9winz.com, managed by Globis N.V. and licensed under Curacao law with registration number 155962 and license number 365/JAZ, adheres to rigorous Anti-Money Laundering (AML) protocols. Our AML policy is designed to ensure the highest level of security for all users and incorporates a mandatory three-step verification process to verify user identity. This thorough approach is aimed at preventing any association with stolen or unauthorized use of deposit methods.
Our objective is to maintain and secure the integrity of financial transactions on www.9winz.com by verifying the legitimacy of our customers and their transactions. This includes adapting security measures based on nationality and transaction method to mitigate money laundering risks effectively.
We operate in strict accordance with EU Directive 2015/849 and EU Regulation 2015/847, among other regulations aimed at preventing financial systems from being used for the laundering of money from criminal activities. Our policy also respects the Belgian Law of 18 September 2017, which restricts cash use and combats money laundering.
Definition of money laundering
Money laundering activities include, but are not limited to, the conversion or transfer of property derived from criminal activity for the purpose of concealing its illegal origin. This also includes the acquisition, possession, or use of such property and involvement in such activities, regardless of the location where the property was generated.
Organizational AML Structure: The AML efforts at www.9winz.com are overseen by the highest-level management of UD Advertising Agency Ltd., with an Anti-Money Laundering Compliance Officer (AMLCO) appointed to ensure the enforcement of AML policies. The AMLCO reports directly to the general management and is responsible for policy implementation.
Policy implementation and verification
Changes to the AML policy must be approved by the general management and the AMLCO. All users and customers must complete a step one verification, which involves providing personal information such as name, date of birth, residence, gender, and address, regardless of their transaction choices or nationality. This initial verification step is critical for enhancing the security of withdrawals and maintaining compliance with global AML standards.
Users who engage in transactions exceeding $2,000 for deposits, withdrawals, or tip other users more than $1,000 must complete step two verification. This involves navigating to a specific page where users must upload a photograph of their official ID, accompanied by a paperclip holding a six-digit, randomly generated number. This step verifies the consistency of information provided in step one with two independent databases and checks the authenticity of the ID. Should electronic verification fail or be unavailable, users may be asked to submit proof of residency through a government-issued registration certificate or a similar document.
For transactions surpassing $5,000 in deposits or withdrawals, or tipping over $3,000, step three verification becomes necessary, focusing on substantiating the user source of wealth.
Customer Identification and Verification (KYC)
Identification at the point of entry into commercial relationships is crucial for adherence to anti-money laundering regulations and the KYC policy. Verification involves submitting a photo of a valid passport, ID card, or driving license next to a handwritten note with a six-digit number. A secondary photo capturing the user face must also be submitted, though personal details except for the date of birth, nationality, gender, name, and photo may be obscured for privacy. All documents must be clear, showing all four corners, and must be readable.
Proof of Address
Verification of address is conducted through two separate electronic database checks. If these checks fail, users can manually provide proof through a recent utility bill or a government-issued document confirming their residence, ensuring the document is clear and all text is legible.
This structured verification process ensures compliance with regulatory standards while protecting user privacy and preventing fraudulent activities. Additional checks may be conducted by employees based on specific circumstances or requirements.
Verification of Source of Wealth for Large Deposits
When a player deposits more than five thousand euros, 9winz implements a process to verify the source of these funds to ensure the transparency and legality of the wealth. Acceptable sources of wealth may include earnings from business ownership, employment, inheritance, investments, or family contributions.
Documentation and Verification Process
Players are required to provide clear evidence about the origin of their wealth. If the documentation or explanations are insufficient, 9winz staff may request additional proof. Failure to provide satisfactory information will result in the freezing of the account, with players being notified directly via email and through notifications on the website.
Additional Identity Verification
To further verify the identity of our users, 9winz requires a linked bank account or credit card. This helps in providing a clearer picture of the financial status of the user.
Basic Information Requirement
All users must complete a basic information form available through the settings page on www.9winz.com. Required details include first name, second name, nationality, gender, and date of birth. This document is initially processed by an automated system, with manual checks conducted as needed based on specific cases.
