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234e is committed to preventing money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy governs all activities conducted on the 234e platform, including account creation, funding, wagering, and withdrawal of funds. The Policy applies to all customers, employees, and payment channels and requires strict adherence to applicable laws, regulatory directives, and internal procedures. 234e does not permit anonymous accounts or accounts opened in fictitious names, and funds must be transmitted through traceable, compliant methods only.
234e designates a Money Laundering Reporting Officer (MLRO) who bears full responsibility for the AML program. The MLRO oversees ongoing compliance, ensures appropriate staff training, and maintains the systems and controls necessary to detect and mitigate money laundering and terrorist financing risks. The AML program is reviewed and updated regularly to reflect changes in regulatory requirements and business risk.
On registration, 234e collects minimum identification data suitable to establish the customer’s identity and assess risk. The information collected includes: date of birth, full name, residence address, contact information, payment method details, a valid email address, and a unique account credential set. The Company may request supporting documentation prior to processing payments exceeding USD 2,000 per event or when cumulative payments over a defined period warrant enhanced verification. Acceptable documents include a government-issued identity document, proof of address (no older than three months), and any additional information necessary to verify identity in accordance with data protection laws. The Company may verify identity through independent verification services, public records, or financial institution references. Any uncertainty regarding the accuracy of customer information is escalated to the MLRO for review.
234e screens against government and international sanctions lists when establishing or updating customer records. Accounts linked to sanctioned individuals or entities are frozen or closed in accordance with applicable sanctions obligations. Politically Exposed Persons (PEPs) receive enhanced due diligence at onboarding and on an ongoing basis due to increased risk of illicit activity.
234e implements ongoing risk-based monitoring of customer activity. All transactions are subject to automatic monitoring with periodic manual review. A daily report identifies transactions above USD 1,000 and associated details for review. Alerts are triggered by indicators such as: transfers to or from high-risk jurisdictions without clear economic purpose, rapid movement of funds without legitimate rationale, unusual or unexplained transaction patterns, or discrepancies in provided documentation. When suspicious activity is detected, the MLRO or Transaction Monitoring Department will investigate, request additional information as needed, and determine whether to escalate, suspend activity, or file a report with the relevant authorities.
Funds received from customers are restricted to electronic channels and must be traceable to the originating source. 234e will not accept cash or non-electronic payments. Winnings and refunds are returned to the same payment route used for funding where feasible. Inter-account transfers between customer accounts or third-party transfers are prohibited unless explicitly authorized under regulatory guidance.
Recordkeeping for financial transactions is maintained in accordance with applicable data protection and retention laws in the relevant jurisdiction, and is accessible for audit and regulatory review as required.
234e maintains a restricted list of jurisdictions where business activity is limited or prohibited in order to comply with international sanctions and internal risk assessments. The policy includes periodic screening of customer data against sanctions and watchlists, and the competent authority’s guidance on risk-based onboarding and monitoring. Where risk indicators are identified, enhanced due diligence is applied or accounts are closed as appropriate.
Educational programs for employees are conducted under the supervision of the MLRO and the Transaction Monitoring Department. Training occurs at least annually and is updated to reflect changes in the regulatory landscape and typologies of money laundering and terrorist financing. Training covers red flag indicators, escalation procedures, roles and responsibilities, and data retention requirements.
All AML records, including customer identification data, due diligence materials, and transaction logs, are retained for a minimum period required by law in the applicable jurisdiction. Data processing complies with relevant data protection regulations, and access to sensitive information is restricted to authorized personnel only.
When suspicious activity is identified, the MLRO is responsible for deciding on the appropriate course of action, including internal escalation, additional information gathering, freezing of accounts as warranted, and reporting to the proper authorities in accordance with applicable laws and regulations. 234e cooperates with regulatory authorities and provides information in response to lawful requests while safeguarding customer privacy to the extent permitted by law.
This AML Policy is approved by 234e senior management and is reviewed at least annually or more frequently if required by changes in law, regulation, or risk assessment outcomes. Updates are communicated to all relevant personnel, and training is refreshed to reflect any amendments.