AML Policy of www.six.run
For Cash Deposits and Cash Withdrawals.
(AMLI Anti-Money-Laundering policy of www.six.run
Introduction: www.six.run is operated by six. having its office at Abraham de Veerstraat 9 Willemstad, Curacao. Company Registration number 163348.
Purpose of the AML Policy: We aim to provide a high level of security to all of our users and customers on www.six.run and for this reason a three-step account verification process is used to ensure the identity of our customers. The purpose is to confirm that the registered person’s details are accurate and the deposit methods used are not stolen or being used by another person, thereby creating the general framework for combating money laundering. We also consider that depending on the nationality and origin, the way of payment and for withdrawing different security measures may be required.
www.six.run also has reasonable measures in place to manage and reduce ML risk, including allocating appropriate resources.
www.six.run is committed to strong anti-money-laundering standards (AML) according to the EU guidelines, compliance and requires management and employees to apply these standards in preventing the use of its services for money laundering purposes.
The AML program of www.six.run 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
Definition of money laundering:
Money Laundering is understood as:
The conversion or transfer of property, especially money, knowing that such property comes from criminal activity or from taking part in such activity, for the purpose of hiding 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 comes 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 will be treated 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 www.six.run:
In accordance with the AML legislation, www.six.run has appointed the "highest level" for the prevention of ML: The full management of www.six.run. is responsible.
Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is responsible for applying the AML policy and procedures within the System.
The AMLCO is placed under the direct supervision of the general Management:
AML policy changes and implementation requirements:
Each major change of www.six.run AML policy is subject to approval by the general management of www.six.run. and the Anti money laundering compliance officer.
Three step Verification:
Step one verification:
Step one verification must be completed by every user and customer to withdraw. Depending on the choice of payment, the amount of payment, the withdrawal amount, the withdrawal choice and the nationality of the user/customer, step one verification must be completed first. Step one verification is a document that must be completed by the user/customer himself. The following information must be provided: first name, second name, date of birth, country of usual residence, gender and full address.
Step two verification:
Step two verification must be completed by every user who deposits over 2000$ (two thousand Dollar) or who withdraws over 2000$ (two thousand Dollar). Until step two verification is complete the withdrawal, tip or deposit will be held. Step two verification will direct the user or customer to a subpage where he must submit his ID. The user/customer must take a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may vary. There will also be an electronic check if the submitted data from the step one verification is correct. The electronic check will check via two different databases to ensure the submitted information matches the completed document and the name from the ID: If the electronic test fails or is not possible the user/customer is required to submit proof of current residence. A certificate of registration by the government or a similar document is required.
Step three verification:
Step three verification must be completed by every user who deposits over 5000$ (five thousand Dollar), who withdraws over 5000$ (five thousand Dollar), or who sends another user over 3000$ (three thousand Dollar). Until step three verification is complete the withdrawal, tip or deposit will be held. For step 3 a user/customer will be asked for a source of wealth.
Customer identification and verification (KYC)
The formal identification of customers on entry into commercial relations is an essential element, both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles:
A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture. To protect their privacy.
Please be aware that all four corners of the ID have to be visible in the same image and all details must be clearly readable besides the named above. We might ask for all details if necessary.
An employee may perform additional checks if necessary, based on the situation.
Proof of Address:
Proof of address will be verified through different electronic checks using two different databases. If an electronic test fails, the user/customer may provide manual proof.
A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proves your place of residence.
To make the approval process as speedy as possible, please make sure the document is sent in a clear resolution where all four corners of the document are visible, and all text is readable.
For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.
An employee may perform additional checks if necessary, based on the situation.
Source of funds
If a player deposits over a five thousand euro there is a process of understanding the source of wealth (SOW)
Examples of SOW are:
Ownership of business
Employment
Inheritance
Investment
Family
It is important 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 proof.
The account will be frozen if the same user deposits this amount either in a single transaction or through multiple transactions that reach this amount. An email will be sent to them manually to go through the above and information on the website itself.
www.six.run also asks for a bank wire/credit card to further verify the identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
Basic document for step one:
The basic document will be accessible via the setting page on www.six.run. Every user has to fill out the following information:
- First name
- Second name
- Nationality
- Gender
- Date of Birth
The document will be saved and created by an AI, An employee may perform additional checks if necessary based on the situation.
Risk management:
To address different risks and wealth levels across regions of the world, www.six.run will classify every nation into three risk categories.
Region one: Low risk:
For every nation from region one the three-step verification is done as described earlier.
Region two: Medium risk:
For every nation in region two the three-step verification will be done at lower deposit, withdrawal and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand Dollars), withdrawing 1000$ (one thousand Dollars) or tipping another user/customer 500$ (five hundred Dollars.) Step three will be done after depositing 2500$ (two thousand five hundred Dollars), withdrawing 2500$ (two thousand five hundred Dollars) or tipping another user/customer 1000$ (one thousand Dollars). Also, users from a low risk region that change crypto currency in any other currency will be treated like users/customers from a medium risk region.
Region three: High risk:
Regions of high risks will be banned. High risk regions will be updated regularly to keep up with a fast-changing environment.
Additional measurements.
In addition, an AI which is overseen by the AML compliance officer will look for any unusual behavior and report it right away to an employee of www.six.run.
According to a risk-based view 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 behavior like: Depositing and withdrawing without extended betting sessions. Attempts to use a different bank account for deposit and withdrawal, nationality changes, currency changes, behavior and activity changes as well as checks, if an account is used by its 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, www.six.run has conducted an AML "Enterprise-wide risk assessment" (EWRA) to identify and understand risks specific to www.six.run and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank's operations, customers and transactions and other qualitative and emerging risks.
The identification of AML risk categories is based on www.six.run 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. This transaction monitoring is conducted on two levels:
1) The first Line of Control:
www.six.run works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the large majority of suspicious deposits onto www.six.run from taking place without proper execution of KYC procedures onto the potential customer.
2) The second Line of Control:
www.six.run 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:
Requests for the execution of financial transactions on the account;
Requests in relation to means of payment or services on the account;
Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of www.six.run whenever needed.
Also, all transactions must be overseen by employees supervised by the AML compliance officer, who is supervised 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 cross checks 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 www.six.run 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 final line of defense against AML www.six.run will do manual checks on all suspicious and higher risk users in order to help prevent money laundering.
If fraud or Money Laundering is found the authorities will be notified.
Reporting of Suspicious transactions on www.six.run
In its internal procedures, www.six.run describes clearly, for the attention of its staff members, when reporting is required and how such reporting should be made.
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 www.six.run.
Record keeping
Records of data obtained for the purpose of identification must be retained for at least ten years after the business relationship has ended.
Records of all transaction data must be retained for at least ten years following the carrying-out of the transactions or the end of the business relationship.
These data will be stored securely and encrypted offline and online.
Training:
www.six.run human employees will perform manual controls as part of risk-based approval, for which they receive special training.
The training and awareness program is reflected by its usage:
A mandatory AML training program in accordance with the latest regulatory developments, for all in touch with finances
Academic AML learning sessions for all new employees
The content of this training program has to be established in accordance with the kind of business the trainees are working for and the positions they hold. These sessions are given by an AML-specialist working in www.six.run. AML team.
Auditing
Internal audit regularly conducts reviews and reports about AML activities.
Data Security:
All data given by any user/customer will be kept secure, will not be sold or provided to anyone else. Only If required by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
www.six.run 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, please contact us:
By Email: [email protected]
If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us:
By Email: [email protected]