It is the policy of Orion Gate Gaming Ltd. to prohibit and actively prevent money laundering and any activity that facilitates the funding of terrorism or other criminal acts.
Money laundering generally involves disguising the origin of illegally gained funds so they appear legitimate. Terrorist financing, while sometimes using lawful funds, pursues ideological objectives and often relies on similar laundering techniques to move money discreetly.
The Company remains vigilant in preventing money laundering and terrorist financing to protect its reputation and meet legal obligations. All internal policies, procedures and controls are reviewed regularly to ensure full compliance with applicable legislation and regulatory guidance.
Reasonable steps are taken to verify the identity of each player before an account is opened. Anonymous or fictitious accounts are strictly prohibited.
Documentary evidence (e.g. passport, proof of address) is requested when risk thresholds are met or any payment exceeds 2 000 EUR. All players are screened against global sanctions and politically exposed-person lists.
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Accounts will not be opened, or may be closed, if a player refuses to supply requested identification or appears to provide misleading information. Such cases are reviewed by the AML Compliance Officer.
Transactions are automatically monitored. Daily reports flag any activity above 2 000 EUR or unusual patterns.
The Compliance Officer investigates red-flag indicators such as:
Any transaction, attempted or completed, totalling 2 000 EUR or more that appears suspicious will be reviewed and, if necessary, reported to the relevant authority. Indicators include use of sanctioned accounts, funds of illicit origin, or activity without lawful purpose.
All employees receive annual AML training covering detection of red flags, escalation procedures, record-keeping obligations and disciplinary consequences for non-compliance. Training content is updated as laws or risks evolve.