Milliora
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KYC Policies

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1.1 Policy Objectives and Scope

  • In line with its ongoing efforts to increase its operational effectiveness, Milliora is committed to taking the necessary measures to ensure that all of its employees – whether full-time or contracted – actively participate in the process of preventing the company's services and/or channels from being used for the purpose of money laundering and/or the financing of terrorism.

  • The use of legal or illegal funds for the purpose of financing terrorism, along with money laundering (ML), have become increasingly growing threats. Milliora (hereinafter referred to as the "Company") is dedicated to contributing to global efforts to combat organized crime and terrorism.

  • Within the framework of this internal policy, the Company has established the Anti-Money Laundering and Counter-Terrorism Financing Policy (the "Policy"). The Policy applies to all personnel and demonstrates a commitment to maintaining the highest standards in the industry by taking a strict stance against illegal activities, particularly money laundering.

1.2 Definition of Money Laundering

  • Money laundering is a term that defines many illegal offenses involving the "cleaning" of money obtained from certain crimes (such as blackmail, insider trading, and drug trafficking), which is considered "dirty," so that it appears to have been obtained from legal activities. This is done so that it can be processed by banks and financial institutions without arousing suspicion. Money laundering can be carried out through many methods of varying levels of complexity and sophistication.

  • Actions such as the conversion, transfer, concealment, cover-up, or acquisition of funds obtained from criminal activities, or providing participation/assistance in these processes – are all forms of money laundering.

1.3 Distribution of the AML Policy

  • The Executive Management Team has reviewed and approved this AML Policy. The Policy has been distributed to all personnel, including frontline employees, team leaders, managers, and the Board of Directors. When updates are made, it is re-published and distributed.

  • One of the core responsibilities of the Money Laundering Reporting Officer (MLRO) – who is also considered the Compliance Officer – is to prepare a report that evaluates the effectiveness of the Policy and its associated operational procedures and is submitted to the Executive Management Team at least once every twelve (12) months.

  • In addition, the MLRO makes recommendations to management about possible improvements to operational processes or policies. The Executive Management Team will evaluate this Policy at least once a year to determine the necessary updates. The MLRO should receive recommendations if necessary.

  • Except for the guidance of competent authorities, any proposed changes to the Policy must be reviewed and approved by the MLRO, the Executive Management Team, and legal counsel.

2 – MONEY LAUNDERING REPORTING OFFICER (MLRO) - COMPLIANCE OFFICER

2.1 Appointment of the MLRO / Compliance Officer

  • It is mandatory that a senior member of staff with appropriate experience is appointed as the Money Laundering Reporting Officer (MLRO) at all times. The person responsible for compliance has been designated, and their contact information has been made accessible to all employees and the relevant personnel of service providers.

2.2 Reporting Structure and Independence

  • The MLRO does not hold any other position within the organization or any affiliated company or supplier and operates independently of the organization's other functions in order to prevent conflicts of interest. Although the MLRO is under the supervision of the CEO, they have the autonomy to carry out their duties completely independently of the organization's other departments. The MLRO has the full and open support of the Executive Management Team in carrying out their duties. All personnel are obliged to cooperate with the MLRO (or their duly appointed representative) in carrying out their duties.

2.3 Duties and Responsibilities of the MLRO

  • To establish procedures that ensure compliance with all relevant laws, regulations, guidance principles, codes of practice, and Company policies.

  • To supervise all compliance-related activities of the Company and its service providers.

  • To report to the CEO and provide information about the corrective actions taken.

  • To hold regular Compliance Meetings with selected senior managers.

  • To update and maintain all compliance policies.

  • To organize regular training programs for all departments.

  • To be the point of contact with relevant regulatory bodies.

  • To report to senior management and, if necessary, to regulatory bodies in the event of violations.

  • To ensure the regular review of the internal control system.

3 – COMPANY POLICY AND COMMITMENT

  • The Company establishes appropriate policies and procedures to support the AML policy and monitors compliance with them. It is ensured that personnel are subjected to comprehensive training on AML procedures.

  • The objectives of the Policy are:

  • To ensure the Company's full compliance with all legal regulations,

  • To protect employees, as individuals, from legal violations,

  • To prevent the Company's reputation from being damaged by money laundering/terrorism financing,

  • To make a positive contribution to the fight against crime and terrorism.

4 – SCREENING AND MONITORING

4.1 Collection of Account Information

  • When opening a new customer account, the information provided is collected and examined for possible suspicious connections. Suspicious items are:

  • Accounts with similar information,

  • Multiple accounts created with the same email address,

  • The customer having more than one account,

  • Information found suspicious by the Fraud/Security teams.

  • In these cases, the Financial Services team is informed and action is taken according to business rules. This may include closing the account, enhanced review, and restricting deposit/withdrawal methods.

4.2 Enhanced Due Diligence (EDD)

  • Some customer relationships may carry a higher AML risk. In this case, Enhanced Due Diligence is applied in addition to normal procedures.

  • In this process, the customer's identity, financial history, and source of funds are verified. If necessary, additional documents are requested. Example situations:

  • If the customer is located outside the geographic area where the company provides services,

  • If there are unusual account movements,

  • If the customer is a Politically Exposed Person (PEP),

  • If there are other situations that the Company considers risky.

4.3 PEP – Politically Exposed Person

  • A PEP is a person who holds a significant public office in any country. Examples: Heads of state, judges, senior military officers, and close family members.

  • If there is a possibility of a PEP, the account is frozen, the MLRO is notified, and an assessment is made.

