AML Policy | Platform1 - Anti-Money Laundering & Compliance

Policy Overview

As a provider of iGaming solutions, Platform1 operates in a regulated environment where Anti-Money Laundering (AML) compliance is essential. This policy outlines our commitment to detecting, preventing, and reporting suspicious activities that may indicate money laundering or terrorist financing.

Our Commitment

Zero Tolerance: We have a zero-tolerance approach to money laundering and terrorist financing

Full Compliance: We comply with all applicable Estonian and EU regulations

Continuous Monitoring: We continuously monitor transactions and client activities

Staff Training: All staff receive regular AML training and updates

Regulatory Framework

Our AML policy is based on and complies with the following regulatory requirements:

Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFPA)

The primary Estonian legislation governing AML/CTF requirements for financial institutions and service providers.

EU Fifth Anti-Money Laundering Directive (5AMLD)

European Union directive establishing comprehensive AML/CTF frameworks across member states.

Financial Action Task Force (FATF) Recommendations

International standards for combating money laundering and the financing of terrorism and proliferation.

Gaming Industry Specific Regulations

Malta Gaming Authority (MGA), UK Gambling Commission (UKGC), and other gaming regulators' AML requirements.

Customer Due Diligence (CDD)

We implement comprehensive Customer Due Diligence procedures to verify the identity of our clients and assess their risk profile:

Standard Due Diligence

All Clients

When applied: For all new business relationships and transactions above €1,000

Requirements:

Identity verification using government-issued documents
Proof of address verification
Business registration documents (for corporate clients)
Source of funds declaration
Beneficial ownership identification

Enhanced Due Diligence (EDD)

High Risk

When applied: For high-risk clients, PEPs, or transactions above €15,000

Additional requirements:

Enhanced identity verification and background checks
Source of wealth documentation
Ongoing monitoring of business relationship
Senior management approval for relationship
Regular review of risk assessment

Simplified Due Diligence (SDD)

Low Risk

When applied: For low-risk clients from low-risk jurisdictions

Reduced requirements:

Basic identity verification
Simplified documentation requirements
Reduced ongoing monitoring
Risk-based approach to verification timing

Risk Assessment Framework

We maintain a comprehensive risk assessment framework that evaluates various risk factors:

Geographic Risk

High Risk Countries: FATF blacklisted countries, countries with inadequate AML/CTF systems

Medium Risk Countries: Countries under FATF monitoring or with deficiencies

Low Risk Countries: EU/EEA countries, countries with robust AML/CTF frameworks

Customer Risk

High Risk: PEPs, sanctioned individuals, cash-intensive businesses, offshore entities

Medium Risk: High-value transactions, unusual business activities, complex ownership structures

Low Risk: Established businesses, transparent ownership, reasonable transaction patterns

Product/Service Risk

High Risk: Large cash transactions, anonymous transactions, cross-border services

Medium Risk: Digital payments, cryptocurrency integration, high-value gaming

Low Risk: Standard gaming services, transparent payment methods, regulated markets

Transaction Risk

High Risk: Transactions >€15,000, unusual patterns, frequent large deposits/withdrawals

Medium Risk: Transactions €1,000-€15,000, occasional large transactions

Low Risk: Transactions <€1,000, consistent patterns, reasonable gaming activity

Prohibited Activities

Platform1 strictly prohibits the following activities and will terminate business relationships where such activities are suspected:

Money Laundering

Zero Tolerance

Any attempt to disguise the origins of illicitly obtained funds through our gaming platforms or services.

Layering funds through multiple gaming transactions
Using gaming accounts for fund transfers
Converting criminal proceeds into gaming credits

Terrorist Financing

Zero Tolerance

Providing financial support or services to terrorist organizations or activities.

Transactions involving sanctioned individuals or entities
Fund transfers to terrorist-linked accounts
Services for individuals on terrorism watch lists

Sanctions Evasion

Zero Tolerance

Circumventing international sanctions or embargoes.

Services to sanctioned countries or regions
Transactions involving blocked persons
Facilitating sanctions circumvention

Structuring Transactions

Prohibited

Breaking down large transactions to avoid reporting thresholds.

