Anti-Money Laundering

Introduction: SEVENTORIA B.V., a company lawfully registered under Curaçaoan legislation, is the operator of the PariPulse platform. The company is registered under the number 163919 and has its official location at Abraham Mendez Chumaceiro Boulevard 03, Curacao. PariPulse, as a responsible operator, guarantees adherence to international standards and legal frameworks to stop money laundering and related illegal actions.
Purpose of the Anti-Money Laundering (AML) Policy: The main goal of the AML Policy is to give all users and clients that use its platform the utmost security and confidence. To do this, the business uses a strict three-step account verification procedure. This procedure has been meticulously crafted to guarantee the precise identification and validation of each user of the site. The purpose of this procedure is to verify that the payment methods used for deposits and withdrawals are valid, not stolen, and are only being used by the account’s lawful owner. It also aims to verify that the personal information submitted at registration is genuine.
In order to prevent money laundering and reduce associated risks, the AML policy acts as a broad framework. It acknowledges the need for customized safety measures to reduce possible risks due to a number of circumstances, including nationality, place of origin, and the particular payment or withdrawal methods used.
We have put strong safeguards in place to reduce and manage the risks related to money laundering. These steps include allocating enough funds and using industry-standard procedures to successfully detect and fix problems.
We are firmly committed to adhering to the highest standards of AML protocols in accordance with EU guidelines. It ensures compliance through its policies, which are enforced by the management and employees, to prevent the misuse of its services for money laundering purposes.
The AML program implemented by PariPulse is structured to fully comply with the following legal and regulatory frameworks:
European Union (EU): Directive 2015/849 of the European Parliament and Council, dated May 20, 2015, which addresses measures for preventing the financial system from being exploited for money laundering activities.
European Union (EU): Regulation 2015/847 concerning the requirements for information that must accompany fund transfers to enhance transparency and traceability.
European Union (EU): Various sanctions and restrictive measures targeting specific individuals, entities, or jurisdictions, as well as prohibitions on certain goods and technologies, including those with dual-use applications.
Belgium (BE): The Law of September 18, 2017, aimed at preventing money laundering and curbing the excessive use of cash transactions.
Curaçao (CW): Regulations designed to combat money laundering, the financing of terrorism (ML/FT), and the proliferation of weapons of mass destruction.

Money laundering refers to a series of deliberate actions aimed at concealing the origins of property or funds obtained through criminal activities. Specifically, it involves:

• Conversion or Transfer of Illegally Obtained Property. When property, especially money or financial assets is transferred or converted with full awareness that it comes from illegal activity, this happens. The main objective is to conceal or hide the property’s illicit origins. This may also entail helping a person or organization engaged in such illegal activity to escape the repercussions of their activities;
• Concealment or Misrepresentation of Property Details. The actual nature, source, location, destination, transportation, ownership, or related rights of property are also concealed or misrepresented in money laundering. This is done with full awareness that the property in issue was obtained via involvement in criminal activity or through illegal means;
• Acquisition, Possession, or Use of Illegal Property. When the recipient of the property is aware that it is the result of illegal conduct or involvement in it, the purchase, ownership, or use of the property is also considered money laundering;
• Assistance and Participation. Participating in, collaborating with, trying, aiding, abetting, facilitating, or guiding the conduct of any of the aforementioned acts are all considered forms of money laundering.

Additionally, money laundering is still illegal even if the illegal operations that created the property were done in a different jurisdiction, such as another EU member state or a third nation. This transnational aspect emphasizes how crucial it is to have concerted international actions in order to successfully combat money laundering.

To ensure compliance with anti-money laundering (AML) regulations, PariPulse has implemented a structured approach to the prevention of money laundering activities. The responsibility for overseeing these measures has been entrusted to the top leadership of SEVENTORIA B.V., who bear ultimate accountability for the effective execution of the AML framework.

In addition to the oversight provided by senior management, the role of an Anti-Money Laundering Compliance Officer (AMLCO) has been established. The AMLCO is specifically tasked with the implementation, monitoring, and enforcement of the company’s AML policies and procedures across all operations.

The AMLCO operates directly under the authority and guidance of the company’s general management team, ensuring that the measures taken align with the overarching compliance strategy and meet regulatory requirements. This structure reinforces the company’s commitment to combating money laundering through a clear chain of responsibility and dedicated enforcement mechanisms.

A crucial component of the KYC policy and the laws pertaining to money laundering is the official identification of clients upon their entry into business relationships.

