Anti-Money Laundering Policy - version 2.0

ZWEELER’s primary goal is to facilitate people in having fun and compete in the sports they love. It is for that reason that ZWEELER will happily support anyone legally allowed to join/compete as long as FUN IS AND STAYS THE GOAL! The opposite is also true; IF ANYTHING ELSE BUT FUN becomes the goal of the player, ZWEELER will do everything within its power to protect, educate and assist the individual that has misunderstood the means of ZWEELER'S existence.
To prevent situations in which ZWEELER is (attempted to be) used for other means than FUN, The following guidelines are in place:

COMPLIANCE

ZWEELER is licensed and regulated by the Malta Gaming Authority (MGA) to offer remote (on-line) betting games over the internet, under the Remote Gaming Regulations, 2004. Under the licence conditions issued by the MGA, ZWEELER is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity. ZWEELER is therefore obliged to follow the provisions contained in the Maltese legal framework namely the Prevention of Money Laundering Act (Chapter 373 of the laws of Malta ), the Prevention of Money Laundering and Funding of Terrorism Regulations, 2008 (Legal Notice 188 of 31st July 2008 of the laws of Malta) and any guidance notes issued by the relevant Authorities.

COMMITMENT

ZWEELER is fully committed to:

  • Protect, at all times, the organization and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities;
  • Be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risk such as the risks to its reputation, legal risk and regulatory risk;
  • The social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes;
  • To remain updated with developments both at national and international on any initiatives to prevent money laundering and the financing of terrorism;

OPERATIONAL MEASURES

In order to prevent Money laundering and Terrorist Financing to occur, ZWEELER,

  • Appointed one of its senior officers as the designated Money Laundering Reporting Officer (MLRO) whose responsibilities include the duties required by the laws regulations and guidance notes;
  • Has taken reasonable steps to establish the identity of any person for whom it is proposed to provide its service. For this purpose the process for the registration of Players provided for under the General Terms and Conditions provides for the due diligence process that must be carried out before the opening of a User Account;
  • Retains a secure list of all registered Players;
  • Retains identification and transactional documentation as defined in the laws regulations and guidance notes;
  • Provides initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions;
  • Ensures that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities;
  • Examines with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism;
  • Report any suspicion or knowledge of money laundering of terrorism financing to the MGA and, if need be to the Financial Intelligence Analysis Unit (FIAU) set up by law as a Malta Government Agency responsible for the collection, collation, processing, analysis and dissemination of information with a view to prevent money laundering and combat the funding of terrorism.
  • Co-operate with all relevant administrative, enforcement and judicial authorities in their endeavor to prevent and detect criminal activity;
  • Not accept to open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known;
  • Not accept cash from Players. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method approved by the MGA;
  • Not register a Player who is under eighteen (18) years of age;
  • Only register a single account in the name of a particular person: multi-account practices are strictly prohibited;
  • Transfer payments of winnings Payouts above the 250 euro must be done to the same destination as the source of the funds.
  • Not accept a wager unless a User Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager.
  • Full identification of Person in the case of deposits exceeding 2,000 EURO cumulatively within a period of 180 days.
  • Where it deems necessary, verify creditworthiness of the Player with third parties who previously provided any information on the Player; and
  • if it becomes aware that a person has provided false information when providing due diligence documents, not register such person. Where that person has already been registered, ZWEELER shall immediately cancel that person’s registration as a Player with the company.