TOP CASTLE 777 AML Policy
1. Objective of the AML Policy
We seek to offer the highest security to all of our users and customers on TOP CASTLE 777 for that a three-step account verification is done in order to insure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.
TOP CASTLE 777 also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.
TOP CASTLE 777 is committed to high standards of anti- money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
The AML program of TOP CASTLE 777 is designed to be compliant with:
EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
EU: “Regulation 2015/847 on information accompanying transfers of funds”
EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash"
2. Definition of money laundering:
Money Laundering is understood as:
• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before. Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
3. AML policy changes and implementation requirements:
Each major change of TOP CASTLE 777 AML policy is subject to be approval by the general management of TOP CASTLE 777 and the AML compliance officer.
4. Three step Verification:
A. Step ONE verification:
Step ONE verification must be done by every user and customer to withdraw. Regarding of the choice of payment, the amount of payment, the amount of withdraw, the choice of withdraw and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. Following information’s must be filled in: first name, second name, date of birth, country of usual residence, gender and full address.
B. Step TWO verification:
Step two verification must be done by every user which deposit over 2000$ (two thousand Dollar) or withdraws over 2000$ (two thousand Dollar) or sends another user over 1000$ (one thousand Dollar) Until step two verification is done the withdraw, tip or deposit will be hold. Step to verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different. There will also be an electronic check if the filled in Data from the step one verification is correct. The electronic check will check via two different databanks to insure the given information’s matches with the filled document and the name from the ID: If the electronic test fails or is not possible the user/customer is required to send in a conformation of his current resident. A certificate of registration by the government or a similar document is required.
C. Step THREE verification:
Step three verification must be done by every user which deposit over 5000$ (five thousand Dollar) or withdraws over 5000$ (five thousand Dollar) or sends another user over 3000$ (three thousand Dollar) Until step three verification is done the withdraw, tip or deposit will be hold. For step 3 a user/customer will be asked for a source of wealth.
5. Customer identification and verification (KYC)
The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles:
• A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers.
• Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture. To secure their privacy.
Please note that all four corners of the ID have to be visible in the same image and all details has to be clearly readable besides the named above. We might ask for all details if necessary.
An employee may do additional checks if necessary, based on the situation.
6. Proof of Address
Proof of address will be done via to different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manually proof.
• A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proofs your state of residence.
To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible, and all text is readable.
For example:An electricity bill, water bill, bank statement or any governmental post addressed to you.
An employee may do additional checks if necessary, based on the situation.
7. Source of funds
If a player deposits over a five thousand euro there is a process of understandings the source of wealth (SOW)
Examples of SOW are:
• Ownership of business
• Employment
• Inheritance
• Investment
• Family
It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or prove.
The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and an information on the website itself.
TOP CASTLE 777 also asks for a bank wire/credit card to further insure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
8. Reporting of Suspicious transactions on TOP CASTLE 777
In its internal procedures, TOP CASTLE 777 describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.
Depending on the result of this examination and on the basis of the information gathered, the AML team:
• will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
• will decide whether or not it is necessary to terminate the business relations with the customer.
9. Data Security
All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
TOP CASTLE 777 will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)
