Anti-Money Laundering (AML) Policy
1. Policy Statement
Orange Entertainment B.V. (“the Company”) is fully committed to ensuring that its operations cannot be used for money laundering, the financing of terrorism, or the proliferation of weapons of mass destruction.
This Anti-Money Laundering Policy defines the principles, obligations, and internal procedures applied by the Company to identify, prevent, and report any such illicit activities.
The Policy is binding for all Company employees, contractors, and any associated entities engaged in providing gaming services under the Company’s license.
2. Purpose
This Policy aims to ensure compliance with the regulatory requirements established by the Curaçao Gaming Control Board, including:
the National Ordinance on Identification when Rendering Services,
the National Ordinance on the Reporting of Unusual Transactions, and
all relevant international standards, such as the FATF Recommendations.
Its goal is to establish a risk-based AML/CFT framework encompassing internal controls, risk assessments, customer due diligence, and reporting mechanisms, in order to effectively reduce exposure to financial crime.
3. Audience
This Policy applies to all individuals and entities associated with the Company, as detailed below:
Category | Covered Parties |
|---|---|
Employees | All Company employees, both permanent and temporary. |
Management | Members of the Board of Directors and senior management. |
Compliance Personnel | The appointed Compliance Officer and all staff responsible for AML/CFT functions. |
External Partners | Contractors, agents, or third parties acting on behalf of the Company who are involved in player onboarding, payment processing, or other AML-relevant activities. |
4. Definitions
Term | Definition |
|---|---|
Money Laundering (ML) | The act of concealing the illicit origin of funds by integrating them into the legitimate financial system. This process generally involves three stages: placement, layering, and integration. |
Terrorist Financing (TF) | The direct or indirect provision or collection of funds intended for use in supporting terrorist acts, organizations, or individuals, regardless of the legality of their source. |
Proliferation Financing (PF) | The provision of funds or financial services that enable the development, acquisition, or transfer of nuclear, chemical, or biological weapons and their delivery systems, in violation of international obligations. |
Customer Due Diligence (CDD) | The process of identifying and verifying customers, understanding the purpose and nature of the relationship, and monitoring transactions to ensure they align with the customer’s risk profile. |
Enhanced Due Diligence (EDD) | Additional verification and monitoring measures applied to high-risk situations, such as dealings with Politically Exposed Persons (PEPs) or customers from high-risk jurisdictions. |
Politically Exposed Person (PEP) | An individual who holds or has held a prominent public position, as well as their immediate family members or close associates, who may pose a heightened risk of corruption or bribery. |
Sanctions Screening | The process of checking customers and transactions against international and national sanctions lists (UN, EU, Curaçao) to ensure compliance with prohibitions. |
Beneficial Owner | A natural person who ultimately owns or controls a customer or on whose behalf a transaction is carried out, typically someone with 25% or more ownership or control in a legal entity. |
Unusual Transaction Report (UTR) | A report filed with the Curaçao Financial Intelligence Unit (FIU) when a transaction is identified as suspicious or unusual, based on objective or subjective criteria. |
Risk-Based Approach (RBA) | A strategic approach in which resources, controls, and procedures are applied proportionally to the level of risk posed by a customer, product, service, or transaction. |
5. Policy Implementation
5.1 Business Risk Assessment (BRA)
The Company carries out a documented Business Risk Assessment (BRA) to identify, evaluate, and mitigate the risks of money laundering, terrorist financing, and proliferation financing that may arise from its operations.
This assessment forms the foundation of the Company’s risk-based approach and serves as the basis for the design of all internal AML policies, procedures, and controls.
The BRA analyses the ways in which the Company’s products, services, and distribution channels could potentially be misused for illicit purposes and evaluates the likelihood and impact of such misuse.
Key Risk Factors Considered
Risk Type | Description |
|---|---|
Customer Risk | Evaluates types of customers and their potential involvement in money laundering or terrorist financing activities. |
Product and Service Risk | Identifies products that offer higher anonymity or liquidity, which may be more vulnerable to misuse. |
Delivery Channel Risk | Considers risks associated with non-face-to-face interactions and the use of third-party intermediaries. |
Geographical Risk | Examines the jurisdictions involved in customer relationships or transactions, particularly high-risk or sanctioned countries. |
National Risk Assessment (NRA) | Integrates findings and recommendations from national assessments into the BRA framework. |
The Company defines its risk appetite and develops mitigation strategies that include enhanced controls for high-risk areas.
