AML/CFT Policy
AML/CFT Policy
AML/CFT Policy
AML/CFT Policy

Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy

Legal Entity: INTERNATIONAL RADICAL INVESTMENT LTD

License: Anjouan Gaming License Authority (AGLA)

License No. ALSI-202509042-FI1

Effective Date: Immediately

1. Introduction

BogartCasino.ag, operated by INTERNATIONAL RADICAL INVESTMENT LTD (the “Company”), is fully committed to preventing its sportsbook and casino operations from being used for money laundering (ML), terrorist financing (TF), fraud, or other financial crimes.

This AML/CFT Policy is established in accordance with:

  • The KYC & AML Code of Conduct for Anjouan Internet Gaming Operators
  • Anjouan Gaming License Authority (AGLA) regulations
  • Financial Action Task Force (FATF) Recommendations
  • United Nations and other internationally recognized sanctions regimes
  • International best practices for remote gaming and financial crime prevention

The Company applies a risk-based approach (RBA) supported by customer due diligence, enhanced monitoring, internal controls, and timely reporting. This Policy applies to all employees, contractors, affiliates, and third-party service providers.

2. Regulatory Framework

BogartCasino.ag complies with:

  • AML/CFT laws of the Autonomous Island of Anjouan
  • Guidance issued by Anjouan Licensing Services Inc.
  • FATF global AML/CFT standards
  • UN and other recognized international sanctions frameworks
  • Online gaming industry integrity standards

This Policy is reviewed and updated regularly to reflect regulatory changes and evolving ML/TF risks.

3. Definitions

For the purposes of this Policy:

  • AML: Measures to prevent the processing of illicit funds
  • CFT: Measures to prevent funds from supporting terrorism
  • Beneficial Owner: Natural person(s) who ultimately own or control a customer
  • CDD: Customer Due Diligence
  • EDD: Enhanced Due Diligence for higher-risk customers
  • PEP: Politically Exposed Person, including close associates and family members
  • High-Risk Jurisdiction: Country identified by FATF or equivalent bodies
  • Source of Funds (SOF): Origin of funds used in transactions
  • Source of Wealth (SOW): Origin of a customer’s overall wealth
  • Suspicious Activity: Any activity suggesting ML, TF, or financial crime
  • Sanctions Lists: UN and other internationally recognized sanctions databases

4. Core AML/CFT Principles

Bogart Casino adheres to the following pillars:

  • Risk-Based Approach (RBA)
  • Customer identification and verification
  • Ongoing monitoring of activity
  • Timely regulatory reporting
  • Strong internal controls and governance
  • Mandatory staff training
  • Record retention and auditability
  • Zero tolerance for ML/TF activities

5. Risk Assessment

The Company conducts ongoing risk assessments covering:

  • Customer profiles
  • Geographic exposure
  • Payment methods
  • Betting behavior and product risk
  • Device, IP, and behavioral indicators
  • Exposure to sanctioned or high-risk jurisdictions

A comprehensive AML/CFT risk assessment is conducted annually and following any material operational change.

6. Customer Due Diligence (CDD)

6.1 Mandatory Verification Triggers

Customer identity verification is required:

  • Prior to first withdrawal (regardless of amount)
  • When cumulative deposits reach USD 10,000
  • When suspicious activity is detected
  • When required by risk reassessment

6.2 Required CDD Information

  • Full legal name
  • Date of birth
  • Residential address
  • Nationality
  • Government-issued photo ID
  • Proof of address (issued within 6 months)
  • Phone and email verification

6.3 Verification Procedures

  • Document authenticity and validity checks
  • Cross-referencing with independent data sources
  • Resolution of discrepancies via additional documentation
  • Suspension or closure if verification cannot be completed

7. Enhanced Due Diligence (EDD)

EDD applies to:

  • PEPs
  • Customers from high-risk jurisdictions
  • Large, complex, or unusual transactions
  • Activity inconsistent with known customer profile

