AML Policy of FX Solutions Ltd.

For Deposits and Withdrawals

AML Anti-Money-Laundering policy of fixa.casino

Introduction: the casino fixa.casino is owned and operated by FX Solutions Ltd., registration number: 000053060, registered address: San Victor Street, Orange Walk Town, Belize.

Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on fixa.casino for that a three step account verification is done in order to insure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.

fixa.casino also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

fixa.casino is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of fixa.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

For Deposits and Withdrawals

Money Laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
• 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 from an act of participation in such an activity;
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for fixa.casino:

In accordance with the AML legislation, fixa.casino has appointed the “highest level” for the prevention of ML: The full management of FX Solutions Ltd. 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:

AML policy changes and implementation requirements:

Each major change of fixa.casino AML policy is subject to be approval by the general management of FX Solutions Ltd. and the Anti money laundering compliance officer.

Deposit Wagering Requirement

As part of our Anti-Money Laundering (AML) policy and to ensure the security of financial transactions, fixa.casino applies a deposit wagering requirement (rollover requirement) for all users wishing to withdraw funds from their gaming account.

This requirement is a mandatory condition for fund withdrawals and is designed to prevent the use of the platform for money laundering purposes, as well as to ensure the integrity of the gaming process.

To fulfill the deposit wagering requirement, you must place bets equal to or exceeding the amount of the deposited funds. Different game categories are counted differently in meeting the wagering requirement:

• Slot games: 100% of the bet amount
• Live casino games: 10% of the bet amount
• Fixa games (proprietary games): 10% of the bet amount

Some games may have an individual wagering percentage that may differ from standard values. Current information about the wagering percentage for a specific game is displayed in the game description or in the bonus program rules.

The deposit wagering requirement applies to all deposits made to the gaming account, regardless of the deposit method (bank transfer, cryptocurrency, e-wallets, etc.). The remaining amount that needs to be wagered is displayed in the withdrawal modal and is updated in real-time as bets are placed.

Source of funds

If a player deposits over a five thousand euro there is a process of understandings the source of wealth (SOW)

• Ownership of business
• Employment
• Inheritance
• Investment
• Family

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or prove.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and an information on the website itself.

fixa.casino also asks for a bank wire/credit card to further insure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

Additional measurements.

In addition, an AI which is overseen by the AML compliance officer will look for any unusual behaviour and report it right away to a employee of fixa.casino.

According to a risk based few and general experience the human employees will recheck all checks which are done before by the AI or other employees and may redo or do additional checks according to the situation...

In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behaviour like: Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account to for Deposit and Withdraw, nationality changes, currency changes, behaviour and activity changes as well as checks, if an account is used by it´s original owner.

Also 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

As part of its risk-based approach, fixa.casino has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to fixa.casino...

The identification of AML risk categories is based on fixa.casino understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.

The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile...

1) The first Line of Control:

fixa.casino works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto fixa.casino from taking place without proper execution of KYC procedures onto the potential customer.

2) The second Line of Control:

fixa.casino makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include...

Also, the three-step verification with adjusted risk management should provide all necessary information’s about all costumers of fixa.casino at all time.

Also, all transaction must be overseen by employees over watched by the AML compliance officer who is over watched by the general management.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.

These checks will be done by an automated System, while an Employee crosschecks them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).

Any fixa.casino staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.

3) The third Line of Control:

As a last line of defence against AML fixa.casino will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.

If fraud or Money Laundering is found the authorities will be informed.

Reporting of Suspicious transactions on fixa.casino

In its internal procedures, fixa.casino describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, 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;
• will decide whether or not it is necessary to terminate the business relations with the customer.

Procedures

The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of fixa.casino.

Record keeping

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

These data will be safely, encrypted stored offline and online.

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security:

All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.

fixa.casino will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

Contact us:

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

By email: [email protected]