Sekabet (ZConsulting B.V.)

Anti-Money Laundering (AML) and Counter-Terrorist

Financing (CTF) Policies

1. Standard KYC procedures

As a responsible sportsbook company, Sekabet ensures it is in complete compliance with all applicable industry standards. We focus on enduring relationships with our customers and are proud of our ability to serve each customer according to their specific needs and goals. In addition to building excellent customer relationships, we also comply with relevant anti-money laundering laws in a way that enables us to protect our customers’ assets and provide them first-rate financial services. To balance this compliance and service issue, Sekabet requires a high resolution ID and proof of residence from its customers in case of any withdrawal request (no older than three months).

 

Our standard KYC requirements includes to provide the following:

 

For all customers at the first withdrawal request:

- Passport or ID copy;

- Utility bill less than 3 months (as proof of address);

 

Sekabet can ask its customers to justify certain financial transactions. If you are asked such questions,

you will be expected to provide us relevant contracts, invoices or purchase orders. We reserve the

right to contact the parties associated with such transactions to verify their legitimacy. Sekabet notifies all account debits to the account holders via email. Sometimes, we can also call on the given contact number to verify who is using the account. This necessitates that you notify us in case of a change of contact details.

 

2. AML policy

2.1. Policy and definition

Sekabet enforces a strict anti-money laundering policy with zero tolerance for money laundering activities. We define money laundering as any activity that is carried out in an attempt to misrepresent

the source of funds actually acquired through illegal processes as funds that were acquired through

lawful sources/activities.

 

All Sekabet affiliates are obligated to comply with Sekabet’s anti-money laundering policy and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as

criminal penalties and heavy fines.

 

Sekabet ensures complete compliance with laws pertaining to anti money laundering through its

related policy. At Sekabet, suspicious activities ,such as chip dumping, mirror bets or any kinds of

illegal activity are strictly forbidden. Sekabet will immediately stop any such financial activity as soon

as it is identified because such activities go against the spirit of Sekabet and the principles on which

this company was founded.

 

Sekabet implements a range of filtration operations for swift and accurate identification of any financial

activities that may constitute or are related to money laundering. This helps ensure a money laundering-free financial operations throughout the Sekabet system.

 

All Sekabet customers acknowledge, undertake and agree to the following terms regarding their use of this website, opening and maintenance of accounts at Sekabet and for all financial transactions as a Sekabet customer:

 

1. The customer will comply (throughout the time as a Sekabet customer) with all relevant statutes

pertaining to money laundering and proceeds from criminal activities.

 

2. Sekabet operates under certain obligations known as “know-your-customer” obligations which grant

Sekabet the right to implement anti money laundering procedures to help detect and prevent money

laundering activities where money laundering may mean to handle any funds associated with any

illegal activity regardless of the location of such activity.

 

3. The customer agrees to lend full cooperation to Sekabet with respect to anti money laundering

efforts. This involves providing information that Sekabet requests regarding the customer’s business

details, account usage, financial transactions etc. to help Sekabet perform its duties as dictated by

applicable laws regardless of jurisdiction.

 

4. Sekabet reserves the right to delay or stop any funds transfer if there is reason to believe that

completing such a transaction may result in the violation of any applicable law or is contrary to

acceptable practices.

 

5. Sekabet reserves the right to suspend or terminate any account or freeze the funds in an account if there is reason to believe that the account is being used for activities that are deemed unlawful or

fraudulent.

 

6. Sekabet has the right to use customer information for the investigation and/or prevention of

fraudulent or otherwise illegal activities.

 

2.2. Risk assessment

Sekabet uses its standardized risk rating model to conduct risk assessment related to the exposure to money laundering across all customer relationships. Sekabet Board of Directors approves this model 

once every year.

 

2.3 Activities that Sekabet deems «suspicious»

Activities that Sekabet considers possible indications of money laundering include:

- The customer showing unusual apprehension or reservations about Sekabet’s anti-money laundering

policies.

- The customer having a history of being the subject of news that is indicative of civil or criminal

violations.

- The customer seems to be acting as a ‘front man’ for an unrevealed personality or business, and

does not satisfactorily respond to requests for identifying this personality.

- The customer frequently makes large deposits and demands dealing in cash equivalents only.

- The customer maintains multiple accounts and conducts an unusually high number of inter-account

or 3rd party transactions.

- The customer is a native of, or has accounts in, a country on Financial Action Task Force’slist of

Non-Cooperative Countries or Territories.

- The customer’s previously usually inactive account starts receiving a surge of wire activity.

-Chip dumping and mirror bets

The above list is by no means an exhaustive list; Sekabet monitors its customer and account activity in

light of several other red flags and takes appropriate measures to prevent money laundering.

 

2.4. Customer’s identification procedures

Sekabet utilizes customer identification procedures to validate the true identity of its customers. Documenting and maintaining these identification procedures enhances Sekabet’s ability to prevent

money laundering activities. If Sekabet fails to verify a customer’s identity within an acceptable time

period, all services will be suspended for that customer and any accounts opened will be terminated.

In addition, the account and services attached to that customer will be under stricter scrutiny until the

suspension and/or closure is carried out.

 

IDENTIFICATION PROCEDURES FOR NATURAL PERSONS

Sekabet requires the following information for natural persons:

- Legal and other names used such as maiden name;

- Complete permanent address;

- Telephone number;

- Email address;

- Date and place of birth;

- Nationality;

- Any unique identification number from a valid official document bearing a photograph of the customer

such as ID card, passport or driving license;

 

2.5. Recordkeeping

Sekabet keeps all relevant documents and service records for the minimum time as determined by

applicable law.

 

 

 

 

2.6. Training

Sekabet implements a comprehensive training policy under which it imparts anti-money laundering

training to every new employee. In addition to initial training, Sekabet employees also have to

complete an annual anti-money laundering training program. Moreover, employees involved in anti-money laundering roles are also required to participate in special training programs.

 

As a result of this comprehensive training policy, all Sekabet employees who are tasked with providing

Sekabet’s services and/or deal with customers (directly or indirectly) are fully aware of all applicable

anti-money laundering laws and regulations. All Sekabet employees are therefore in the ideal position

to perform their duties in complete compliance with Sekabet’s AML policy, and with all applicable laws,

statutes and regulations.

 

2.7 Administration

An AML Compliance Officer administers the anti-money laundering policy at Sekabet. The board’s

responsibilities include interpreting, revising and implementing Sekabet’s AML policy.