EDD measures may include:

  • SOF and SOW verification
  • Additional identity documents
  • Senior management approval
  • Increased monitoring frequency

8. Source of Funds & Source of Wealth Controls

8.1 When SOF/SOW Is Required

SOF or SOW documentation is required when:

  • Deposit thresholds exceed USD 10,000
  • Transactions lack economic rationale
  • Customer risk level increases
  • Customer is a PEP
  • ML/TF indicators are present

8.2 Acceptable Documentation

SOF Examples: salary slips, bank statements, business income, crypto transaction history

SOW Examples: property sales, inheritance records, company ownership, investments

All documentation is reviewed, validated, and retained.

9. Risk Scoring & Customer Classification

Customers are classified as:

  • Low Risk – standard behavior, low exposure
  • Medium Risk – higher volumes or cross-border activity
  • High Risk – PEPs, high-risk jurisdictions, unusual patterns

Risk ratings are dynamic and reviewed periodically.

10. Ongoing Monitoring & Player Lifecycle Controls

Bogart Casino continuously monitors:

  • Rapid deposit-withdraw cycles
  • Structuring to avoid thresholds
  • Inconsistent betting behavior
  • Multiple accounts or linked identities
  • Use of anonymizing technologies

Unverified Accounts

  • Withdrawals restricted
  • Transaction limits applied
  • Suspension if verification is not completed

Multiple Account Detection

  • Device fingerprinting
  • IP analysis
  • Behavioral correlation

Confirmed abuse results in closure.

11. Sanctions Screening

  • Screening at onboarding, before first withdrawal, and continuously
  • Screening against UN and recognized international sanctions lists
  • Potential matches escalated immediately
  • Accounts frozen pending investigation
  • Confirmed matches reported and terminated

12. Fraud Prevention Measures

Fraud controls include:

  • Identity theft detection
  • Payment fraud monitoring
  • Bonus abuse detection
  • Velocity and device analytics

Fraud indicators are treated as AML risk triggers.

13. Suspicious Activity Reporting (SAR)

Reporting Workflow

  1. Automated alert generated
  2. Compliance review
  3. MLRO assessment
  4. SAR filed within 24 hours if suspicion remains
  5. Account restrictions applied
  6. No tipping-off

14. Internal Controls & MLRO

A qualified Money Laundering Reporting Officer (MLRO) is appointed and responsible for:

  • AML/CFT enforcement
  • SAR reporting
  • Regulatory liaison
  • Training oversight
  • Record maintenance

Internal controls ensure segregation of duties and compliance independence.

15. Employee Training

Mandatory AML/CFT training:

  • At onboarding
  • Annually
  • Upon regulatory changes
  • After incidents or breaches

16. Responsible Gaming Integration

AML controls integrate with responsible gaming:

  • Deposit limits
  • Self-exclusion
  • Behavioral harm indicators
  • Cross-alert escalation

17. Third-Party & Vendor Due Diligence

Third-party providers must:

  • Undergo AML risk assessment
  • Provide corporate and ownership documentation
  • Contractually agree to AML obligations
  • Be subject to periodic review

18. Cybersecurity & Data Protection

Security measures include:

  • Encrypted systems
  • Restricted access
  • Intrusion detection
  • Vulnerability testing

Security incidents are reported within 24 hours.

19. Record Keeping

All AML/CFT records are retained for:

  • Minimum 5 years after account closure
  • Longer if required by law or investigation

20. Independent Audits

Bogart Casino undergoes:

  • Annual independent AML/CFT audits
  • Regulatory inspections upon request

Findings are used for continuous improvement.

21. Continuous Improvement

The Company continuously updates:

  • Monitoring systems
  • Risk models
  • Sanctions databases
  • Training programs

22. Zero-Tolerance Policy

  • Confirmed ML/TF activity results in:
  • Immediate account closure
  • Regulatory reporting
  • Permanent platform exclusion