Company introduction
Ahnah Investments N.V. (hereinafter referred to as “Ahnah Investments” or as “the Company”) is registered in Curacao with registration number 16313 and registered address at Kaya W.F.G. (Jombi) Mensing 24 Unit A, Willemstad, Curacao. Ahnah Investments is a B2C remote gaming company, operating through the website https://bichomania.bet
Ahnah Investments 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
Ahnah Investments is not classified as a financial institution under Curacao law 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 Curacao Gaming Control Board, Ahnah Investments 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. Ahnah Investments also keeps up with guidelines set by the Financial Action Task Force (FATF) and the Curacao Gaming Control Board, and will make any necessary updates to comply with changes in the law.
Ahnah Investments’ intention is to follow best practices in safeguarding against Ahnah Investments products being used to facilitate such activities. Those best practices include:
- 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
The following definitions are widely used in the online gaming industry:
Money laundering:
All acts done with money of illegal origin to change its identity so that it appears to have originated from a legitimate source, can be considered money laundering (ML). It is the process of making dirty money look clean. Money Laundering consists of three phases:
- 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:
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
Ahnah Investments is responsible for coordinating the implementation of the AML Policy. This includes developing AML initiatives, work together with other Ahnah Investments 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
Ahnah Investments N.V. operates a risk-based approach to developing and operating its systems and controls designed to prevent financial crime.
AML risk is analysed, as applicable, into the following risk categories:
- 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 Ahnah Investments N.V.’s local strategy and success in mitigating those risks.
Where a new service, customer group or new geography is addressed by Ahnah Investments N.V., 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 Curacao Anti Money Laundering and Terrorist Financing regulations. Such as far as these affiliated entities are affecting the business of the Company in Curacao. 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 Ahnah Investments N.V., being used for the purposes of financial crime. Developments will be reported to the Board.
In order to mitigate the risk of financial crime, Ahnah Investments N.V. 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 Ahnah Investments will be promptly reported to the appropriate authorities as mandated by the Curacao Gaming Control 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
The Company will maintain detailed records of all customer identification and transaction data for a minimum of five (5) years. These records will include:
- Customer identification documents;
- Transaction histories;
- Reports of unusal activities;
- Communication records related to customer accounts and investigations.
This information will be readily available for review by the Curacao Gaming Control Board and other relevant authorities.
Awareness and Training
Ahnah Investments will provide regular AML training to all employees, particularly those in roles related to customer service, compliance, and finance. This training will ensure that staff members:
- 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 potential customers against sanctioned persons, against PEPs is carried out by Ahnah Investments N.V. via a 3rd party Provider, a holistic and seamless Customer Due Diligence software. The Company is obliged to undertake measures at law aimed at combating terrorism, terrorism financing and the financing of the proliferation of weapons of mass destruction. This includes obligations emanating from the National Interest (Enabling Powers) Act relating to sanctions screening, freezing of assets and reporting.
Sanctions lists
Sanctions list screening is the responsibility of the MLRO. The performance of the screening procedures may be delegated or outsourced.
In obtaining, applying, and disseminating government and FATF findings, the MLRO ensures that all customers and business partners (e.g. Distributors) with whom a business relationship is established, are subject to due diligence procedures that ensure screening against relevant notices published by the OFAC, FIU and FATF.
Sanctions screening will form part of the initial due diligence procedures as well as the ongoing monitoring of customers and business partners. ‘False positives’ are investigated, and any true sanction matches reported to the MLRO immediately.
Staff are required to report where they have knowledge or a suspicion that financial sanctions measures have been or are being contravened.
Politically Exposed Persons (PEPs)
It is Ahnah Investments N.V.’s policy not to accept PEPs as customers and the Company will proceed to end the relative business relationship with any individual/s found to be PEPs (notwithstanding declaring otherwise in the onboarding process).
Risk assessments for new customers, products or features will take account of the risk that the product might be used by PEPs for money laundering purposes.
Risks with Crypto payments
Cryptocurrency is decentralized digital money secured by cryptography and based on blockchain technology - that is, a distributed digital ledger that keeps a secure, transparent, and decentralized record of transactions.
Cryptocurrency is almost impossible to counterfeit or double-spend, so it might prove valuable to online gambling sites looking to become more secure and transparent.
However, their decentralized structure allows crypto to exist outside the control of governments and central authorities. Therefore, this new form of value is extremely unregulated.
Risks using cryptocurrency:
- Lack of legal framework;
- Volatility;
- Hacking concerns;
Cryptocurrency is an exciting, technology-powered form of value that promises to change many aspects of people’s lives - including their gambling habits. However, while promising, this technology is still riddled with loopholes and issues that need to be addressed to protect consumers and the gambling industry as a whole.
Apart from focusing on all the benefits of digital currencies, Ahnah Investments is aware of its potential risks and do its best to mitigate them.
Conclusion
Ahnah Investments is dedicated to creating a safe, secure, and transparent gaming environment. Our AML policy reflects our commitment to preventing financial crimes and adhering to the regulations established by the Curacao Gaming Control Board.