Multiple transactions just below reporting limits
Coordinated activities across multiple accounts
Deliberate avoidance of CDD procedures

Transaction Monitoring & Reporting

We employ sophisticated monitoring systems and procedures to detect suspicious activities:

Automated Transaction Monitoring

Technology: AI-powered transaction monitoring system

Capabilities:

Real-time transaction screening
Pattern recognition and anomaly detection
Risk scoring and alerting
Integration with sanctions databases

Manual Review Procedures

Process: Human expert review of flagged transactions

Triggers:

High-value transactions (>€10,000)
Unusual transaction patterns
High-risk customer activities
Cross-border transactions

Suspicious Activity Reporting

Authority: Estonian Financial Intelligence Unit (FIU)

Reporting Requirements:

Suspicious transactions reported within 3 working days
Cash transactions >€10,000 reported
All terrorist financing suspicions reported immediately
Detailed documentation maintained for 5 years

Reporting Thresholds

Cash Transactions

€10,000

Mandatory reporting to FIU

Suspicious Activities

Any Amount

Report within 3 working days

Terrorist Financing

Any Amount

Immediate reporting required

Enhanced Due Diligence

€15,000

Enhanced verification required

Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

Customer Records

Retention Period: 5 years after relationship ends

Includes:

Identity verification documents
Proof of address documents
Business registration certificates
Beneficial ownership information
Risk assessment documentation

Transaction Records

Retention Period: 5 years after transaction

Includes:

Transaction details and amounts
Payment method information
Source and destination of funds
Purpose of transaction
Monitoring and review notes

Compliance Records

Retention Period: 5 years minimum

Includes:

Suspicious activity reports
Training records
Policy updates and approvals
Audit reports and findings
Regulatory correspondence

Training and Awareness

All Platform1 employees receive comprehensive AML training and regular updates:

Initial Training

Duration: Mandatory for all new employees within 30 days

Content includes:

AML/CTF legal requirements
Company policies and procedures
Risk identification and red flags
Reporting procedures and requirements
Customer due diligence procedures

Ongoing Training

Frequency: Annual refresher training plus ad-hoc updates

Content includes:

Regulatory updates and changes
New typologies and threats
Case studies and examples
System updates and procedures
Performance assessment and testing

Specialized Training

Target: Compliance officers and senior management

Content includes:

Advanced risk assessment techniques
Investigation procedures
Regulatory liaison and reporting
Industry best practices
Technology and system management

Contact Information

Money Laundering Reporting Officer (MLRO)

Email: compliance@platform1.ee

Secure Line: Available 24/7 for urgent reports

Address: Platform1, Tallinn, Estonia

Estonian Financial Intelligence Unit

Website: Estonian Police and Border Guard Board

Reporting: Electronic reporting system (goAML)

Hotline: Available for suspicious activity reports

Anonymous Reporting

Employees and third parties can report suspicious activities anonymously through our secure reporting channels. All reports are treated confidentially and investigated thoroughly.

Anonymous Email

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Anti-Money Laundering Policy

Policy Overview

Our Commitment

Regulatory Framework

Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFPA)

EU Fifth Anti-Money Laundering Directive (5AMLD)

Financial Action Task Force (FATF) Recommendations

Gaming Industry Specific Regulations

Customer Due Diligence (CDD)

Standard Due Diligence

Enhanced Due Diligence (EDD)

Simplified Due Diligence (SDD)

Risk Assessment Framework

Geographic Risk

Customer Risk

Product/Service Risk

Transaction Risk

Prohibited Activities

Money Laundering

Terrorist Financing

Sanctions Evasion

Structuring Transactions

Transaction Monitoring & Reporting

Automated Transaction Monitoring

Manual Review Procedures

Suspicious Activity Reporting

Reporting Thresholds

Record Keeping

Customer Records

Transaction Records

Compliance Records

Training and Awareness

Initial Training

Ongoing Training

Specialized Training

Contact Information

Money Laundering Reporting Officer (MLRO)

Estonian Financial Intelligence Unit

Anonymous Reporting