Anti‑Money Laundering (AML) Policy of WinWin Bet Kenya

This document outlines the AML policy in effect at WinWin Bet, operated by ALASIA SOFT B.V., situated at Abraham Mendez Chumaceiro Boulevard 03, Willemstad, Curaçao (Company No. 163748), adapted for Kenyan users.

1. Introduction

At WinWin Bet Kenya, maintaining the integrity of our platform is paramount. We use rigorous identity verification processes to confirm that all users are genuine and to block unauthorized use of third-party funds. Our system checks identity based on region and payment type to ensure legitimacy and compliance with AML regulations. All users must complete verification before engaging in betting or financial transactions.

To manage money laundering risk effectively, WinWin Bet Kenya adheres to broad international AML standards, including EU directives, delivering a reliable and transparent service to Kenyan bettors.

2. Regulatory Adherence

Our AML efforts at WinWin Bet Kenya align with the following regulations:

• EU AML Directive 2015/849, preventing illegal financial flows
• EU Regulation 2015/847, governing fund transfers
• Belgian AML frameworks
• Curaçao laws combating terrorism financing and WMD proliferation
  

These regulations guide our operations, even as a global operator serving Kenyan users.

3. Defining Money Laundering

Money laundering covers any activity aiming to disguise illegal wealth. Common forms include:

• Complex transfers or conversions of illicit assets
• Concealing true ownership or source of funds
• Using criminally derived assets knowingly
• Facilitating or promoting illicit financial activity
  

Even criminal acts occurring abroad fall under the scope of money laundering and are subject to action at WinWin Bet Kenya.

4. AML Oversight

The executive leadership at ALASIA SOFT B.V. holds ultimate responsibility for AML compliance at WinWin Bet Kenya. A dedicated AML Compliance Officer (AMLCO) monitors program implementation, reports to senior management, and ensures ongoing alignment with regulations.

5. Identity Verification

We employ a tiered KYC process:

Level 1 (Initial): Required before any withdrawals. Users must submit:

• Full name, birth date, residence, and country
• Gender and address
  This is completed via our secure online application.

Level 2 (Enhanced): Triggered by:

• High-value deposits or withdrawals above KES 200,000
• Suspicion of money laundering or terrorism financing
• Suspicion of fake or incomplete data
  User must supply government ID and a selfie including a randomly generated code, plus address confirmation via utility bills or government letters.
  

6. Know Your Customer (KYC)

To guarantee valid customer identities, users submit:

• A valid photo ID displaying birth date and nationality
• A selfie with ID, to verify likeness
• Proof of address—either an official letter or utility invoice, issued within the past 3 months
  

These measures ensure lawful participation and compliance with AML.

7. Source of Funds Disclosure

If users deposit over €5,000 (or equivalent), they must declare and provide proof of their income source—such as employment, business ownership, investments, inheritance, or gifts. Failure to provide this proof leads to account suspension until resolved.

8. Account Onboarding

Registration collects key personal info—name, date of birth, gender, nationality—which is screened automatically. Manual review follows any questionable entries. Every user must be verified accurately before engaging in betting.

9. Sanctions and PEP Screening

WinWin Bet Kenya screens all new users for ties to:

• Global sanctions lists
• Politically Exposed Persons (PEPs)
• Criminal networks
  

Profile checks use names, birth dates, and visual data to identify any flagged associations.

10. Risk-Based Jurisdictional Filtering

Nations are categorized into three tiers:

• Low Risk: Standard checks apply
• Medium Risk: Prudent systems limit exposure
• High Risk: Access is declined, based on periodic updates
  

This ensures compliance with shifting international risk profiles.

11. Monitoring and Alerts

Our AML procedures rely on AI-driven systems to spot unusual transactions such as:

• Repeated high-value activity without betting
• Withdrawals from unused banking or payment accounts
• Swift changes in deposit or betting volumes
• Users only using one payment method for deposits and withdrawals
  

Flagged behaviors are investigated by the compliance team.

12. Enterprise‑Wide Risk Analysis

An annual risk review evaluates:

• Customer profiles and activity patterns
• Services and platform payment options
• Transaction types and delivery systems
• Geographic trends among our user base
  

Based on findings, we update policies, controls, and procedures to reduce emerging threats.

13. Ongoing Transaction Oversight

We use a three-layer security framework:

1. First line: Only approved payment partners with strong AML protocols
2. Second line: Staff monitor unusual customer activity and report suspect behavior
3. Third line: Periodic audits of flagged accounts; confirmed breaches are notified to regulators
   

This ensures thorough oversight at every level.

14. Reporting of Suspicious Activity

Transactions meeting any of the following criteria are reported via the Curaçao goAML portal within 48 hours:

• Activity involving sanctioned individuals
• Deposits or withdrawals exceeding KES 250,000
• Actions indicating potential links to crime
  

Rapid reporting helps regulatory authorities respond effectively.

15. Record Retention

We retain records for a minimum of five years, including:

• Identification documents
• Transaction history
• Support and internal communications
• Compliance reports
  

All data is encrypted and stored securely, both on-site and offline.

16. Staff Training and Audits

WinWin Bet Kenya requires regular training of employees, including:

• Initial AML education
• Role-based sessions by AML specialists
• Ongoing internal audits to check for policy adherence
  

These practices ensure a vigilant, well-prepared team at all times.

17. Data Privacy

All personal data is protected under the EU Data Protection Directive (95/46/EC) and Kenyan regulations. WinWin does not share personal data unless required by law or to prevent illegal activity. User privacy is safeguarded alongside AML compliance.

18. Contact for AML Queries

For AML-related concerns, inquiries, or to submit information, please reach out to:

• AML-related concerns: [email protected]
• General support: [email protected]
  

Our teams are equipped to handle AML questions and compliance interactions quickly and effectively.