AML Policy

AML Policy for Combating Money Laundering - ocean-casino.org
For depositing and withdrawing cash funds.

Introduction
The goal of the AML policy at ocean-casino.org is to ensure maximum security for all our users and clients, for which a two-step account verification is conducted to confirm the identity of our clients. The aim is to ensure that the registered person's data is correct and that the deposit methods used are not stolen or used by third parties, thereby creating a common framework for combating money laundering. We also take into account that, depending on citizenship, origin, payment method, and withdrawal method, different security measures may need to be taken.

ocean-casino.org also applies reasonable measures to control and limit money laundering risks, including allocating appropriate resources.

ocean-casino.org is committed to adhering to high anti-money laundering (AML) standards in accordance with EU recommendations and requires management and employees to comply with these standards to prevent our services from being used for money laundering purposes.

AML Program
The AML program at ocean-casino.org is designed in accordance with:

EU: Directive (EU) 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 (EU) 2015/847 on information accompanying transfers of funds.
EU: Various regulations establishing sanctions or restrictive measures against persons and embargoes on certain goods and technologies, including all dual-use items.
Belgium: Law of 18 September 2017 on the prevention of money laundering and the restriction of the use of cash.

Definition of Money Laundering
Money laundering is understood as:

The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person involved in such activity to evade the legal consequences of his actions;
The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or participation in such activity;
The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or participation in such activity;
Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the actions mentioned above.
Money laundering shall be regarded as such even if the activities which generated the property to be laundered were carried out in the territory of another Member State or of a third country.

AML Organization for ocean-casino.org
In accordance with AML legislation, ocean-casino.org has appointed the "highest level" for preventing money laundering: full management bears responsibility.
Furthermore, an AMLCO (AML Compliance Officer) has been appointed, who is responsible for adherence to AML policies and procedures within the system. The AMLCO is under the direct responsibility of general management.

AML Policy Changes and Implementation Requirements
Every major change to the ocean-casino.org AML policy is subject to approval by general management and the AML Compliance Officer.

Two-Step Verification

First Stage Verification: The first stage of verification must be completed by every user and client to withdraw funds. Regardless of the chosen payment method, payment amount, withdrawal amount, withdrawal method, and user/client citizenship, the first stage of verification must be performed first. The first stage of verification consists of a document that must be filled out by the user/client themselves. The following information must be provided: first name, last name, date of birth, country of usual residence, gender, and full address.
Second Stage Verification: The second stage of verification is mandatory for every user who deposits or withdraws an amount exceeding $10,000 USD. Until the second stage of verification is completed, withdrawals, tips, or deposits will be suspended. The second stage of verification directs the user or client to a subpage where they must provide their identification. The user/client must take a photo of their identification, next to which is a piece of paper with a randomly generated six-digit number. Only official identification may be used for identity verification, and the list of acceptable IDs may differ depending on the country. Additionally, the user/client may be asked for their source of income. An electronic check is also conducted to ensure that the data provided in the first stage of verification matches the submitted document and the name on the ID. If the electronic check fails or is impossible, the user/client is obliged to provide proof of their current place of residence. A state-issued registration certificate or similar document is required.

Client Identification and Verification (KYC)
Formal identification of clients when establishing business relationships is an important element for both money laundering-related legislation and KYC policy. This identification is based on the following principles:

A copy of a passport, ID card, or driver's license with a handwritten note containing six randomly generated digits. A second photo featuring the user/client's face is also required.
The user/client may hide any information except date of birth, nationality, gender, first name, last name, and photo to protect their privacy.
All four corners of the ID must be visible in a single image, and all details except those mentioned above must be clearly legible. If necessary, we may request all details. An employee may conduct additional checks if necessary.

Address Confirmation
Address confirmation is carried out through two different electronic checks. If the electronic check fails, the user/client can provide manual confirmation: a utility bill issued within the last 3 months, or an official document confirming residence. All four corners of the document must be visible, and the text clear.

Source of Funds
If a player deposits more than 5,000 EUR, a Source of Wealth (SOW) investigation process is conducted. Examples of income sources: business ownership, employment, inheritance, investments, family. The account will be frozen until the source of funds is confirmed.

Risk Management
To manage various risks, ocean-casino.org classifies each country into three risk regions:

Region 1: Low Risk
Region 2: Medium Risk
Region 3: High Risk — blocked
The list of high-risk regions is updated regularly.

Additional Measures
Artificial intelligence, under the supervision of the AML officer, monitors unusual behavior, and specialists conduct additional checks on transactions, sources of funds, and user activity. Withdrawals must be made using the same method as the deposit.

Continuous Transaction Monitoring

First line of control: collaboration with trusted payment service providers who have effective AML policies.
Second line of control: performing due diligence on all client transactions, including an adapted three-step verification.
Third line of control: manual checks of all suspicious and higher-risk users to prevent money laundering.

Reporting Suspicious Transactions
All atypical transactions are analyzed by the AML team. Based on the analysis, a decision is made on whether to send a report to the FIU and/or terminate the business relationship with the client.

Procedures and Data Retention
All AML rules, including KYC, are recorded in operating manuals. Identification and transaction data are stored for at least ten years after the termination of the business relationship, in encrypted form.

Training and Audit
Employees undergo mandatory AML training and academic sessions. Internal audit conducts regular AML checks.

Data Security
All user/client data is securely protected and not transferred to third parties without legal basis. ocean-casino.org complies with data protection directive 95/46/EC.