AML Policy
Company introduction
Wild Blackfin Limited SRL, (hereinafter referred to as “Stupidcasino” or as “the Company”) is registered in Costa Rica with Registration Number 3-102-916426 and its registered address at Avenidas 8 & 10, Calle 39, LY Center, 11501, San Jose, Costa Rica. Wild Blackfin Limited SRL is a B2C remote Gaming Company, licenced by the Anjouan Gaming Board under licence number ALSI-202601043-FI2 and operating through the website stupidcasino.com
The has established compliance measures commensurate with its services and products that are reasonably designed to detect any illicit activity on its website. Such measures include customer onboarding and compliance screenings of its customers and risk-based controls. Policy Statement
The company is not classified as a financial institution under the Laws of The Autonomous Island of Anjouan and, as such, is not directly governed by the regulations that apply to financial institutions, money transfer services, or virtual asset service providers. However, in line with the Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) regulations set by the The Autonomous Island of Anjouan Gaming Board, the Company strictly prohibits and rejects the use of its products for any illegal activities, such as money laundering, terrorist financing, or violations of trade sanctions. This is in line with various national AML laws and regulations. The Company also keeps up with guidelines set by the Financial Action Task Force (FATF) and the The Autonomous Island of Anjouan Gaming Board and will make any necessary updates to comply with changes in the law. The Company’s intention is to follow best practices in safeguarding against Stupidcasino products being used to facilitate such activities. Adoption of an AML policy, and procedures and controls. Designation of a Compliance Officer / MLRO to oversee the implementation of the AML policy, procedures and controls. Provision education and training to employees; and
Independent reviews, monitoring and maintenance of the policy, procedures and controls. Definitions
Placement. During this stage, the money launderer introduces the illegal proceeds into the financial system through financial institutions, casinos, shops and other cash intensive businesses. This is done among other things by buying chips for cash, then redeeming value without playing or with minimal playing, funding casino accounts with credit and debit cards, prepaid cards, checks and cryptocurrency and then requests for pay out and inserting funds into gaming machines and immediately claiming those funds as credits. Layering. This stage involves converting the proceeds of crime into another form to disguise the audit trail, source and ownership of funds. It can involve transactions such as transfers of funds from one account to another, sometimes to or from other casinos or jurisdictions, currency exchange, structuring and refining and gambling accounts held for storing moneys and hiding them from the authorities. Integration. The re-entry of funds into the economy in what appears to be normal business or personal transactions. Examples are the purchase of luxury assets, financial investments, investing in gaming companies or commercial investments. Financing of Terrorism (FT) is the financing of terrorist acts, of terrorists and terrorist organizations. A terrorist act is an act to intimidate a population, or to compel a government or an international organization to do or to abstain from doing any act. The most basic difference between financing of terrorism and money laundering involves the origin of the funds. Terrorist financing uses funds for an illegal political purpose, but the money is not necessarily derived from illicit proceeds. Money laundering always involves the proceeds of illegal activity. There is a need for the terrorist group to disguise the link between it and its legitimate funding sources. In doing so, the terrorists use methods similar to those criminal organizations use to launder money like cash smuggling, structuring, wire transfers, purchase of monetary instruments, use of debit and credit cards. While ML is concerned with obscuring the source of funds, FT is mostly concerned with obscuring the end recipient of the funds. Sanctions: refers to penalties or punitive measures imposed on individuals, companies, or countries that violate laws or regulations. These sanctions can be imposed by governments, regulatory bodies, or international organizations to control illegal activities or enforce compliance with legal standards. Suspicious Activity: refers to any behaviour or actions that seem unusual, out of the ordinary, or potentially harmful. It often indicates that something is wrong or that someone may be planning or engaging in illegal, unethical, or harmful activities. Governance
Stupidcasino is responsible for coordinating the implementation of the AML Policy. This includes developing AML initiatives, work together with other wcasino-online or external stakeholders to revise the AML policy, assessing new regulatory requirements and investigate potentially suspicious or unusual activity. Risk Assessment, Management and Risk-Based Approach
Customer risk
Geographical risk
Product, service and transaction risk
Distribution channels risk
The Compliance Officer/MLRO will perform regular assessments of the financial crime risks and Stupidcasino’s local strategy and success in mitigating those risks. Where a new service, customer group or new geography is addressed by Stupidcasino, the financial crime risk assessment will be updated during development/launch (to ensure that AML processes can support the new activities). In line with article 5h of the NOIS the company will assure that affiliated entities will meet the The Autonomous Island of Anjouan Anti Money Laundering and Terrorist Financing regulations. Such as far as these affiliated entities are affecting the business of the Company in The Autonomous Island of Anjouan. The results of the financial crime risk assessment will be used to support the development of appropriate systems and controls (policies and procedures) designed to minimize the risk of the Company, being used for the purposes of financial crime. Developments will be reported to the Board. To mitigate the risk of financial crime, Stupidcasino will ensure that appropriate risk-based systems and controls are in place and operated. Existing systems and controls will be reviewed and where necessary amended to reflect changes in assessed risk and identified vulnerabilities. Additional systems and controls will be implemented by the MLRO where required. Customer Due Diligence
Customers of the Company are subject to risk-based initial and ongoing due diligence procedures. Initial due diligence seeks to obtain the identity of the customer and verify the identity prior to the establishment of the business relationship. Information on the purpose and intended nature of the business relationship, is also obtained, such that the Company is able to establish the business and risk profile of the customer and to accept or reject a client based on the Client Acceptance Policy. Ongoing monitoring
The Company notes that it offers a single service to its customers whereby the applicant for business is affecting payments for remote gambling services. Therefore, in all cases, the Company understands the nature of the relationship with the customer and all payments received are sourced from this business. Customer initial due diligence information will be periodically reviewed to ensure that it remains up to date. This review is recorded by way of assessing whether any due diligence information has expired. The review will also assess whether any changes have been made to the company structure and/or the people involved. In such an instance, due diligence will be updated accordingly. Reporting
Any suspicious activities or transactions identified by Stupidcasino will be promptly reported to the appropriate authorities as mandated by the The Autonomous Island of Anjouan Gaming Board. Our designated Compliance Officer / Money Laundering Reporting Officer (MLRO) will be responsible for filing Suspicious Activity Reports (SARs) with the regulatory body in a timely manner. Employees are required to report any suspicious behaviour or activity directly to the MLRO without informing the customer involved (i.e., maintaining confidentiality to avoid tipping off). Record-keeping procedures
Customer identification documents. Transaction histories. Reports of unusual activities. Communication records related to customer accounts and investigations. This information will be readily available for review by the The Autonomous Island of Anjouan Gaming Board and other relevant authorities. Awareness and Training
Understand AML laws and regulations. Recognize potential money laundering risks and red flags. Know how to properly report unusual activities. Screening process
The screening of
