This Money Laundering and Terrorist Financing Prevention (AML/CFT) Policy aims to prevent, detect and mitigate the risks of the SIETE platform being used for illicit activities.
This policy applies to all customers, operations, transactions and collaborators linked to the operation of the SIETE brand.
Employees and contractors are subject to this policy and:
This policy is applied to all activities, services, products, and workplaces of the company.
This policy applies to all customers, operations, transactions and collaborators linked to the operation of the SIETE brand.
Employees and contractors are subject to this policy and:
- a)Are required to read and follow the AML policy;
- b)Are required to attend regular AML training programs if their position is designated by this policy as requiring such;
- c)Should avoid drawing conclusions about customers and their activities based solely on the customer’s ethnicity or national origin;
- d)Must report any suspicious activity to the Money Laundering Reporting Officer (MLRO);
- e)All employees and contractors are prohibited from informing customers and other employees or contractors that their activities have been, may be or will be reported as suspicious or under investigation.
This policy is applied to all activities, services, products, and workplaces of the company.
SIETE assesses the risks of AML considering, among other factors:
- Transactional profile of the customer.
- Volume, frequency, and patterns of deposits and withdrawals.
- Payment methods used.
- Gaming behavior and use of the platform.
- Jurisdiction of residence or connection of the customer.
Based on this analysis, the probability and impact of the risk is evaluated, customers may be classified as low, medium or high risk, applying monitoring measures according to said classification.
- Transactional profile of the customer.
- Volume, frequency, and patterns of deposits and withdrawals.
- Payment methods used.
- Gaming behavior and use of the platform.
- Jurisdiction of residence or connection of the customer.
Based on this analysis, the probability and impact of the risk is evaluated, customers may be classified as low, medium or high risk, applying monitoring measures according to said classification.
SIETE implements Know Your Customer procedures to verify the identity of users, being a prerequisite to enable withdrawals. For verification purposes, reasonable or appropriate measures will be taken to review all this information, together with the documentation provided by the client, and, if required, SIETE may request additional information and documentation to verify the veracity and authenticity of the information and documentation provided by the client.
It is important to note that the company follows responsible gaming standards and offers its products only to individuals aged 18 and over, in accordance with its Terms and Conditions. Minors are not allowed to register as players or hold a SIETE account.
SIETE reserves the right to request documents and perform additional checks in order to verify the information provided. A SIETE account may be suspended until satisfactory proof of age is provided.
3.1. Enhanced Due Diligence (EDD)
Enhanced Due Diligence (EDD) is generally applied to players who present a medium-high or high risk to the Operator and relevant Authorities. Red flags may include:
The purpose of EDD documentation is to verify the source of funds and the source of wealth of the end-user.
It is important to note that the company follows responsible gaming standards and offers its products only to individuals aged 18 and over, in accordance with its Terms and Conditions. Minors are not allowed to register as players or hold a SIETE account.
SIETE reserves the right to request documents and perform additional checks in order to verify the information provided. A SIETE account may be suspended until satisfactory proof of age is provided.
3.1. Enhanced Due Diligence (EDD)
Enhanced Due Diligence (EDD) is generally applied to players who present a medium-high or high risk to the Operator and relevant Authorities. Red flags may include:
- High level of deposits;
- High wagering activity;
- Use of multiple prepaid payment methods on the same account;
- The end-user originates from a high-risk country;
- High-net-worth individuals;
- The end-user is identified as a Politically Exposed Person (PEP), among others.
The purpose of EDD documentation is to verify the source of funds and the source of wealth of the end-user.
Transactions are monitored by SIETE on an ongoing basis in order to timely detect unusual, atypical or inconsistent operations with the client's profile, expected behavior and usual activity, allowing the identification of potential risks in terms of money laundering and terrorist financing in order to adopt the corresponding analysis, control and mitigation measures in a timely manner.
Upon detection of warning signs, SIETE will be able to:
- Request additional information or documentation.
- Temporarily restrict operations.
- Suspend or close the customer's account.
- Report the case internally for analysis.
- Report player and its activity to regulator or other authorised body regarding Money Laundering.
Upon detection of warning signs, SIETE will be able to:
- Request additional information or documentation.
- Temporarily restrict operations.
- Suspend or close the customer's account.
- Report the case internally for analysis.
- Report player and its activity to regulator or other authorised body regarding Money Laundering.
When an operation is detected that presents characteristics of suspicion, it must be analysed in accordance with the established internal procedures, in order to determine whether it has a sufficient economic or legal justification. Transactions related to assets of possible illicit origin are also considered suspicious, even when they do not materialize.
If, after such review, reasonable doubts persist as to its origin, purpose or consistency with the customer profile, the transaction shall be classified as suspicious and appropriate measures shall be taken.
Upon detection of warning signs, SIETE will be able to:
- Request additional information
- Restrict operations or close accounts.