4.4 Reporting

  • If there are reasonable grounds to believe that a customer or account may be associated with money laundering, a notification is promptly made to the relevant authorities.

  • If suspicions are confirmed through internal review:

  • The account is frozen,

  • Pending transactions are stopped,

  • The necessary information is transmitted to the legal authorities,

  • The MLRO prepares the relevant reporting forms and submits them to the regulator.

  • In addition, daily/weekly reports, suspicious transaction reports (SAR), and PEP reports are made.

4.5 Continuous Monitoring

  • All customer/personnel transactions are continuously monitored. The MLRO or authorized persons provide AML training:

  • Procedure for reporting suspicious activities,

  • Recognizing risky behaviors,

  • Risk assessment in new products/services,

  • Transaction analyses according to specific time periods,

  • Requesting reasoned explanations from the customer.

5 – MANAGEMENT OF COMPLIANCE AND AML POLICIES

  • The Company's legal compliance with the AML/CFT program is regularly monitored. The Policy is reviewed every year and updated in line with new products/regulations. The effectiveness of the AML/CFT program is periodically evaluated. This ensures its compliance with best practices and regulations in the industry. The Company guarantees to act in accordance with the legal obligations in all jurisdictions in which it operates.

Know Your Customer (KYC)

Introduction

By accepting the Terms, you authorize us or third parties (including regulatory bodies) to carry out any verification checks (the "Checks") that we or they may request to verify your identity and contact information.

During these Checks, we may restrict withdrawals from your Account.

If any information you provide is false, inaccurate, misleading, does not match your identity, or is otherwise incomplete, we reserve the right, among other measures, to immediately close your account and/or prevent you from using the services.

In the event that we cannot confirm that you are of legal age, we may suspend your Account. If we determine that you were under the legal age at the time you carried out gambling or gaming transactions:

Your Account will be closed;

all transactions made during that period will become void, and all related funds you deposited will be refunded;

all winnings you won during that period will be taken from you, and you will be required to return to us all funds withdrawn from your Account.

In the event of any change in your personal information, you must inform us by contacting the Support unit.

Purpose of the Policy

The Company will request identity verification of the users of its Services in the following cases:

  1. Suspicion of fraud, money laundering, criminal activity, etc.;

  2. Doubts about the authenticity of the documents provided;

  3. Violation of the conditions for using the Company's services;

  4. Other cases that the Company deems appropriate.

In line with this request, the Company may request additional documents in addition to a standard set of identity information and documents.

The minimum set of identity information includes:

  • full name;

  • date of birth;

  • nationality;

  • permanent residence address;

  • identity number;

The required documents are:

  • the customer's valid passport / identity card;

  • a document verifying the customer's permanent residence address as of that date (bill, bank statement, etc.)

The additional documents are:

  • an additional national identity card (driver's license, military ID, etc.);

  • photographs of the user's open passport with their face in the background (the document must be legible)

  • a photograph of the front of the bank card (the first 5 and last 4 digits, the cardholder's name, and the expiration date must be legible).

In addition, the Company may ask the User to submit source of funds documents, which are important to ensure that the User submits evidence identifying the real source(s) of the funds they use to bet or play.

This information may be in the following forms:

  • proof of income: Payslip/Director's remuneration/Dividend/Pension;

  • a bank statement/savings account clearly showing consistent incoming values from an identifiable source;

  • a trust deed clearly showing a consistent entitlement to the funds;

  • dated proof of the award/payment made to the User;

Documents provided by the User will not be approved for the following reasons:

  • The address/name in the documents does not match the account name/address;

  • Illegible documents or copies;

  • the document is Unacceptable (for example, the user sends a copy of a document that is not among the documents accepted for identity verification, or a copy of a mailing envelope instead of a real bill);

  • other reasons deemed appropriate by the Company's employees or contractors.

Based on the results of the analysis of the documents provided, the Company will produce a resolution in accordance with the Terms and Conditions, the Privacy Policy, the Website's License Agreement, and the requirements of the legislation.

Obligations

Due Diligence (DD): The Company's customers must be subjected to the due diligence process and records must be kept.

Anonymous Accounts: Anonymous or nominal account registrations are prohibited. Existing anonymous accounts, or accounts believed to be pseudonymous, or accounts with inconsistent identity information, must be subjected to the appropriate due diligence process to determine the identity and good faith of the account holder as soon as possible. If it is not possible to determine the identity of the account holder, the account must be closed, the winnings must be cancelled, and the deposits must be paid back to the account from which they were received, or withheld if the refund of the deposits is impossible or costly.

Double/Multiple Accounts: Many customers wish to operate parallel accounts to separate their gambling spending. Despite this activity, the Company will detect and associate "linked" accounts that may belong to the same person or may be under the control of the same person. The Company has the right to cancel the additional account or accounts of the player in question, cancel the winnings won in this way, and refund the deposits to the account holder.

Politically Exposed Persons (PEP). The Company is obliged to respond to any attempt to gamble by any person who qualifies as a Politically Exposed Person, that is, any person who holds a significant public office (or has held such office at any time in the previous year), has access to public funds, or is in a position of influence. PEPs also include the easily identifiable family members and business associates of these persons. A risk-based approach must be applied according to the value and scale of the gambling and the location of such customers. Questionnaires must include questions that identify PEPs.

The Company reserves the right to unilaterally reject the application of any customer and/or terminate the provision of services in the event of a violation of the KYC policy, without providing any explanation or justification to the customer.