Review and Update Requirements
The BRA is reviewed and updated at least once a year or whenever a significant change occurs in the Company’s business environment, including:
Trigger Event | Examples |
|---|---|
Product Changes | Introduction of new products or payment methods. |
Market Expansion | Entry into new jurisdictions or markets. |
Technology Implementation | Deployment of new technologies or business models. |
Regulatory Changes | Amendments to laws or regulatory requirements affecting AML obligations. |
Governance and Documentation
The Business Risk Assessment is a formal and documented process:
Governance Element | Details |
|---|---|
Approval Authority | Approved by the Board of Directors. |
Maintenance | Managed and maintained by the Compliance Department. |
Availability | Provided to the Curaçao Gaming Control Board upon request. |
Documentation Includes | Methodology used to assess risk, justification for classifications (low/medium/high), conclusions, and references to data sources. |
5.2 Customer Risk Assessment (CRA)
The Company conducts a Customer Risk Assessment (CRA) for every player during onboarding or before executing an occasional transaction.
The goal of this process is to identify potential risks of money laundering (ML), terrorist financing (TF), or proliferation financing (PF) associated with each customer and to assign a corresponding risk rating — low, medium, or high.
This rating determines the level of Customer Due Diligence (CDD) to be applied.
Key Risk Factors Considered
Risk Category | Description |
|---|---|
Customer Risk | Assessment of the player’s financial background, income sources, and behavioral indicators. Red flags include:– Multiple or irregular income sources;– Unverifiable or inconsistent financial data;– Excessive or disproportionate spending;– Use of third parties or agents for transactions;– PEP status;– Multiple accounts to disguise transaction patterns;– Large withdrawals unconnected to gameplay. |
Geographical Risk | Evaluation based on the customer’s country of residence, nationality, and origin of funds. High-risk countries include:– Jurisdictions with strategic AML/CFT deficiencies (as identified by FATF, CFATF, OFAC, etc.);– Countries subject to international sanctions;– Regions with high levels of corruption or terrorist activity;– Countries appearing negatively in the Corruption Perception Index or InCSR reports. |
Product, Service, and Transaction Risk | Assessment of the inherent risk in certain products or services, including:– Acceptance of high-risk payment methods (e.g., prepaid cards, crypto, e-wallets);– Peer-to-peer gaming features;– Deposits and withdrawals without real gambling activity;– Transfers between accounts or casinos using the same backend. |
Distribution Channel Risk | Evaluation of how the customer interacts with the platform. Higher risk is attributed to:– Non-face-to-face onboarding (if not mitigated by secure verification technologies);– Use of third-party intermediaries without AML oversight;– Anonymous or remote registration channels. |
Dynamic Risk Management
Each customer’s risk profile is continuously maintained and re-evaluated whenever significant changes occur, such as:
Change Type | Examples |
|---|---|
Behavioral | Unusual transaction patterns or irregular betting behavior. |
Status | Change in PEP or sanctions status. |
Financial | Updated or unexplained source of funds. |
5.3 Customer Acceptance Policy (CAP)
The Customer Acceptance Policy (CAP) defines the rules, thresholds, and procedures governing how the Company accepts and maintains business relationships with players.
It ensures that customers are only onboarded once the associated ML/TF/PF risk is clearly understood, properly assessed, and effectively mitigated through robust Customer Due Diligence (CDD) measures.
The CAP works in conjunction with the Customer Risk Assessment (CRA) and includes the following elements.
(a) Risk-Based Acceptance Criteria
The Company only establishes business relationships with customers whose risk profiles fall within the approved risk appetite.
Aspect | Description |
|---|---|
High-Risk Indicators | Customers posing higher-than-average ML/TF/PF risk, such as PEPs, individuals from high-risk jurisdictions, or disproportionate spenders. |
Risk Categorization | Customers are classified as low, medium, or high risk based on objective indicators and behavior. |
CDD Level | The degree of due diligence and monitoring frequency depends on the assigned risk category. |
Enhanced Due Diligence Triggers | Applied when risk exceeds acceptable thresholds (e.g., unexplained wealth, sanctioned countries). |
(b) Sanctions and PEP Screening
All customers are screened before onboarding and continuously thereafter against relevant sanctions and PEP databases.
