> For the complete documentation index, see [llms.txt](https://whitepaper.bc.game/bc-white-paper/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://whitepaper.bc.game/bc-white-paper/appendix/aml-policy.md). # AML Policy BC.GAME is operated by Twocent Technology Limited, a limited liability company registered in Belize with company registration number 000041939, with registered address at Sea Urchin Street, San Pedro, Ambergris Caye, Belize. BC.GAME is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros and operates under License No. ALSI-202410011-FI1. BC.GAME has passed all regulatory compliance and is legally authorized to conduct gaming operations for any and all games of chance and wagering. We have established a comprehensive compliance framework that aligns with both domestic and international standards to detect and deter illicit activities on our platform. Our approach is based on a Risk-Based Assessment (RBA) utilized throughout the customer lifecycle. #### Regulatory Compliance Framework We adhere strictly to the 2016 Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations. Our operations prohibit any illicit activities, including money laundering, terrorist financing, or violations of trade sanctions, in line with various global AML regulations. Our compliance team actively monitors updates from the Financial Action Task Force (FATF) and the GCB to maintain high compliance standards. Our key practices include: * Developing and maintaining policies, procedures, and controls to combat money laundering, terrorist financing, and sanctions violations. * Establishing an internal AML/KYC team to oversee these protocols. * Providing ongoing training to our staff. * Conducting regular independent reviews to ensure compliance and address any identified deficiencies. #### Glossary of Term & Conditions * Money Laundering: Transforming illegal gains into seemingly legitimate funds, typically through placement, layering, and integration stages. * Placement: Introducing illegal proceeds into financial systems via deposits or other means. * Layering: Disguising the origins of criminal proceeds through complex financial transactions. * Integration: Reintroducing laundered money into the economy as legitimate to evade detection. * Suspicious Activity: Transactions that suggest fraud or illegal activities by users or non-users. * Sanctions: Measures imposed by international bodies to restrict activities of targeted entities or nations. Our Chief Compliance Officer oversees the implementation of our AML policies, driving initiatives, and ensuring adherence to evolving regulatory requirements. #### Clients Due Diligence(CDD) We apply rigorous due diligence and continuous monitoring using advanced software to comply with legal standards. #### Know Your Customer(KYC) Our KYC process, based on a Risk-Based Approach (RBA), helps us understand and assess the profiles of our players. This includes collecting essential information at registration and during account management. Our Customer Identification Program (CIP) includes: * Collecting key data such as wallet addresses and email at account creation. * Monitoring the risk associated with the cryptocurrency wallets used for funding. * Keeping records of identification data. * Screening against lists of known or suspected terrorists or their organizations. #### Identity and Age Verification To ensure the validity of the user information and compliance with KYC requirements, BC.GAME employs third-party services. These services verify users' identity and age to confirm they are eligible and not from restricted or sanctioned jurisdictions. They also check global sanctions lists to ensure users do not appear on them, based on the onboarding information such as wallet addresses. #### Customer Information BC.GAME collects detailed user information to establish a well-informed belief regarding the identity of its users, aligned with their risk profile. This information may include wallet address, name, address, country, date of birth, and postal code, collectively known as "KYC Information". Prior to issuing BC.GAME funding addresses for deposits, we ensure all necessary KYC Information is collected. We do not permit corporate entities or non-natural persons to register. Depending on the situation, BC.GAME may rely on third-party institutions to perform some or all aspects of our Customer Identification Program (CIP). #### Geo-blocking for Prohibited and Sanctioned Jurisdictions BC.GAME requires clients to certify that they will not offer services in countries where such activities are illegal through IP address-based geo-blocking. We also ensure that users are not subject to sanctions from Austria, France and it's territories, Germany, Netherlands and it's territories, Spain, Union of Comoros, United Kingdom, USA and it's territories, All FATF Blacklisted countries, and any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority. #### Enhanced Due Diligence(EDD) For users who display indicators of suspicious behavior or those involved in high-risk transactions, BC.GAME conducts enhanced due diligence. This may include verifying the user's full legal name, country of citizenship, permanent address, identification number (such as taxpayer identification, passport number, or alien identification card number), and documentation of their source of funds and wealth. #### Restrictions BC.GAME will block users who: * Fail to provide requested identification information. * Submit fraudulent identification documents. * Attempt to misrepresent their location. * Are from restricted or prohibited jurisdictions. * Are subject to global sanctions or watch lists. * Are identified as being addicted to gambling or having mental health issues. * Have funds originating from restricted jurisdictions. BC.GAME reserves the right to suspend or block players for any other reasons deemed necessary. #### Transctions Monitoring BC.GAME is committed to adhering to economic and trade sanctions and has established a transaction monitoring program. This includes both manual and automated processes to identify and address any unusual activities in real-time and through ongoing monitoring. Our systems review user history and activity patterns to detect and report unusual behavior and implement necessary controls. #### Ongoing Monitirong of Transctions In addition to the above, BC.GAME implements procedures for ban evasion detection, time zone monitoring, and product and service reviews to prevent misuse of our platform and ensure compliance with our terms of service. We periodically evaluate our third-party service providers to ensure they meet our compliance requirements. These comprehensive measures ensure BC.GAME maintains high standards of regulatory compliance and safeguards against illegal activities, reinforcing our commitment to operating with integrity and responsibility in the gaming industry. #### Vendor Management BC.GAME collaborates with reputable third-party service providers as part of our compliance infrastructure. We regularly assess the performance of these providers to ensure they meet our operational and compliance standards. If a service provider is not meeting expectations, or if additional services are required, we may take remedial action or seek alternative solutions to maintain our compliance with regulatory requirements. #### Compliance Innovation In our pursuit of continuous improvement, BC.GAME actively explores and tests non-documentary compliance mechanisms to evaluate their effectiveness for our platform. This includes experimenting with blockchain-native compliance tools such as fraud prevention services and on-chain KYC providers, which are designed to leverage the unique technological features of blockchain platforms. We may run pilot programs with compliance vendors to determine the viability of these tools in enhancing our regulatory framework. #### Internal Training BC.GAME ensures that our employees receive regular training on Anti-Money Laundering (AML), anti-terrorist financing, and compliance with trade sanctions. These training sessions are conducted periodically and are tailored to the specific needs of our staff, based on the latest regulatory developments and best practices in the industry. #### Suspicious Tranctions Reporting(STR) BC.GAME is committed to adhering to the National Ordinance concerning the reporting of unusual or suspicious transactions. If a customer is identified as being linked to money laundering, terrorism financing, or other criminal activities, such activity will be reported as suspicious to the relevant regulatory authorities. This is part of our broader effort to maintain a safe and legal gaming environment and to fulfill our regulatory obligations.