Anti-Money Laundering (AML) Policy

1. Introduction

Gamba.com, licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros under License No. ALSI-152512013-F13, acknowledges the risks of money laundering and terrorist financing in its operations. This AML Policy demonstrates our commitment to detect, prevent, and mitigate these risks in compliance with applicable laws and international standards.

2. Policy Statement and Objectives

Gamba.com is dedicated to preventing the misuse of its products for money laundering, terrorist financing, or any illicit financial activities. Our objectives are to:

  • Establish and enforce robust controls to prevent illicit use of our services.
  • Maintain a risk-based approach towards assessing and monitoring customer behavior.
  • Ensure comprehensive compliance with all relevant legislation and regulatory requirements.
  • Provide ongoing training and support to all staff to recognize and handle potential money laundering or terrorist financing activities.

3. Company Business Model

Gamba.com operates as an online gaming platform offering various forms of gaming and wagering. We acknowledge that our operations might be vulnerable to misuse by money launderers and terrorists, and thus, we have structured our business model and operations to promote transparency, customer due diligence, and compliance with all regulatory requirements.

4. Chief Compliance Officer

A Chief Compliance Officer (CCO) is appointed to oversee the enforcement of the AML policy and procedures. The CCO's responsibilities include establishing and maintaining necessary controls, staying updated with changes in legislation, and ensuring prompt and accurate reporting of suspicious activities to the appropriate authorities.

5. Know Your Customer (KYC) and Customer Due Diligence (CDD)
  • Customer Identification: We will collect and verify customers' identification information, such as government-issued IDs and proof of address.
  • Risk Assessment: Customers will be assessed and classified according to their risk profile based on provided information and transaction behavior.
  • Enhanced Due Diligence (EDD): For high-risk customers or unusual activities, additional information and documentation will be requested to better understand the nature of transactions.

6. Ongoing Monitoring and Reporting
  • Transaction Monitoring: Continuously monitor transactions for signs of unusual or suspicious activity.
  • Suspicious Activity Reporting (SAR): Report suspicious activities internally and, as required, to the relevant financial intelligence unit or regulator.
  • Record Keeping: Maintain comprehensive and retrievable records of all transactions and customer identification information as required by law.

7. Employee Training and Awareness

All employees will receive training on AML regulations, recognizing suspicious activities, and the proper reporting mechanisms. The training will be updated regularly to reflect legislative changes and emerging risks.

8. Review and Update of AML Policy

The policy will be reviewed and updated regularly to reflect changes in legislation, regulatory guidance, or the risk environment. The CCO is responsible for ensuring the policy remains current and robust.

9. Regulatory Compliance and Cooperation

Gamba.com is committed to full cooperation with regulatory and law enforcement authorities and ensuring that all reporting and compliance obligations under the laws of the jurisdiction are met.

10. Conclusion

Gamba.com is committed to high standards of anti-money laundering compliance and expects all employees, customers, and associates to adhere to these standards in preventing the misuse of its products and services for money laundering or terrorist financing purposes.

In constructing this policy, all areas, including customer due diligence, employee responsibilities, and continuous monitoring, are thoroughly covered to ensure a robust and compliant AML framework for Gamba.com. This policy will be communicated to all stakeholders to ensure transparency and understanding of our AML commitments.