Screening Source | Details |
|---|---|
UN and EU Consolidated Lists | Verified to prevent engagement with sanctioned individuals or entities. |
Local Curaçao Sanctions Lists | Checked for compliance with national AML/CFT obligations. |
PEP Databases & Transparency Sources | Such as Transparency International and other reputable providers. |
Condition | Requirement |
|---|---|
Senior Management Approval | The relationship must be approved at a senior level before proceeding. |
Independent Verification | Source of wealth and source of funds must be independently verified. |
Enhanced Monitoring | Ongoing review and scrutiny of account activity are applied. |
(c) Grounds for Declining or Terminating Relationships
The CAP defines the specific circumstances under which the Company must refuse or terminate a customer relationship.
Grounds | Description |
|---|---|
Incomplete CDD | The customer fails or refuses to complete CDD within required timelines. |
Fraudulent Documentation | The customer provides falsified or unverifiable documents. |
Sanction Links | The customer is confirmed or suspected to have ties with sanctioned entities or terrorist organizations. |
Suspicious Activity | Evidence or strong suspicion of criminal activity, money laundering, or third-party proxy use. |
(d) Documentation and Governance
The CAP is a formally approved and controlled policy.
Governance Aspect | Description |
|---|---|
Approval | Reviewed and approved by the Board of Directors. |
Oversight | Enforced under the supervision of the Compliance Officer. |
Documentation | All declined or terminated customer cases are recorded with clear justification and supporting evidence. |
Review Cycle | The CAP is reviewed annually or upon material business or regulatory changes. |
5.4 Customer Due Diligence (CDD)
The Company applies a comprehensive, risk-based Customer Due Diligence process designed to identify and verify every customer’s identity, understand the purpose and nature of the relationship, and monitor all transactions to detect and prevent ML, TF, or PF activities.
When CDD Measures Are Required
Trigger Event | Description |
|---|---|
Transaction Threshold | When a player performs financial transactions equal to or exceeding NAf. 4,000. |
Occasional Transactions | When an occasional or linked series of transactions exceeds NAf. 4,000. |
Suspicion of ML/TF | Whenever there is suspicion of money laundering or terrorist financing. |
Doubt in Existing Data | When previously obtained identification information is found to be inaccurate or insufficient. |
CDD Components
CDD Step | Description |
|---|---|
1. Customer Identification and Verification | The Company collects and verifies each customer’s full name, permanent residential address, date and place of birth, nationality, and identification number. Verification is conducted using valid, unexpired government-issued photo identification (e.g., passport, national ID). Residential address verification may be supported by secondary documentation such as utility bills or bank statements not older than six months. |
Additional Verification Tools | Biometric validation, video verification, cross-checks with geo-location/IP data, and device fingerprinting may be applied where appropriate. |
2. Customer Risk Assessment | Each customer is risk-rated during onboarding based on personal characteristics, geography, product use, and behavioral factors. This determines the appropriate CDD level and monitoring intensity. |
3. Purpose and Nature of Relationship | The Company collects enough information to understand the intended use of the account, expected funding patterns, and activity level. For low-risk cases, a source-of-wealth declaration may suffice; in higher-risk cases, documentary evidence and behavioural analysis are required. |
4. Sanctions and PEP Screening | All customers are screened at onboarding and on an ongoing basis against:– UN and EU Consolidated Sanctions Lists– Curaçao national lists– Reliable databases (e.g., KnowYourCountry, Transparency International). Customers identified as PEPs require senior management approval, verified source of wealth/funds, and enhanced monitoring. |
Freezing of Funds and Reporting Obligations
If a customer reaches the NAf. 4,000 threshold but fails to submit required CDD documents within 30 days:
Action | Consequence |
|---|---|
Account Status | The account is suspended immediately. |
Transaction Restriction | No further deposits or withdrawals are permitted. |
Fund Return | Funds are returned to the original source account unless ML/TF is suspected. |
FIU Reporting | In cases of suspicion, the matter is reported to the FIU Curaçao, and where necessary, escalated to the Public Prosecutor’s Office. |
If completing the CDD process would alert the customer of an Unusual Transaction Report (UTR), the process is suspended, and the report is filed directly with the FIU without further client interaction.
