criminal activities related to money laundering, including aiding, abetting, facilitating, or attempting to commit any of the actions mentioned above.
Money laundering is considered illegal even when the criminal activities that generate the illicit property take place outside the jurisdiction of the involved Member State or in a third country.
Organization of the AML for Lodi291
In line with AML legislation, Lodi291 has established a strong organizational structure to effectively prevent money laundering. The highest level of management at Platinum Technology N.V. oversees all anti-money laundering (AML) efforts to ensure compliance and security.
To enforce the AML policy and procedures, we have appointed an Anti-Money Laundering Compliance Officer (AMLCO). The AMLCO is directly responsible for implementing the policy and ensuring its adherence across all systems and processes. This position reports directly to Lodi291’s senior management, ensuring that all AML measures are consistently enforced.
AML Policy Changes and Implementation Requirements
Lodi291 regularly reviews and updates its Anti-Money Laundering (AML) policy to ensure ongoing compliance. Any significant changes to the AML policy require approval from the general management of Platinum Technology N.V. and the appointed Anti-Money Laundering Compliance Officer (AMLCO).
Three-Step Verification Process:
Lodi291 implements a comprehensive three-step verification process to safeguard all transactions and ensure AML compliance. The process is designed to validate the identity of users and customers, with increasing levels of scrutiny based on the amount of deposit, withdrawal, or transfer.
Step One Verification:
Step one is mandatory for all users before making a withdrawal. It must be completed regardless of the payment method, withdrawal amount, or the user’s nationality. The user must fill out a verification form, providing the following details:
- First name
- Last name
- Date of birth
- Country of residence
- Gender
- Full address
Step Two Verification:
For users who deposit or withdraw amounts exceeding $2,000, we require step two. Until this step is completed, we will hold any deposit, withdrawal, or tip. During step two, we direct the user to a subpage where they must upload a picture of their official ID. To complete the verification, the ID must include a six-digit, randomly generated number displayed alongside it. Depending on the user’s country, accepted ID types may vary.
An electronic check will verify the accuracy of the information provided in step one. The system will cross-reference the details with two different data banks to ensure the information matches the ID. If the electronic verification fails or is unavailable, the user must provide a government-issued confirmation of their current residence, such as a certificate of registration.
Step Three Verification:
Step three verification is required for users who deposit or withdraw amounts over $5,000 or transfer more than $3,000 to another user. Until this verification is completed, the user’s transactions will be held. During step three, users must provide proof of the source of their wealth to further verify their financial activity.
Customer Identification and Verification (KYC)
Customer identification is a crucial step when entering into any commercial relationship. It is a key requirement for both money laundering regulations and our Know Your Customer (KYC) policy. At Lodi291, we adhere to strict identification standards to ensure compliance and safeguard our platform against illicit activities.
Fundamental Principles of Identification:
To verify a customer’s identity, the following documents and steps are required:
- A copy of an official document, such as a passport, ID card, or driver’s license. This must be accompanied by a handwritten note that includes six randomly generated numbers.
- A second photo showing the customer’s face clearly.
- The customer may blur out all personal information on the ID, except for the following:
- Date of birth
- Nationality
- Gender
- First name
- Last name
- Photo
The photo of the ID must show all four corners clearly, and all information must be legible, except for the blurred details mentioned above. We may request additional details if necessary to ensure the authenticity of the identification.
In certain situations, our employees may conduct further checks if required, depending on the circumstances.
Source of Funds
If a player deposits over €5,000, Lodi291 requires a clear understanding of the source of their wealth (SOW). This helps ensure compliance with anti-money laundering regulations and verifies the legitimacy of the funds.
Examples of Accepted Sources of Wealth (SOW):
- Ownership of a business
- Employment income
- Inheritance
- Investments
- Family support
It is essential to verify the origin and legitimacy of these funds. If the source cannot be clearly identified, our team may request additional documents or proof.
If a user deposits €5,000 in a single transaction or across multiple smaller transactions that total this amount, their account will be temporarily frozen. They will receive a manual email requesting further clarification. Additional details will also be available on the website.