The following essential ideas form the basis of this identification:
A copy of your ID card, passport, or driver’s license is shown with a handwritten note that lists six randomly generated digits. A second image that features the user’s or customer’s face is also necessary. The user/customer may exclude any information except the photo, first and second names, gender, country, and date of birth. in order to protect their privacy.
Please take note that the ID must be visible in all four corners in a single picture, and all information must be easily accessible aside from the names mentioned above. Should the need arise, we may request complete information.
If more checks are required, an employee may carry them out.

Proof of address will be provided via two separate computerized checks that employ two distinct databases. If an electronic test fails, the user/customer can do a manual proof.

A recent utility bill received to your registered address within the previous three months, or an official document issued by the government proving your state of residency.

To expedite the review process, please send the document in a clear resolution with all four corners viewable and all text readable.

For example, an electricity bill, water bill, bank statement, or any government mail addressed to you.

Depending on the scenario, an employee may do further checks.

When a player deposits an amount exceeding five thousand euros, it is mandatory to investigate and verify the source of their wealth (SOW). This process ensures transparency and compliance with financial regulations.

Some common examples of acceptable sources of wealth include:

• Ownership of a business or entrepreneurial ventures;
• Income derived from employment or professional activities;
• Inheritance received from family or relatives;
• Profits or earnings from investments;
• Financial support or contributions from family members.

It is essential to establish and validate the origin and legitimacy of these funds. If sufficient clarity about the source of wealth cannot be obtained, additional documentation or proof may be requested by a company representative.

In cases where a user deposits the specified amount in a single transaction or through multiple smaller transactions that collectively exceed the threshold, their account will be temporarily frozen. They will be manually notified via email, detailing the required steps to proceed. Additionally, information regarding this process will be made available on the website for reference.

To further strengthen the verification process, PariPulse may request a bank transfer or credit card transaction as additional proof of identity. These methods provide supplementary insights into the user’s financial background and confirm the authenticity of their account details. These measures are designed to uphold high standards of integrity and ensure that the platform operates within legal and ethical frameworks.

To address the varying levels of risk and the differing financial conditions across regions worldwide, PariPulse classifies countries into three distinct risk categories: low risk, medium risk, and high risk. This classification determines the verification requirements and limits for users from each region.

Low-Risk Region:

For nations categorized as low risk, the standard three-step verification process applies as outlined previously. Users from these regions are subject to the regular deposit, withdrawal, and tipping thresholds for verification.

Medium-Risk Region:

Countries classified as medium risk will have stricter verification requirements that activate at lower financial thresholds. While Step One of the verification process will proceed as usual, the following rules apply for Steps Two and Three:

• Step Two Verification: Triggered when a user deposits or withdraws an amount equal to or exceeding $1,000 (one thousand dollars) or tips another user/customer $500 (five hundred dollars);
• Step Three Verification: Initiated when a user deposits or withdraws an amount equal to or exceeding $2,500 (two thousand five hundred dollars) or tips another user/customer $1,000 (one thousand dollars).
  Additionally, users from low-risk regions who engage in cryptocurrency exchanges into other currencies will be treated as users from medium-risk regions.

High-Risk Region:

Countries classified as high risk are prohibited from accessing PariPulse. This ban is enforced to minimize exposure to elevated risk scenarios. The list of high-risk regions is reviewed and updated periodically to reflect the rapidly evolving global landscape.

This multi-tiered approach ensures compliance with international standards, safeguards the platform from potential risks, and provides a secure and fair environment for all users.

The AML compliance program at PariPulse ensures ongoing scrutiny of transactions to identify any activity that appears unusual or suspicious in relation to a customer’s profile. This monitoring process operates across three distinct levels of control:

1) Initial Line of Defense:
PariPulse exclusively collaborates with reliable Payment Service Providers (PSPs) that maintain robust AML policies. These policies are designed to prevent the vast majority of questionable deposits from occurring without first undergoing comprehensive Know Your Customer (KYC) procedures. By partnering with such PSPs, the platform effectively filters out a significant portion of potentially suspicious activity at the entry point.

2) Secondary Layer of Monitoring:
The platform ensures that all interactions with customers, players, or their authorized representatives trigger a careful review of account transactions. This includes but is not limited to:

• Requests for financial transactions involving a user account;
• Queries regarding payment methods or services linked to an account.

The integrated three-step verification system, coupled with region-specific risk management protocols, ensures that a comprehensive understanding of all users is maintained.

Additionally, transactions are systematically reviewed through automated processes, with employees conducting secondary checks to ensure the highest level of security. If transactions raise concerns about their legitimacy or the origin of funds, these are flagged as atypical and subjected to deeper analysis. Employees are expected to report any activity that cannot be clearly attributed to a lawful source of income or known customer activities to the AML team.