- Report the case internally for analysis and externally if needed
5.1. Tipping off
It is a criminal offence for an employee or contractor to disclose information to any third party, including customers or colleagues, once an internal or external report of suspicious activity has been made.
This means that no employee of SIETE may, under any circumstances, inform players that their account is under review due to the filing of an internal Suspicious Activity Report (SAR).
If, after such review, reasonable doubts persist as to its origin, purpose or consistency with the customer profile, the transaction shall be classified as suspicious and appropriate measures shall be taken.
Upon detection of warning signs, SIETE will be able to:
- Request additional information
- Restrict operations or close accounts.
- Report the case internally for analysis and externally if needed
5.1. Tipping off
It is a criminal offence for an employee or contractor to disclose information to any third party, including customers or colleagues, once an internal or external report of suspicious activity has been made.
This means that no employee of SIETE may, under any circumstances, inform players that their account is under review due to the filing of an internal Suspicious Activity Report (SAR).
Within the framework of the system for the prevention of money laundering and terrorist financing (AML/CFT), the following actions are expressly prohibited, as they do not comply with the controls and principles established in this area, and consequently may not be carried out:
- Anonymous accounts.
- Payments or withdrawals to third parties.
- Operations from sanctioned or non-cooperative jurisdictions.
- Use the platform for transfers between users.
- Anonymous accounts.
- Payments or withdrawals to third parties.
- Operations from sanctioned or non-cooperative jurisdictions.
- Use the platform for transfers between users.
The Client represents and guarantees that all funds, resources and assets used come exclusively from lawful sources, have been obtained in accordance with applicable legislation and are not related, directly or indirectly, to illicit activities, including, but not limited to, money laundering and terrorist financing. Likewise, the Client will provide sufficient information and documentation to verify the lawful origin of such funds, when reasonably required.
Politically Exposed Persons (PEPs) are defined as individuals who are or have been entrusted with prominent public functions in a foreign country, for example Head of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials.
Business relationships with family members or close associates of PEPs involve reputational risks similar to those with PEPs themselves. This definition is not intended to cover middle ranking or more junior individuals in the foregoing categories.
Siete will evaluate the PEP risk based on:
- Politically exposed person’s nationality or country of origin. Risks are higher in countries where corruption is widespread. Please refer to the Country Risk Rating Policy.
- Person’s position, authority and powers. The higher the rank or influence, the higher the risk of involvement in money laundering.
- Business relationships volume and complexity. The size and structure of financial operations indicate higher levels of risk.
- Types of products or services offered. Certain services, such as private banking, imply a higher level of risk.
- Foreign parties dealt with. Use of offshore companies, shell entities, or banks in jurisdictions with bank secrecy or weak AML standards increases risk.
Siete checks all players' status upon account creation. If a High/Low risk PEP is identified, additional documentation may be required along with MLRO approval.
No business relationships will be established with sanctioned individuals or entities.
Business relationships with family members or close associates of PEPs involve reputational risks similar to those with PEPs themselves. This definition is not intended to cover middle ranking or more junior individuals in the foregoing categories.
Siete will evaluate the PEP risk based on:
- Politically exposed person’s nationality or country of origin. Risks are higher in countries where corruption is widespread. Please refer to the Country Risk Rating Policy.
- Person’s position, authority and powers. The higher the rank or influence, the higher the risk of involvement in money laundering.
- Business relationships volume and complexity. The size and structure of financial operations indicate higher levels of risk.
- Types of products or services offered. Certain services, such as private banking, imply a higher level of risk.
- Foreign parties dealt with. Use of offshore companies, shell entities, or banks in jurisdictions with bank secrecy or weak AML standards increases risk.
Siete checks all players' status upon account creation. If a High/Low risk PEP is identified, additional documentation may be required along with MLRO approval.
No business relationships will be established with sanctioned individuals or entities.
Terrorism Financing is the process of making funds or other assets available, directly or indirectly, to terrorist groups or individual terrorists to support their operations. This may originate from legitimate sources or from a combination of lawful and unlawful sources. A key difference between terrorism financing and money laundering is that, while money laundering focuses on concealing the origin of funds, terrorism financing focuses on concealing the final destination of the funds.
Another difference is that, while the money launderer seeks to disguise the link between the crime and the funds generated, the terrorist’s ultimate objective is to obtain resources to support terrorist activities.
Although funds may originate from legitimate sources, there is often a need to disguise the link between the terrorist or organisation and those sources. While Money Laundering is concerned with hiding the source of funds, Terrorism Financing is primarily concerned with hiding the end recipient.
Terrorism financing typically occurs in four stages:
- Raising of funds: This may involve legitimate sources (e.g. donations, business income, salaries) or illegitimate sources (e.g. ransom, smuggling, sale of stolen goods, drug trafficking).
- Movement of funds: Use of channels that may be misused to transfer funds internationally.
- Storage of funds: Includes holding funds securely; gambling accounts may be used to avoid scrutiny or additional checks.
- Use of funds: Funds may be used for terrorist acts, preparation activities (e.g. training, travel, propaganda), or operational expenses.
