🔍 AML & KYC Policy

Introduction and Purpose

GoldGlimpse Limited, operating Khel Karo Casino, maintains strict compliance with anti-money laundering regulations and know-your-customer requirements under our Anjouan gaming license.

Policy Objectives

• Prevent money laundering and terrorist financing
• Verify the identity of all customers
• Monitor and report suspicious activities
• Maintain comprehensive records for regulatory compliance
• Protect the integrity of the gaming industry
• Comply with international AML/CFT standards

Know Your Customer (KYC) Procedures

Customer Identification Requirements

All players must provide valid identification documents to verify their identity, age, and address. This process helps us ensure:

• Players are of legal gambling age (18+)
• Identity documents are authentic and current
• Residential address can be verified
• Source of funds is legitimate
• No connection to prohibited activities

Required Documents

Enhanced Due Diligence (EDD)

High-Risk Customer Categories

Additional verification measures apply to customers who fall into high-risk categories:

Additional Requirements for Enhanced Due Diligence

• Source of Wealth: Documentation proving the origin of large funds
• Source of Funds: Evidence of how specific deposits were funded
• Purpose of Relationship: Explanation of intended gaming activities
• Ongoing Monitoring: Regular review of account activity
• Senior Management Approval: High-risk accounts require additional authorization

Transaction Monitoring

Automated Monitoring Systems

We employ sophisticated monitoring systems to detect suspicious activities:

• Real-time transaction analysis
• Pattern recognition algorithms
• Threshold-based alerts
• Behavioral analysis
• Cross-referencing with sanctions lists

Red Flags and Suspicious Activity Indicators

Reporting Thresholds

• ₹200,000: Single transaction reporting threshold
• ₹500,000: Cumulative daily transaction reporting
• Any Amount: Suspicious activity regardless of value
• Cash Equivalents: Cryptocurrency and digital asset transactions

Sanctions Compliance

Sanctions Screening

We maintain comprehensive sanctions screening procedures:

• Real-time screening against international sanctions lists
• Regular updates from regulatory authorities
• Automated blocking of prohibited transactions
• Manual review of potential matches

Prohibited Countries and Entities

• FATF Blacklist: Countries with strategic AML/CFT deficiencies
• UN Sanctions: United Nations Security Council sanctions
• OFAC List: US Office of Foreign Assets Control
• EU Sanctions: European Union restrictive measures
• National Lists: Country-specific sanctions programs

Record Keeping

Document Retention Policy

We maintain comprehensive records in accordance with regulatory requirements:

Data Security Measures

• 256-bit encryption for all stored documents
• Access controls with audit trails
• Regular security assessments
• Backup and disaster recovery procedures
• Compliance with data protection regulations

Reporting Procedures

Suspicious Activity Reporting (SAR)

When suspicious activity is identified, we follow established reporting procedures:

1. Detection: Automated systems or manual identification
2. Investigation: Internal review and analysis
3. Documentation: Detailed report preparation
4. Filing: Submission to relevant authorities within required timeframes
5. Follow-up: Ongoing monitoring and cooperation with authorities

Regulatory Reporting Timeframes

• Immediate: Terrorist financing or serious criminal activity
• 24 Hours: Threshold transactions and suspicious activities
• Monthly: Regular compliance reporting to gaming authorities
• Annually: Comprehensive AML program assessment

Staff Training and Awareness

AML Training Program

All staff members receive comprehensive training on:

• AML/CFT laws and regulations
• Customer identification procedures
• Suspicious activity recognition
• Reporting requirements and procedures
• Sanctions compliance
• Record keeping obligations

Training Schedule

• Initial Training: All new employees before handling customer accounts
• Annual Refresher: Mandatory yearly updates for all staff
• Specialized Training: Additional training for high-risk roles
• Ad-hoc Updates: Training on new regulations or procedures

Customer Rights and Obligations

Customer Rights

• Right to privacy and data protection
• Right to explanation of verification requirements
• Right to appeal verification decisions
• Right to access personal data held
• Right to correction of inaccurate information

Customer Obligations

• Provide accurate and complete information
• Submit required documentation promptly
• Notify us of changes to personal information
• Cooperate with verification procedures
• Use legitimate sources of funds
• Report suspicious activities to our attention

Contact Information and Support

AML Compliance Department

For questions or concerns related to AML/KYC procedures:

Escalation Process

1. Contact customer support for routine verification questions
2. Email compliance team for complex AML/KYC matters
3. Request supervisory review for disputed decisions
4. Contact our AML Officer for serious compliance concerns