Documentation

Anti-money laundering

AML Procedures Guide

This guide summarizes Onmidev Ltd.'s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) procedures for iGaming operations under Anjouan Offshore Finance Authority (AOFA) license, aligning with FATF, EU directives, and Prevention of Money Laundering Law 2005. All staff must apply risk-based CDD before deposits, screen sanctions, monitor transactions, and report suspicions to MLRO without delay.

Governance and Responsibilities

Board approves policy annually, allocates resources, reviews quarterly reports; appoints independent MLRO (3+ years experience) reporting directly to Board.

  • MLRO oversees CDD/EDD, monitoring, STR filing to AOFA FIU, training, audits; cannot be overruled on compliance.

  • Compliance Committee (MLRO + managers) meets monthly to review alerts, risks, high-risk onboarding.

  • All employees: Report suspicions immediately; complete training (new hires 30 days, annual/bi-annual by role); violations risk discipline/license loss.

  • Customer Due Diligence (CDD)

Verify all customers before deposits via automated/manual process (1-4/24 hours).

  • Collect: Name/DOB/nationality/address/occupation/income/purpose; POI (photo ID valid 3+ months), POA (<3 months utility/bank), selfie/liveness, declaration (non-PEP, lawful funds).

  • Entities: Beneficial owners (25%+/control) with POI/POA, registration, board resolution.

  • Automated: Authenticity/facial/OCR/sanctions; manual: Risk classify, approve Low/Medium or escalate High-Risk.

Risk Assessment and EDD

Classify Low (standard CDD, quarterly review), Medium (monthly), High (EDD, weekly)—triggers: PEPs, FATF Grey/Black, high-risk jobs, €5k+ txns, complex BO.

  • EDD adds: SOW (payslips/tax/business docs), SOF (bank/loan/sale proof), video call, business purpose statement, MLRO written approval.

  • Reassess on changes/alerts (High-Risk every 6 months); reject 3 failed verifications.

Sanctions and Transaction Monitoring

Screen daily/weekly vs. UN/OFAC/EU/FATF/PEP/fraud lists; exact matches freeze account/assets to trust, STR to FIU.

  • Alerts: €15k single/€25k 30-day, high-risk geo, rapid in/out (80% 48h), no bets 72h post-deposit, profile mismatch.

  • Investigate: Review 6-month history, document; High-Risk enhanced (e.g., €5k txn review, semi-annual verify).

Suspicious Reporting and Termination

Report reasonable suspicion (no threshold/proof needed) to MLRO within 1-5 days; indicators: structuring, no gaming, high-risk sources, fraud/sanctions patterns.

  • STR process: Document, MLRO approve/form/submit securely to AOFA FIU, retain 10 years; no tipping-off (criminal offense).

  • Terminate for non-CDD/sanctions/forgery/high-risk: STR first, suspend, notify briefly, return funds originally.

Records, Training, and Reviews

Retain CDD/txns/compliance 10 years encrypted with audit trails; third-parties (processors/vendors) need AML proof/B2B cert.

  • Training: Covers red flags/laws; records 6 years.

  • Periodic CDD: Low 3yr/Medium 1yr/High 6mo; annual MLRO report to Board.