Anti-Money Laundering Policy

1. Introduction

CELESTIA is committed to maintaining the highest standards of integrity in all its business dealings and has a zero-tolerance approach to money laundering and terrorist financing. We are dedicated to preventing our platform from being used for illegal activities and ensuring compliance with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations.

This policy outlines our approach to detecting, preventing, and reporting money laundering and terrorist financing activities. By using our services, you acknowledge and agree to comply with this policy.

2. Regulatory Compliance

CELESTIA operates under a gaming license issued by the Government of Curacao and complies with all applicable AML/CTF laws and regulations, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations
• Curacao's National Ordinance on the Reporting of Unusual Transactions
• The EU 5th Anti-Money Laundering Directive
• International standards on combating money laundering and the financing of terrorism

We regularly review and update our policies and procedures to ensure ongoing compliance with evolving regulatory requirements.

3. Know Your Customer (KYC) Procedures

We implement robust Know Your Customer (KYC) procedures to verify the identity of our users and assess the potential risks associated with their accounts. Our KYC process includes:

3.1 Identity Verification

All users are required to provide accurate personal information during the registration process, including full name, date of birth, address, and contact details. We verify this information through reliable and independent sources.

Depending on various risk factors, such as deposit amounts, playing patterns, or geographical location, we may require additional verification documents, including:

• Government-issued identification document (passport, driver's license, national ID card)
• Proof of address (utility bill, bank statement, government correspondence)
• Proof of payment method ownership (bank statement, credit/debit card)
• Source of funds declaration and supporting documentation

3.2 Ongoing Due Diligence

We conduct ongoing monitoring of user accounts and transactions to identify unusual or suspicious activities. This includes:

• Monitoring transaction patterns and playing behavior
• Periodic review of user information and verification documents
• Re-verification when there are material changes in a user's profile or activity
• Enhanced due diligence for high-risk customers or transactions

3.3 Risk-Based Approach

We apply a risk-based approach to our KYC procedures, allocating resources according to the level of risk presented by users, transactions, or geographical locations. Higher-risk situations are subject to enhanced due diligence measures.

4. Transaction Monitoring

We have implemented advanced systems and procedures to monitor transactions for suspicious activities. Our transaction monitoring includes:

• Automated monitoring of deposits, withdrawals, and transfers
• Detection of unusual transaction patterns or behaviors
• Identification of transactions that appear to be structured to avoid reporting thresholds
• Monitoring of transactions involving high-risk countries or regions
• Review of significant changes in transaction volumes or patterns
• Detection of minimal gaming activity compared to the volume of deposits and withdrawals

Any suspicious transactions identified through our monitoring systems are subject to further investigation and, if appropriate, reported to the relevant authorities.

5. Red Flag Indicators

We pay particular attention to the following red flag indicators that may suggest money laundering or terrorist financing activities:

• Multiple accounts registered under similar details or from the same IP address
• Large or unusual deposit patterns not consistent with the user's profile
• Minimal gaming activity followed by withdrawals
• Attempts to circumvent our KYC or transaction monitoring procedures
• Use of multiple payment methods without apparent reason
• Transfers between accounts with no clear legitimate purpose
• Users from high-risk jurisdictions or sanctioned countries
• Unusual source of funds with inadequate explanation
• Third-party deposits or withdrawals
• Reluctance to provide required documentation or information

The presence of one or more of these indicators does not necessarily mean that a user is engaged in money laundering or terrorist financing, but they prompt further investigation by our AML compliance team.

6. Reporting of Suspicious Activities

We have established clear procedures for reporting suspicious activities to the appropriate authorities. Our reporting process includes:

• Internal reporting channels for staff to report suspicious activities
• Timely investigation of all reported suspicions
• Filing of Suspicious Activity Reports (SARs) with the relevant Financial Intelligence Unit (FIU) when appropriate
• Cooperation with law enforcement and regulatory authorities in their investigations
• Maintaining records of all reports and investigations

We follow a "no-tipping-off" policy, meaning that we do not inform users that they are subject to suspicious activity reporting or investigation.

7. Record Keeping

We maintain comprehensive records of all customer identification data, transactions, and any investigations conducted. These records include:

• Customer identification and verification documents
• Transaction records, including date, amount, and type
• Account information and activity logs
• Records of investigations and suspicious activity reports
• AML training records for staff

All records are kept for a minimum of five years from the end of the business relationship or transaction, in accordance with regulatory requirements.

We ensure that all records are maintained securely and with appropriate confidentiality, while still being readily available to appropriate authorities upon request.

8. Staff Training and Awareness

We provide comprehensive AML/CTF training to all relevant staff members to ensure they understand their responsibilities in preventing money laundering and terrorist financing. Our training program includes:

• Understanding of AML/CTF laws, regulations, and standards
• Recognition of suspicious activities and red flag indicators
• Customer due diligence and enhanced due diligence procedures
• Internal reporting procedures for suspicious activities
• Record-keeping requirements
• Consequences of non-compliance

Training is provided upon hiring and periodically thereafter, with additional training when there are significant changes to AML/CTF laws, regulations, or our internal policies.

9. Sanctions Compliance

We are committed to complying with all applicable economic and trade sanctions. We:

• Screen customers against relevant sanctions lists at onboarding and regularly thereafter
• Block transactions to or from sanctioned individuals, entities, or countries
• Monitor and update our sanctions screening procedures to reflect changes in sanctions regimes
• Provide training to staff on sanctions compliance

We do not establish or maintain business relationships with individuals or entities named on applicable sanctions lists or located in comprehensively sanctioned countries or regions.

10. User Cooperation

As a user of our services, you agree to:

• Provide accurate and truthful information during the registration process
• Submit any required verification documents promptly when requested
• Update your personal information if there are any changes
• Comply with our AML/CTF policies and procedures
• Use our services only for legitimate gambling purposes and not for money laundering or terrorist financing
• Not attempt to circumvent our verification or monitoring processes

Failure to comply with these requirements may result in restrictions on your account, including temporary or permanent closure and potential reporting to relevant authorities.