AML Policy of Curacao Co N.V.

Last updated: 20.01.2022

Shazam Casino is operated by Alistair Solutions N.V.

We seek to provide the best level of security to all of our users and customers on Shazam Casino thus a three-step account verification process is used to ensure our customers' identities. The purpose of this is to provide a broad framework for the fight against money laundering by demonstrating that the data of the person enrolled are true and that the deposit methods utilized are not stolen or being used by someone else. We also agree that appropriate safety measures must be applied based on country and origin while making payments and withdrawing money.

Shazam Casino also takes reasonable steps to minimize and mitigate ML risk, by allocating enough resources.

Shazam Casino is committed to maintaining strong anti-money laundering (AML) standards according to EU legislation, and requires management and workers to enforce these standards in order to avoid the exploitation of its services for money laundering purposes.

The AML program of Shazam Casino is designed to be compliant with:

EU : "Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering"

EU : "Regulation 2015/847 on information accompanying transfers of funds"

EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE : Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash

Any information provided by a user or client will be kept private and will not be sold or distributed to anyone else. Data may only be provided with the AML-authority of the concerned jurisdiction if required by law or to prevent money laundering.

Shazam Casino will adhere to all of the data protection directive's principles and requirements (formally Directive 95/46/EC).

In accordance with the AML legislation, Shazam Casino has appointed the "highest level" for the prevention of ML: The full management of Alistair Solutions N.V.are in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general Management.

Every substantial update to the AML policy at Shazam Casino must be approved by the general management of Alistair Solutions N.V. as well as the anti-money laundering compliance officer.

Every user and customer must do step one verification to withdraw. Step one verification is required for the method of payment, the amount of payment, the withdrawal amount, method, and the nationality of the user/customer. The first step of verification is a document that must be completed by the user/customer. The first name, second name, date of birth, country of customary residence, gender, and full address must all be filled in.

Step two verification must be done by every user who deposits over 2000$ (two thousand Dollar) or withdraws over 2000$ (two thousand Dollar). The withdrawal, tip, or deposit will be held until step two verification is completed. The user or client will be sent to a subpage where he must submit his identification. The user/customer must photograph his ID. Only an official ID may be used for ID verification, and the types of IDs permitted vary depending on the nation. An electronic check will also be done to see if the data entered during the first verification stage is valid. The electronic check will check via different databanks to ensure the given information matches with the filled document and the name from the ID: If the electronic test fails or is not possible, the user/customer is required to send in a confirmation of his current residence. A government-issued certificate of registration or a comparable document is necessary.

Step three verification must be done by every user who deposits over $5000 (five thousand Dollar) or withdraws over $5000 (five thousand Dollar. A user/customer will be asked for a source of wealth.

KYC Identification Verification:

1. Copy of a valid photo ID (driver's license, ID, passport). The copy should be a high-quality colored image scan or colored digital photo. The copy must not be cropped and should also include both sides and all details of the ID.
2. Copy of any credit/debit cards successfully used. The copy should be a high-quality colored image scan or colored digital photo. The copy must not be cropped and should include the cardholder's full name, the first 6 and last 4 digits of the card number, and the expiry date.
3. Copy of Utility Bill no older than two months. The copy should be a high-quality colored image scan or colored digital photo. The copy must not be cropped and should include full name, date of issue, full billing address.
4. Card Authentication is required only in case you used your Credit/Debit Card to deposit with the casino.
5. Withdrawal Application with valid banking details aimed to ensure accurate withdrawal cashier.

*Please note that if you want to use another credit/debit card you need to verify it before requesting your next withdrawal. The Casino reserves the right to request additional documentation to verify account information if needed. The Casino reserves the right to deny winnings if any of the documents are missing.

Source of funds If a player deposits more than $5,000, we may ask for the source of wealth, it can be investment, inheritance, employment , ownership of business proof, etc.

It is critical that the origin and legitimacy of that wealth is clearly understood.

AML-Compliance guarantees that "ongoing transaction monitoring" is carried out to discover transactions that are out of the ordinary or suspicious when compared to the customer's profile.

This transaction monitoring is conducted on two levels:

1. Shazam Casino only works with trusted Payment Service Providers who all have effective anti-money laundering policies in place to prevent the vast majority of suspicious deposits onto Shazam Casino from occurring without proper KYC procedures.
2. Shazam Casino informs its network that every communication with a customer, player, or authorized agent must apply due diligence to transactions on the account in question.

All transactions are monitored by personnel under the supervision of the AML compliance officer. In order to properly prevent money laundering, Shazam Casino will conduct manual checks on all suspicious and higher-risk users as a last line of defense against AML. If fraud or Money Laundering is located, the information is going to be passed to authorities.

AML team members analyze reports of atypical transactions using a technique detailed in internal protocols. Depending on the information acquired, the AML team will:

• decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
• decide whether it is necessary or not to terminate the business relations with the customer.

An AI which is overseen by the AML compliance officer will look for any unusual behavior and report it right away to a Shazam Casino employee.

In addition, Shazam Casino employees and a data Scientist, will also check for unusual behavior, such as depositing and withdrawing funds without wagering for prolonged periods of time, attempts to deposit and withdraw money from a different bank account, nationality changes, currency changes, behavior and activity changes, and checks to see if an account is still being used by its original owner.

A User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.

Enterprise-wide risk assessment An AML "Enterprise-wide risk assessment" (EWRA) is held once a year to identify and understand risks specific to Shazam Casino and its business lines: services, customers, transactions, delivery methods used by the bank, geographic locations of the bank's activities, and other emerging risks.

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Shazam Casino website.

All data must be preserved for at least 10 years after the transactions have been completed or the business relationship has ended. The data will be securely stored both offline and online and will be encrypted.

Employees at Shazam Casino will perform manual controls based on a risk-based approval process for which they will receive specific training, according to the Alistair Solutions N.V. AML program:

• A mandatory AML training program in accordance with the latest regulatory evolutions, for employees in touch with finances;
• AML learning sessions for new employees.

The internal audit establishes missions and reports about AML activities on a regular basis.

Please contact us if you have any queries concerning our AML and KYC Policy:

• By email: [email protected]

If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us:

• By email: [email protected]