Onorio Limited AML Rules

Last Update: 24 February 2025

Version: 1.0

INTRODUCTION

At Onorio Limited, a licensed gaming operator under the Anjouan Gaming License, we follow strict Anti-Money Laundering (AML) and Counter financing of Terrorism (CFT) regulations to ensure a safe and compliant gaming environment for all players.

To protect our platform and our players, we adhere to the following key principles:

Monitoring and screening transactions to detect fraudulent activity and ensure compliance with global financial laws.
Verifying player identities in accordance with Know Your Customer (KYC) regulations.
Preventing money laundering at all stages: placement, layering, and integration.

KEY STAGES OF MONEY LAUNDERING

Money laundering is a process that criminals use to disguise the origins of illegal funds. The process consists of three stages:

Placement – Introducing illicit funds into the financial system;

Layering – Conducting multiple transactions to obscure the source of the funds;

Integration – Returning the laundered funds to the economy as legitimate assets.

In online gaming, placement can occur through deposits, layering through multiple rapid transactions or withdrawals, and integration when illicit funds are cashed out as legitimate winnings.

PLAYER VERIFICATION & SECURITY

To comply with international regulations and prevent illegal financial activities, we require players to complete a verification process (KYC) before making withdrawals or when cumulative deposits exceed $10,000 (or equivalent in other currencies).

What do we require?

1. A valid government-issued photo ID (passport, driver’s license, or national ID card).

2. A recent proof of address (utility bill or bank statement, not older than 6 months).

3. Verification of the payment method used on our platform.

Additional verification may be required based on the player's risk profile, including notarized identity documents or a declaration of source of funds.

For high-risk customers, including politically exposed persons (PEPs), players from FATF-listed high-risk jurisdictions, and customers with complex or unusually large transactions, Enhanced Due Diligence (EDD) measures will be applied.

These measures include, but are not limited to:

Verification of the source of funds (SOF) and source of wealth (SOW).
Collection of additional supporting documents, such as tax returns, employment records, or bank statements.
Enhanced transaction monitoring, including real-time flagging of unusual betting patterns, frequent large withdrawals, or inconsistent transaction behavior.
Periodic reviews of high-risk accounts at shorter intervals to reassess risk levels.
Approval from senior management before establishing or continuing business relationships with high-risk customers.

TRANSACTION MONITORING & REPORTING

To ensure transparency and security, we actively monitor player transactions and gaming behavior. Suspicious activities may be flagged and reported in compliance with Anjouan’s Financial Intelligence Unit (FIU) regulations.

Key reporting requirements:

Self-Exclusion Reports: If a player self-excludes, we must report it to the Gaming Board of Anjouan within 24 hours.

Suspicious Transactions: Any unusual or high-risk transaction is reported to the Gaming Board of Anjouan.

Transactions Over $10,000: Any deposit or withdrawal exceeding this amount is automatically documented and reported.

Transactions involving high-risk jurisdictions or third-party payments may trigger additional verification.

PROHIBITED ACTIVITIES

To maintain a safe gaming environment, we strictly prohibit:

The use of anonymous or shell accounts.

Transactions from high-risk jurisdictions subject to global sanctions.

Large or frequent deposits and withdrawals with no clear gaming activity.

Participation in financial crimes, including fraud, tax evasion, or terrorist financing.

Any attempt to violate AML regulations may result in account suspension, termination, or further legal actions.

HOW WE KEEP YOUR DATA SECURE

We store all personal and financial information in encrypted, tamper-proof systems, complying with regulatory requirements and industry security standards. All AML-related records are retained for at least five (5) years as required by law. Your data is protected against unauthorized access and is only shared with regulatory authorities when legally required.

PLAYER RESPONSIBILITY & COMPLIANCE

As a player, you must ensure that all information provided is accurate and up to date. By registering and using our services, you confirm that:

All funds deposited are legally obtained.

You will comply with all applicable anti-money laundering laws and regulations.

You agree to provide any requested documents within 48 hours upon request.

Failure to comply with verification requests may result in account suspension or closure.

MANAGEMENT OF ML/TF RISKS

The Company applies a risk-based approach (RBA) by assessing customer profiles, geographic risks, and transaction behaviors.

AML Compliance Person knows, suspects or has reason to suspect:

Geographic risk (high-risk jurisdictions or sanctioned countries)
Customer risk (PEPs, high-net-worth individuals, and customers with unclear fund sources)
Transaction risk (large, frequent, or unusual deposits and withdrawals)
Payment method risk (third-party payments, cryptocurrency, or prepaid cards)

The company conducts an annual risk assessment review to ensure compliance with the latest regulatory requirements and to address emerging AML/CFT threats. Additionally, the risk assessment will be updated whenever significant changes occur in business operations, such as expansion into new markets, introduction of new payment methods, or regulatory amendments. The updated risk assessment will guide internal AML controls and customer due diligence procedures to reflect current risks.

COMPLIANCE CONTROLS & EMPLOYEE TRAINING

Our Money Laundering Reporting Officer (MLRO) is responsible for reviewing and reporting all suspicious activities.

We reserve the right to withhold funds and restrict accounts if fraudulent activity is suspected.

All employees undergo annual AML/CFT training, including identifying high-risk transactions and proper reporting procedures.

Strict internal controls are in place to detect and prevent money laundering.

REGULATORY OVERSIGHT & INDEPENDENT AUDITS

We undergo annual AML audits to ensure compliance with Anjouan’s Gaming License regulations.

Any breach of AML laws may result in fines, license suspension, or legal action.

This policy ensures full compliance with Anjouan’s Gaming License regulations, aligning with international AML/CFT best practices. If you have any questions about our AML policy or account verification, please contact our support team.