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AML / CFT Policy

Anti-money laundering and counter-financing-of-terrorism controls. Source-of-funds, thresholds, monitoring, suspicious-activity reporting, and retention.

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1. Commitment

Ultimate Poker Holdings N.V. is committed to preventing money laundering and the financing of terrorism. This policy describes the controls we apply to identify, monitor, and report suspicious activity. We comply with the Curaçao National Ordinance on Identification when Providing Services (LID), the National Ordinance on the Reporting of Unusual Transactions (NORUT), Financial Action Task Force (“FATF”) recommendations, and applicable international sanctions regimes.

2. Money Laundering Reporting Officer (MLRO)

We appoint a qualified MLRO who is responsible for the overall AML / CFT programme, the filing of suspicious activity reports, training, and liaison with the financial intelligence unit (“MOT Curaçao”). The MLRO has direct reporting access to the board and the authority to freeze accounts and reject transactions.

3. Customer due diligence (CDD)

We apply a risk-based approach. All players go through standard CDD at onboarding; enhanced CDD applies to higher-risk customers.

3.1 Standard CDD

  • Identity verification through our KYC provider (see KYC Policy).
  • Address verification.
  • Sanctions, PEP, and adverse-media screening.
  • Geolocation and IP screening against the Restricted Countries list.

3.2 Enhanced CDD

Triggered by any of the following:

  • Customer identified as a politically exposed person (“PEP”) or family member / close associate.
  • Customer from a higher-risk jurisdiction per FATF lists.
  • Cumulative deposits or withdrawals exceeding USD 10,000 over a 30-day period.
  • A single transaction exceeding USD 5,000.
  • Pattern of activity inconsistent with the customer’s declared profile.

For Enhanced CDD we require additional documentation including, as relevant: source of funds (payslips, bank statements, sale of asset contracts, tax filings), source of wealth (where the underlying wealth originates), and an updated risk assessment.

4. Ongoing monitoring

Every transaction is screened in real time against:

  • Sanctions lists (UN, OFAC, EU, UK).
  • Internal block-lists.
  • Velocity / pattern rules (rapid deposit-withdraw cycles, structuring below thresholds, dormant-then-active accounts).
  • Game-play patterns indicating chip dumping, collusion, or transfer of value.

Alerts feed into a case-management system reviewed by AML analysts. The MLRO reviews escalated cases.

5. Reporting suspicious / unusual transactions

Where a transaction or pattern raises objective grounds for suspicion of money laundering or terrorist financing, the MLRO files a report with MOT Curaçao within the timeframe required by NORUT. We do not tip off the customer. We will continue to comply with valid orders to freeze, restrict, or release funds.

6. Cryptocurrency-specific controls

For crypto deposits and withdrawals we:

  • Use a regulated payment processor with its own AML programme.
  • Screen wallet addresses against sanction-list address feeds.
  • Block addresses linked to mixers, darknet marketplaces, sanctioned services, ransomware payouts, or known illicit clusters.
  • Apply the FATF Travel Rule where the threshold and provider support permit.

7. Record-keeping

We retain CDD records, transaction records, and AML case files for at least seven (7) years from the end of the customer relationship or the date of the relevant transaction, whichever is later. See the Data Retention Schedule.

8. Training

Staff in customer-facing, payments, and compliance roles complete AML / CFT training at induction and annually thereafter. Training covers recognition of red flags, escalation paths, sanctions awareness, and reporting obligations.

9. Independent review

The programme is reviewed annually by an independent reviewer with no operational involvement in the controls under review. Findings are reported to the board.

10. Player obligations

By using the Service you confirm that funds you deposit are your own and lawfully obtained. You agree to provide source-of-funds and source-of-wealth evidence when reasonably requested. Withholding or providing false information is a material breach of the Terms of Service and may itself be an offence under applicable law.

11. Contact

AML questions: legal@theultimatepokergame.com. The address is monitored by our compliance team and the MLRO.