Transactions requiring further clarity, submitted to customer support or compliance managers, undergo additional due diligence to establish their legality. Any difficulty in identifying legitimate purposes or origins of funds leads to their classification as atypical and escalates scrutiny.

3) Final Layer of Oversight:
As the ultimate safeguard, PariPulse conducts manual reviews of accounts deemed high-risk or flagged for suspicious activity. This measure ensures a thorough investigation, minimizing any chance of undetected money laundering.

If evidence of fraudulent activity or money laundering is uncovered, the appropriate authorities are promptly notified. Through this multi-tiered approach, PariPulse remains committed to fostering a secure and compliant environment.

PariPulse’s internal processes outline in detail, for the benefit of its employees, when it is required to report and how to proceed with such reporting.

Certain objective criteria signal potential unusual transactions and demand immediate attention. These include:

• Transactions Flagged by Authorities:
  Any transaction that has been reported to law enforcement or judicial bodies as suspicious or potentially unlawful;
• Sanctioned Entities Involvement:
  Transactions that involve an individual or entity named on United Nations or European Union sanctions lists, indicating a possible connection to prohibited activities;
• High-Value Transactions:
  Any financial transaction equaling or exceeding NAf. 5,000 (or its equivalent in USD), including activities such as bank transfers, purchases of credits or gaming chips, or prize payouts;
• Connections to Money Laundering or Terrorism Financing:
  Transactions where there is reasonable suspicion of links to money laundering (ML) or terrorist financing (TF) activities;

Submitting Reports via the goAML Portal

Reports of transactions that meet these indicators must be submitted through the goAML portal, accessible at https://portal.fiucuracao.cw. Organizations must first complete the registration process to gain access to the portal. All reports must be written in English for standardization and compliance purposes.

Timeframe for Reporting:

Reports concerning transactions that fulfill objective indicator criteria are required to be submitted within a strict timeline of 48 hours from the time the transaction was identified or completed. This ensures timely communication with relevant authorities and allows for swift action to mitigate risks.

By adhering to these procedures, organizations uphold their commitment to combating financial crimes and ensuring a secure transactional environment.

The AML requirements, including minimum KYC criteria, will be converted into operational instructions or processes available on PariPulse’s intranet site.

The Company is obligated to securely maintain specific records and information for a duration of five years following the conclusion of a business relationship with a client or after the completion date of an occasional transaction. This ensures compliance with legal and regulatory obligations. The retained records include the following:

• Client Identification Documentation:
  Complete copies and details collected during the client identification process, verifying the customer’s identity in adherence to compliance standards;
• Transaction Records:
  Comprehensive evidence of all domestic and international transactions conducted by the client, maintained for accountability and auditing purposes;
• Client Correspondence:
  All forms of communication and correspondence with clients, documenting interactions for transparency and verification when needed;
• Reports on Suspicious Activities or Transactions:
  Records of any Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) generated by staff. This includes the in-depth analysis conducted by the Compliance Officer (CO), their findings, and any subsequent communication with FUI Curacao or relevant authorities;
• Client Risk Profiles:
  The documented risk profiles of players, created as part of ongoing risk assessment and monitoring efforts.

All records and information are stored securely, both online and offline, with robust encryption protocols in place to protect against unauthorized access or breaches. This dual storage system ensures data integrity and accessibility while maintaining the highest standards of confidentiality and security.

PariPulse human personnel will do manual controls based on a risk assessment for which they will receive specific training.
The training and awareness program is represented in its use:
An obligatory AML training program in compliance with the current regulatory developments, for anyone in touch with funds.
Academic AML training seminars for all new staff.
The substance of this training program must be determined in line with the type of business the trainees work for and the positions they occupy. These sessions are delivered by an AML specialist from the SEVENTORIA B.V. AML team.

Internal audits periodically develop missions and report on AML activity.

All data provided by a user/customer will be kept safe and will not be sold or distributed to anyone. Only if required by law or to prevent money laundering, data may be shared with the relevant state’s AML authorities.
PariPulse shall observe the recommendations and standards of the Data Protection Directive (formally Directive 95/46/EC).

For any inquiries regarding our Anti-Money Laundering (AML) and Know Your Customer (KYC) policies, we encourage you to reach out to us:

Email: [email protected]

Should you have any concerns or grievances related to our AML and KYC policies, or if you wish to raise issues about the verification processes conducted on your account or personal information, please get in touch with our security team directly:

Email: [email protected]
We are committed to addressing your questions and complaints promptly and ensuring transparency in our procedures.