Risk Management by Geographic Region
9winz classifies nations into three risk categories to tailor the verification process:
- Standard three-step verification (low risk).
- Enhanced verification at reduced thresholds for deposits, withdrawals, and tips. Changes in currency by users from low-risk regions are treated as medium risk (medium risk).
- Nations deemed high risk are prohibited from using the platform, with this list updated regularly to adapt to global changes (high risk).
Additional Security Measures
An AI system, monitored by the Anti-Money Laundering (AML) compliance officer, automatically flags unusual activities. Human oversight ensures that all automated checks are verified, with the possibility of additional reviews based on anomalies detected by data scientists. These include unusual patterns such as frequent deposit and withdrawal activities without corresponding gaming activities, attempts to use different bank accounts, and sudden changes in user behavior or account details.
To combat potential money laundering, users must withdraw using the same method as their initial deposit up to the amount deposited. This policy ensures the integrity of financial transactions on the platform.
Comprehensive Risk Assessment and Transaction Monitoring at 9winz
9winz.com performs an annual “Enterprise-wide Risk Assessment” (EWRA) to pinpoint and manage risks specific to its operations. This assessment involves examining aspects like the types of services offered, user transactions, delivery channels, geographic reach, and additional risks introduced by online operations. This process helps align the website risk policies with regulatory standards and expectations.
Structured Transaction Monitoring
To prevent and identify suspicious activities, 9winz conducts detailed transaction monitoring, structured across three levels of control:
First Line of Control
9winz partners exclusively with Payment Service Providers that implement robust AML policies. This partnership helps to prevent suspicious transactions by ensuring thorough KYC procedures are applied before accepting customers.
Second Line of Control
All interactions with customers, whether they’re transaction requests or inquiries about payment methods, trigger due diligence checks. This includes a detailed three-step verification process tailored to assess the risk profile of each customer continuously. Transactions are monitored by trained staff under the oversight of an AML Compliance Officer, who in turn reports to general management. This system ensures all transactions are scrutinized and any that are unusually complex or unusually large are flagged for further inspection.
Third Line of Control
As a final safeguard, manual checks are conducted on all high-risk or suspicious transactions by the compliance team to ensure no aspect of money laundering or fraudulent activity goes undetected. If any such activity is confirmed, immediate action is taken, including notifying the appropriate authorities.
This rigorous monitoring framework ensures that 9winz maintains a high standard of compliance and security, safeguarding against money laundering risks and protecting both the platform and its users.
Handling Suspicious Transactions at 9winz.com
9winz.com has well-defined internal protocols detailing how staff should identify and report suspicious transactions. The AML team assesses these reports using a structured approach laid out in the company procedures. Based on their analysis and gathered information, the team decides whether to report the activity to the Financial Intelligence Unit (FIU) as per the Law of 18 September 2017 and whether to continue or terminate the customer relationship.
Operational Procedures and Record Keeping
The company translates AML regulations and KYC requirements into clear operational guidelines accessible on 9winz.com intranet. Identification records are retained for a minimum of ten years post the termination of a business relationship, and transaction records are similarly kept for ten years after completion. All data are securely encrypted and stored to ensure privacy and integrity.
Training and Auditing
9winz conducts thorough AML training for all relevant employees, tailored to their specific roles and the nature of their work. This training is delivered by AML specialists from UD Advertising Agency Ltd. AML team and is updated regularly to reflect the latest regulatory changes. Additionally, the company internal audit team conducts regular reviews and reports on AML practices to ensure compliance and efficacy.
Data Security
9winz commits to the highest standards of data security, ensuring that all user information is kept confidential and secure, never sold, or improperly disclosed. Data may only be shared with AML authorities when legally required or to prevent money laundering, adhering strictly to the data protection directive (Directive 95/46/EC).
Contact Information
For any inquiries or concerns regarding our AML and KYC policies, or if you have any issues with the checks performed, please reach out to us via email at [email protected].