5.5 Enhanced Due Diligence (EDD)
Enhanced Due Diligence (EDD) measures are applied in all cases where the customer or transaction presents a higher-than-normal risk of money laundering, terrorist financing, or proliferation financing.
EDD is an essential part of the Company’s risk-based approach and ensures a deeper level of scrutiny.
When EDD Is Required
Scenario | Description |
|---|---|
Politically Exposed Persons (PEPs) | When the customer is a PEP, a close associate, or an immediate family member of a PEP. |
High-Risk Jurisdictions | When the customer resides in, or transactions are linked to, jurisdictions with elevated AML/CFT risk. |
Anonymous Payment Methods | When customers use products or payment options that obscure identity (e.g., prepaid cards, cryptocurrencies). |
New Technologies or Channels | When new or developing technologies, delivery channels, or business models are used. |
EDD Measures
Enhanced Control | Description |
|---|---|
Additional Customer Information | Collect detailed information such as occupation, previous address, adverse media reports, and open-source intelligence. |
Verification of Relationship Purpose | Obtain specific explanations and documents clarifying the nature and purpose of the business relationship. |
Proof of Source of Funds and Wealth | Require documented evidence of income or wealth (e.g., salary slips, inheritance, property sale, gambling winnings). |
Transaction Justification | Request a clear explanation for significant or irregular transactions deviating from expected patterns. |
Senior Management Approval | Require management authorization before initiating or continuing high-risk relationships. |
Enhanced Monitoring | Increase frequency and depth of monitoring of the customer’s account activity. |
Funding from Verified Account | Ensure the first deposit originates from an account in the customer’s own name at a financial institution applying equivalent CDD standards. |
All EDD measures are documented, and the Compliance Officer determines when EDD is necessary and ensures proper implementation and record-keeping.
Ongoing EDD Obligations
Requirement | Details |
|---|---|
Periodic Revalidation | For high-risk cases, the customer’s source of funds must be revalidated periodically even without changes in behavior. |
Continuous Monitoring | Enhanced oversight remains active for the entire duration of the relationship while elevated risk persists. |
Documentation | Every EDD decision and result must be logged in the customer file for audit and regulatory purposes. |
6. Ongoing Monitoring
The Company performs continuous monitoring of both customer identity and transactional activity throughout the business relationship.
This ensures that the relationship remains consistent with the customer’s risk profile and helps identify suspicious patterns that may indicate ML, TF, or PF risks.
Ongoing monitoring is risk-sensitive and consists of two core components.
(1) Monitoring of Customer Identity
The Company maintains accurate and up-to-date identification records for all active customers, acknowledging that personal information (such as address, payment method, or ID expiry date) may change over time.
Monitoring Measure | Description |
|---|---|
Periodic Review | Regular reviews of all customer identification data. |
Document Reverification | Recollection of updated identification where material changes occur. |
Expiry Tracking | Monitoring expiration dates of ID documents and prompting timely re-verification. |
Risk Reassessment | Reviewing the customer’s overall risk profile when significant changes in identity occur. |
These procedures ensure any deviations or discrepancies are promptly identified, verified, and evaluated for potential AML/CFT implications.
(2) Monitoring of Transactions
The Company continuously monitors transactions to identify behaviors inconsistent with the customer’s expected activity.
Monitoring Action | Description |
|---|---|
Pattern Analysis | Comparing transactions against the customer’s historical activity and peer benchmarks. |
Investigation | Reviewing the source of funds and purpose of transactions that deviate from the norm. |
Supporting Documentation | Requesting documentation for unusual or unexplained activity. |
Indicators of Concern | Large, disproportionate, or irregular transactions; use of unfamiliar payment instruments; sudden shifts in betting behavior. |
When anomalies are detected, the Company may revise the risk rating, apply EDD measures, or file an Unusual Transaction Report (UTR) with the FIU Curaçao.
