AML policy

1.1 Objective

Ultima Poker is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimise and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

Ultima Poker will endeavour to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organisation and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.

1.2 Obligations

In order to adhere to obligations relating to the of money laundering Ultima Poker shall as a minimum:

  • appoint one of its senior officers as the designated Money Laundering Reporting Officer (MLRO) whose responsibilities will include the duties required by applicable laws, regulations and guidance notes.
  • take reasonable steps to establish the identity of any person for whom it is proposed to provide its service. For this purpose the process for the registration of Players provided for under the General Terms and Conditions provides for the due diligence process that must be carried out before the opening of a User Account.
  • keep at all times a secure online list of all registered Players.
  • retain identification and transactional documentation as defined in the laws regulations and guidance notes.
  • provide initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions.
  • ensure that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities.
  • examine with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.
  • report any suspicion or knowledge of money laundering of terrorism financing to the relevant authority (if applicable) responsible for the collection, collation, processing, analysis and dissemination of information with a view to prevent money laundering and combat the funding of terrorism.
  • cooperate with all relevant administrative, enforcement and judicial authorities in their endeavour to prevent and detect criminal activity.

Moreover, Ultima Poker shall:

  • not accept to open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known.
  • not accept cash from Players. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques
  • not register a Player who is under eighteen (18) years of age.
  • only register a single account in the name of a particular person: multi-account practices are strictly prohibited.
  • transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.
  • not accept a wager unless a User Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager.
  • not accept a wager unless the funds necessary to cover the amount of the wager are provided in an approved way.
  • not accept Players residing or playing from non-reputable jurisdictions.
  • not make a payment in excess of two thousand three hundred Euro (€ 2,300) out of a User Account to a Player until the Player's identity, age and place of residence have been verified.
  • if no transaction has been recorded on a User Account for thirty months, close the User Account and remit the balance in that account to the Player, or if the Player cannot be satisfactorily located, to the relevant regulatory authority (where this requirement exists).
  • where it deems necessary, verify creditworthiness of the Player with third parties who previously provided any information on the Player.
  • if it becomes aware that a person has provided false information when providing due diligence documents, not register such person. Where that person has already been registered, Ultima Poker shall immediately cancel that person's registration as a Player with the company.

1.3 Monitoring and verification

Any detection of violation of the rules as set put in chapter 3 of this document is to be reported immediately to the MLRO.

Even though the gaming system is set up so that not more than one player account per player can be opened and limits are set in place for deposits and payouts, the MLRO is also responsible for detecting excessive playing behaviour, excessive number of registrations and attempts of payout on different accounts by players. In case of detection of such behaviour, the MLRO's task is to investigate any possible detection. In case of violation of the rules, the MLRO must request a (temporary) closure of the player's account and report this issue to the relevant regulatory authority, where applicable.

1.4 Reporting

Ultima Poker will have a documented process in place for all employees to report when they have suspicions that a player, or players may be engaged in money laundering to the money laundering reporting officer (MLRO) or in his absence, the Deputy MLRO.

The MLRO, must consider each report made to determine whether it gives rise to grounds for knowledge or suspicion. Where such suspicion is determined, a suspicious transaction report will be sent in compliance with the gambling licence issuing authority (where such requirement exists in terms of relevant law and/or regulatory policy). Attention will need to be given to any applicable reporting timetables.