Suspicious activity may be detected through customer due diligence and ongoing transaction monitoring.
If an employee suspects, or has reasonable grounds to suspect, that a transaction may be linked to terrorism financing, whether directly or indirectly, it must be reported to the MLRO.
Accounts associated with sanctioned individuals will be closed.
Another difference is that, while the money launderer seeks to disguise the link between the crime and the funds generated, the terrorist’s ultimate objective is to obtain resources to support terrorist activities.
Although funds may originate from legitimate sources, there is often a need to disguise the link between the terrorist or organisation and those sources. While Money Laundering is concerned with hiding the source of funds, Terrorism Financing is primarily concerned with hiding the end recipient.
Terrorism financing typically occurs in four stages:
- Raising of funds: This may involve legitimate sources (e.g. donations, business income, salaries) or illegitimate sources (e.g. ransom, smuggling, sale of stolen goods, drug trafficking).
- Movement of funds: Use of channels that may be misused to transfer funds internationally.
- Storage of funds: Includes holding funds securely; gambling accounts may be used to avoid scrutiny or additional checks.
- Use of funds: Funds may be used for terrorist acts, preparation activities (e.g. training, travel, propaganda), or operational expenses.
Suspicious activity may be detected through customer due diligence and ongoing transaction monitoring.
If an employee suspects, or has reasonable grounds to suspect, that a transaction may be linked to terrorism financing, whether directly or indirectly, it must be reported to the MLRO.
Accounts associated with sanctioned individuals will be closed.
A Money Laundering Reporting Officer (MLRO) is responsible for receiving, investigating and assessing internal suspicious transaction reports within the company. Staff must record and report all suspicious transactions related to deposits and withdrawals to the MLRO, providing full details.
Any internal Suspicious Transaction/Activity Report (STR/SAR) is examined and analysed by the MLRO, who will:
- Document the report appropriately and acknowledge receipt of internal reports from employees or officers;
- Analyse the report considering all relevant available evidence to determine whether there are reasonable grounds for knowledge or suspicion of money laundering or terrorist financing;
- Report to law enforcement authorities when there are reasonable grounds to suspect that funds are proceeds of criminal activity;
- Take all necessary measures to safeguard the confidentiality of the information;
- Advise employees to prevent tipping off.
The MLRO oversees the day-to-day operations related to AML/TF policies and is responsible for responding promptly to any reasonable request for information from law enforcement authorities.
Any internal Suspicious Transaction/Activity Report (STR/SAR) is examined and analysed by the MLRO, who will:
- Document the report appropriately and acknowledge receipt of internal reports from employees or officers;
- Analyse the report considering all relevant available evidence to determine whether there are reasonable grounds for knowledge or suspicion of money laundering or terrorist financing;
- Report to law enforcement authorities when there are reasonable grounds to suspect that funds are proceeds of criminal activity;
- Take all necessary measures to safeguard the confidentiality of the information;
- Advise employees to prevent tipping off.
The MLRO oversees the day-to-day operations related to AML/TF policies and is responsible for responding promptly to any reasonable request for information from law enforcement authorities.
Information related to customers and transactions will be kept for a minimum period of five (5) years, or for a longer period if required by applicable contractual or regulatory obligations.
The preservation of customer information and documentation, as well as their transactions, is necessary to support monitoring and analysis processes, comply with the requirements of competent authorities, and enable the implementation of internal control measures, risk mitigation, and operational protection.
The preservation of customer information and documentation, as well as their transactions, is necessary to support monitoring and analysis processes, comply with the requirements of competent authorities, and enable the implementation of internal control measures, risk mitigation, and operational protection.
Internal AML-related investigations are confidential. SIETE will not inform customers about analyses, blockages or reports derived from prevention controls
SIETE reserves the right to adopt, at any time, all measures it deems necessary to protect the integrity of its operation and compliance with its obligations in the area of prevention of money laundering and terrorist financing, including, but not limited to, the suspension or blocking of funds, the cancellation or reversal of transactions and the temporary or permanent closure of accounts. where there are sufficient indications of AML/CFT risk or where it is not possible to adequately mitigate such risk. These measures may be adopted without liability for SIETE and in accordance with its internal policies and applicable regulations.
This policy is part of the SIETE Terms and Conditions, which you agree to by creating an account and using the Platform.
This Policy should be read in conjunction with the Terms and Conditions and any additional applicable terms posted on the SIETE platform. Siete may make changes to this Policy from time to time and will be notified by posting the amended terms on the platform. It will be understood that the user accepts the new Policy by logging in to his/her account. SIETE recommends that you review this Policy regularly.
This Policy should be read in conjunction with the Terms and Conditions and any additional applicable terms posted on the SIETE platform. Siete may make changes to this Policy from time to time and will be notified by posting the amended terms on the platform. It will be understood that the user accepts the new Policy by logging in to his/her account. SIETE recommends that you review this Policy regularly.