Monitoring Frequency and Risk Sensitivity
The depth and frequency of monitoring depend on the customer’s assigned risk level:
Risk Level | Monitoring Frequency |
|---|---|
Low Risk | Periodic review to confirm continued compliance with baseline AML controls. |
Medium Risk | Regular checks of transactional patterns and updated documentation. |
High Risk | Continuous or near real-time monitoring with enhanced review of transactions and source of funds. |
7. Reliance on Third Parties
The Company may rely on approved third parties to perform specific elements of Customer Due Diligence (CDD) such as customer identification, verification, and purpose-of-relationship checks.
This reliance is carried out in compliance with Curaçao AML/CFT laws and subject to strict internal oversight and documentation.
Conditions for Third-Party Reliance
Condition | Requirement |
|---|---|
Immediate Access to Data | The Company must receive all CDD data and documentation immediately upon reliance. |
Written Agreements | Formal contracts guarantee access to full CDD documentation upon request. |
Testing of Reliability | Periodic checks are conducted to ensure quality and timely delivery of CDD data. |
Regulatory Oversight | The third party must be regulated or supervised under equivalent AML/CFT standards. |
Jurisdictional Assessment | The third party’s operating country must have a reliable AML regulatory framework verified by public risk indexes. |
The Company retains full responsibility for the effectiveness of CDD and does not delegate key obligations such as risk assessment, PEP/sanctions screening, or ongoing monitoring, which remain under the Company’s direct control.
8. Reporting of Unusual Transactions
The Company maintains a structured and risk-based system for detecting, documenting, and reporting unusual transactions in accordance with the National Ordinance on the Reporting of Unusual Transactions (NORUT) and FATF Recommendations.
This ensures timely identification and submission of reports to the Curaçao Financial Intelligence Unit (FIU).
Recognition of Unusual Transactions
An unusual transaction is any transaction or pattern inconsistent with a player’s known profile, purpose, or source of funds.
Indicators | Examples |
|---|---|
No Economic Purpose | Transactions with no clear lawful or economic rationale. |
Behavioral Deviation | Sudden changes in spending or gaming habits. |
Inconsistent Payment Sources | Use of methods or accounts unrelated to the customer’s declared profile. |
Types of Unusual Transactions
Transaction Type | Description |
|---|---|
Suspected ML/TF Activity | Transactions suspected to be linked to money laundering or terrorist financing. |
Sanctioned Persons or Entities | Transactions by or on behalf of entities listed under the Sanctions National Ordinance (N.G. 2014 no. 55). |
Large Transactions | Transactions of NAf. 5,000 or more, regardless of payment medium (cash, chips, e-wallets, etc.). |
Linked Transactions | Cumulative transactions reaching NAf. 5,000 in a single gaming day. |
Unjustified Transfers | Transactions with no clear legal justification or significantly above normal activity levels. |
Internal Documentation and Review
Process Step | Description |
|---|---|
Internal Reporting | All identified unusual transactions are reported internally to the Compliance Officer. |
Supporting Documentation | Identity documents, payment confirmations, and correspondence must accompany internal reports. |
Non-FIU Reports | Transactions not escalated to FIU are documented internally with clear justification and senior management approval. |
Record-Keeping | The Compliance Officer maintains a secure, auditable record of all reported and unreported transactions. |
External Reporting to FIU Curaçao
Requirement | Details |
|---|---|
FIU Registration | The Company is registered with the FIU Curaçao and uses the goAML online portal. |
Submission Language | Reports are submitted in English with all supporting documents. |
Timeliness | Reports must be submitted promptly upon identification of an unusual transaction. |
Legal Reference | Reporting complies with Article 11 of the NORUT and FIU Curaçao regulations. |
Prohibition of Disclosure (Tipping-Off)
The Company, its management, and all personnel are strictly prohibited from informing the customer or third parties about any transaction report or FIU communication.
Information about the existence, content, or status of a report cannot be disclosed, as it could compromise investigations or regulatory processes.
In high-risk scenarios, the Company may choose to maintain the relationship under enhanced monitoring while continuing to report all relevant transactions.
9. Anti-Money Laundering Compliance Program
The Company maintains a comprehensive Anti-Money Laundering (AML) Compliance Program to mitigate the risks of money laundering, terrorist financing, and proliferation financing.
The program establishes minimum internal standards and controls to ensure compliance across all business units, channels, and jurisdictions. It is periodically reviewed to address emerging threats, regulatory updates, and audit recommendations.