To further confirm the user’s identity, Lodi291 may request a bank wire or credit card statement. This step helps verify the financial situation and ensures the legitimacy of the funds being deposited.
Basic Document for Step One
- First name
- Last name
- Nationality
- Gender
- Date of birth
Risk Management
Region One: Low Risk
For nations classified as low risk, we apply the standard three-step verification process as described earlier.Region Two: Medium Risk
For medium-risk nations, we trigger verification steps at lower deposit, withdrawal, and tipping thresholds.- Step One: Completed as usual for all users.
- Step Two: Required after depositing, withdrawing, or tipping amounts of $1,000.
- Step Three: Triggered after transactions of $2,500 for deposits, withdrawals, or $1,000 for tips.
Region Three: High Risk
We ban nations classified as high risk from accessing services. We regularly update the list of high-risk regions to reflect the evolving global landscape.Additional Measures
At , additional measures are in place to identify and address unusual activities, ensuring compliance and security at all times. These include leveraging AI and human oversight to maintain strict monitoring and prevent money laundering.
AI Monitoring and Reporting
An AI system, supervised by the AML Compliance Officer, actively scans for unusual behavior. If suspicious activities are detected, they are immediately reported to an employee for further investigation.
Human Oversight and Risk-Based Review
Human employees conduct risk-based reviews and recheck the AI’s findings. Depending on the situation, they may perform additional checks to ensure accuracy and compliance.
Data Analysis and Behavioral Monitoring
A data scientist, supported by modern analytical systems, monitors patterns such as:
- Depositing and withdrawing funds without extended betting sessions.
- Using different bank accounts for deposits and withdrawals.
- Changes in nationality, currency, behavior, or activity.
- Verifying that accounts are accessed only by their original owners.
Withdrawal and Deposit Rules
To prevent money laundering, users must use the same method for withdrawals as they did for deposits, at least for the amount of the initial deposit.
Enterprise-Wide Risk Assessment (EWRA)
As part of its risk-based strategy, Lodi291 conducts an annual Enterprise-Wide Risk Assessment (EWRA) to identify and manage risks specific to its business operations.
Risk Identification and Documentation
The EWRA identifies and documents risks inherent to Lodi291, such as:
- Services offered on the platform.
- Transactions performed by users.
- Delivery channels utilized.
- Geographic locations of operations, customers, and transactions.
- Emerging risks and qualitative factors.
Risk Policy Determination
The AML risk policy is shaped by a comprehensive understanding of these risk categories, regulatory requirements, industry guidelines, and evolving regulatory expectations. Special safety measures address risks unique to operating on the global web.
Annual Reassessment
To stay aligned with changing regulatory and business environments, Lodi291 reassesses its EWRA annually. This reassessment ensures that risk mitigation strategies remain effective and up to date.
Ongoing Transaction Monitoring
At Lodi291, ensuring compliance with anti-money laundering (AML) policies involves ongoing transaction monitoring. This process detects and addresses transactions that appear unusual or suspicious compared to the customer’s profile. Monitoring occurs at three levels:
1. First Line of Control
Lodi291 exclusively collaborates with trusted Payment Service Providers. These providers enforce robust AML policies, minimizing the likelihood of suspicious deposits without proper Know Your Customer (KYC) procedures.
2. Second Line of Control
The second level of monitoring involves a heightened state of diligence throughout Lodi291’s network. All customer interactions are carefully examined, particularly:
- Requests for executing financial transactions on accounts.
- Inquiries about payment methods or services linked to accounts.
Every transaction is overseen by employees under the supervision of the AML compliance officer, who in turn reports to the general management. Compliance teams and managers further scrutinize flagged transactions, ensuring due diligence.
Key aspects include:
- Assessing unusual transactions based on the customer’s KYC profile, financial behavior, and transaction counterparties.
- Automated systems flagging transactions for initial review, followed by manual cross-checks for added security.
- Classifying transactions that lack a clear lawful activity or fund origin as atypical, requiring immediate attention.
All Lodi291 staff must promptly report atypical transactions to the AML division for further investigation.
3. Third Line of Control
As the final defense, Lodi291 conducts manual reviews on high-risk and suspicious users. This step allows us to identify and report any fraudulent or money-laundering activities to the appropriate authorities.
By employing these three lines of control, Lodi291 maintains a secure and compliant transaction monitoring system, reinforcing its commitment to preventing money laundering.
Reporting of Suspicious Transactions at Lodi291 (AML)
Lodi291 has detailed internal procedures guiding staff on identifying and reporting suspicious transactions. These procedures ensure compliance and a streamlined process for addressing atypical transactions.
Internal Reporting Process
- Clear Guidelines for Staff: The procedures explicitly outline when and how to report suspicious activities to the AML team.
- Analysis by the AML Team: Upon receiving a report, the AML team conducts a thorough analysis using a defined methodology outlined in the internal guidelines.
Actions Taken by the AML Team
Based on the results of their examination and the information collected, the AML team determines the appropriate course of action:
Filing a Report to the Financial Intelligence Unit (FIU)
If deemed necessary and in accordance with the Law of 18 September 2017, the team will submit a formal report to the FIU.Terminating Business Relations
If the transaction raises significant concerns, the team may decide to terminate the business relationship with the customer to mitigate risks.
These measures demonstrate Lodi291’s commitment to identifying, reporting, and addressing suspicious activities in strict compliance with AML regulations.
Procedures
Operational Guidance
“We convert the Anti-Money Laundering (AML) rules, including the minimum Know Your Customer (KYC) standards, into detailed operational procedures. These guidelines are easily accessible to all authorized personnel through the Lodi291 intranet. This ensures consistent adherence to compliance practices across all operations.
Record Keeping
Lodi291 maintains stringent record-keeping protocols to align with regulatory requirements:
Identification Data
- We securely store records of customer identification data for at least ten years after the termination of the business relationship.
Transaction Data
- We preserve all transaction records for at least ten years following the execution of the transaction or the conclusion of the business relationship.
Data Security
To ensure the safety and integrity of customer information:
- We store data in encrypted formats, safeguarding it against unauthorized access.
- We implement dual storage with both offline and online solutions, providing redundancy and enhanced security.
Training
We equip our employees with the necessary skills and knowledge to detect and prevent money laundering through a structured training program tailored to our operations.
Manual Controls and Risk-Based Approval
Employees responsible for manual controls undergo specialized training to perform risk-based approvals effectively.
Training and Awareness Program
Mandatory AML Training
- All employees who interact with financial operations are required to complete mandatory AML training programs.
- These programs are updated regularly to reflect the latest regulatory changes and industry standards.
Academic AML Learning Sessions
- New hires undergo introductory AML learning sessions designed to familiarize them with the company’s anti-money laundering policies and procedures.
Content and Delivery
- We customize the training content based on the employee’s role and responsibilities, ensuring relevance and practical application.
- An AML specialist from Platinum Technology N.V.’s AML team conducts the training sessions.
Data Security
At Lodi291, safeguarding customer data is a top priority. The following measures ensure that all user/customer data remains secure and protected:
Data Protection Standards
Confidentiality
- We treat customer data with the utmost confidentiality. We will never sell or share it with third parties.
- We only disclose data under legal obligations or to prevent money laundering by reporting to the appropriate AML authority in the relevant jurisdiction.
- Compliance with Regulations
- Lodi291 strictly adheres to the guidelines and rules of the Data Protection Directive (Directive 95/46/EC), ensuring full compliance with data security laws and regulations.
Data Handling and Storage
Secure Storage
- We store all data in encrypted formats, both online and offline, to protect against unauthorized access or breaches.
Access Controls
- Only authorized personnel, under strict security protocols, have access to sensitive user/customer data.
Retention Policy
- We retain data only for the duration required by law or business necessity, as outlined in our company’s Record Keeping Policy.