The AML Program is approved by senior management and applies to all group entities involved in customer onboarding, payments, or transaction processing.
Component | Description |
|---|---|
Internal Policies, Procedures, and Controls | The Company enforces written AML/CFT procedures covering due diligence, reporting of unusual transactions, record-keeping, sanctions compliance, and staff conduct. These are approved by senior management and reflect a zero-tolerance stance toward financial crime. |
Designated Compliance Officer | A senior, independent Compliance Officer oversees the AML Program, including its design, implementation, staff training, internal investigations, and reporting to the FIU via the goAML portal. The Officer has unrestricted access to CDD records and is supported by a compliance team. |
Employee Screening and Training | All relevant employees are screened for integrity and receive mandatory AML training tailored to their roles. New hires receive introductory training, while ongoing refresher courses are provided for critical functions such as cashiers, dealers, compliance, audit, and management. |
Independent Audit Function | An internal or external audit—independent from daily operations—is conducted annually. The audit reviews procedures, tests sample transactions, interviews staff, and evaluates the detection system’s effectiveness. Findings are reported to senior management with recommendations and corrective timelines. |
Ongoing Risk-Based Management
Focus Area | Application |
|---|---|
Integration with Risk Assessments | The AML Program aligns with both the Business Risk Assessment (BRA) and Customer Risk Assessment (CRA). |
Dynamic Risk Scoring | Risk scoring is applied at onboarding, throughout transactions, and during periodic reviews. |
Enhanced Controls for High-Risk Areas | Transactions, products, or jurisdictions identified as higher risk receive additional monitoring and due diligence. |
Adaptation to Emerging Threats | The program evolves in response to new payment technologies, remote onboarding practices, and typologies identified by regulators or FIUs. |
10. Compliance and Consequences of Non-Compliance
The Company enforces strict compliance with all Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) procedures as a fundamental part of its legal and operational responsibilities.
Adherence to this Policy is mandatory for all employees, officers, contractors, and any party acting on behalf of the Company.
Objectives of Compliance
Goal | Outcome |
|---|---|
Legal Adherence | Maintains full compliance with the laws and regulations of Curaçao. |
Regulatory Standing | Meets all licensing conditions imposed by the Curaçao Gaming Control Board (GCB). |
Corporate Reputation | Upholds the Company’s image as a transparent and responsible operator. |
Risk Mitigation | Reduces exposure to financial, regulatory, and criminal risks. |
Obligations of Staff and Management
Role | Responsibilities |
|---|---|
All Staff | Must understand and comply with AML/CFT policies, complete all required training, promptly report suspicious activity to the Compliance Officer, cooperate with audits and investigations, and maintain confidentiality of FIU reports. |
Management | Must establish a culture of compliance, allocate adequate resources to AML/CFT functions, and lead by example in implementing risk-based controls. |
Consequences of Non-Compliance
Failure to adhere to AML obligations—whether by negligence, omission, or deliberate misconduct—may result in severe disciplinary, regulatory, or legal consequences for both individuals and the Company.
Consequence Type | Details |
|---|---|
Internal Disciplinary Action | Employees violating AML policies may face disciplinary measures up to and including termination. Contractors or agents may have agreements suspended or terminated. |
Regulatory Sanctions | The GCB may impose administrative fines, license suspension or revocation, enhanced supervision conditions, or public reprimands. |
Civil and Criminal Liability | Individuals or the Company may face prosecution, civil penalties, or imprisonment for facilitating or failing to report ML/TF activities. |
Reputational Damage | AML failures may cause loss of customer trust, banking restrictions, and long-term harm to the Company’s commercial position and brand value. |
Monitoring and Enforcement
Enforcement Mechanism | Purpose |
|---|---|
Internal Monitoring and Audits | Continuous internal reviews to verify compliance effectiveness. |
Periodic Employee Reviews | Assessment of staff adherence to AML responsibilities. |
Root-Cause Analysis | Investigation of any deficiencies or breaches to prevent recurrence. |
Corrective Actions | Implementation of remediation measures and escalation to senior management where necessary. |
All employees are reminded that compliance with AML/CFT requirements is a condition of employment, and failure to comply constitutes a material breach of duty.
