Last updated: 25 October 2025
Welcome to acebet90.co. This AML/CTF Policy sets out the standards, controls, and governance practices adopted by the Operator to prevent and detect money laundering, terrorist financing, fraud, and related financial crime. The Policy is written to enhance EEAT signals (expertise, authoritativeness, trustworthiness) and meets YMYL expectations by placing customer protection, data integrity, and lawful conduct at the center of our service. ✅
By accessing or using the services, you confirm that you have read, understood, and agree to be bound by this Policy, as well as any related KYC, Privacy, Responsible Use, and Terms of Service documents. This Policy applies to all customers, payment channels, and products offered via acebet90.co (the “Website”).
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1) Purpose, Scope, and Governance
Our AML/CTF framework is designed to align with widely recognized international standards and best practices, including risk-based controls, layered customer due diligence, ongoing monitoring, robust escalation pathways, and independent assurance. These measures support the prevention, detection, and reporting of suspicious activity, while enabling lawful, fair, and secure access to services. 🛡️
- Purpose: Prevent misuse of the Website for laundering the proceeds of crime or financing of terrorism; protect customers and payment partners; uphold market integrity.
- Scope: All customers, transactions, instruments, and channels, including card payments, bank transfers, e-money, and virtual assets where supported.
- Accountability: Overall responsibility rests with senior management. Day-to-day oversight is delegated to the AML Compliance Officer (AMLCO), who reports directly to senior management and coordinates with internal audit, risk, security, and customer operations.
2) Legal and Regulatory Alignment
The Website operates a risk-based AML/CTF program that is intended to align with leading frameworks and guidance in applicable jurisdictions, including risk assessment, CDD/KYC, enhanced due diligence (EDD), screening, monitoring, and reporting obligations. Where local law imposes stricter requirements, the stricter standard applies. Nothing in this Policy grants services where provision would be unlawful.
- Foundational principles: customer identification and verification, verification of payment instruments, transaction monitoring, sanctions and PEP screening, record-keeping, training, and reporting of suspicious activity.
- Independence: compliance and audit functions are empowered to challenge processes and request remediation where needed.
3) Key Definitions
For clarity, the following terms are used throughout:
- Money Laundering (ML): any act intended to conceal or disguise the nature, source, location, disposition, movement, or ownership of proceeds of crime, including placement, layering, and integration.
- Terrorist Financing (TF): the provision or collection of funds, by any means, directly or indirectly, with the intention to be used, or in the knowledge that they will be used, to carry out terrorist acts.
- Customer Due Diligence (CDD/KYC): measures to identify and verify the identity of a customer and, where applicable, beneficial owner, prior to and during the relationship.
- Enhanced Due Diligence (EDD): additional risk-proportionate measures for higher-risk scenarios, including PEPs, complex payments, adverse media, or high-risk geographies.
4) Risk-Based Approach (RBA)
We apply proportionate controls consistent with the customer risk profile, product risk, channel risk, and geographic exposure. The AMLCO maintains an enterprise-wide risk assessment (EWRA) that is reviewed at least annually or upon material change. 🔍
- Risk Factors: identity attributes, occupation and source of wealth/funds, payment methods, device and IP intelligence, behavioral patterns, historical activity, and country risk.
- Risk Ratings: customers are assigned a dynamic risk rating (low/medium/high) that informs CDD depth, monitoring intensity, and EDD triggers.
5) Customer Identification, Verification, and KYC
Formal identification is mandatory prior to withdrawals and may be required prior to deposits in accordance with risk and regulatory requirements. We use secure systems and trained staff to validate identity documents and liveness where applicable. 🧾
5.1 Standard CDD (Step 1)
- Minimum data: first and last name, date of birth, nationality, gender, country of residence, and full address.
- Verification: automated database checks and documentary evidence as needed. Inconsistencies must be remediated before continued use.
5.2 Threshold CDD (Step 2)
- Trigger example: cumulative deposits or withdrawals exceeding USD/EUR 2,000 or equivalent, or risk signals determined by the AMLCO.
- Documents: government-issued photo ID (passport, ID card, or driver’s license) photographed in full (all four corners visible) next to a handwritten note that displays a system-generated code; optional liveness/face match may be required.
- Proof of address (PoA): recent utility bill, bank statement, or government letter dated within the last 3 months with name and address clearly visible.
5.3 Enhanced Due Diligence (Step 3)
- Trigger example: cumulative deposits or withdrawals exceeding USD/EUR 5,000, large value tips/transfers, PEP/sanctions proximity, high-risk industries, or adverse media.
- Source of Funds/Wealth (SoF/SoW): payroll slips, tax returns, audited financials, sale of assets records, inheritance documentation, or investment statements, as applicable.
- Outcome: until EDD is completed and approved, affected transactions remain on hold. Where risk cannot be mitigated, the relationship may be declined or terminated.
6) Geographical and Product Risk Controls
Country risk is assessed using recognized indices, sanctions lists, and internal intelligence. We do not onboard customers located in, or transacting from, prohibited or sanctioned jurisdictions. For medium-risk regions, thresholds for Step 2/3 may be lowered. Certain payment methods may be unavailable in specific markets.
7) Payment Instruments and Transaction Rules
- Name match rule: the name on the payment instrument must match the verified customer name. Third-party payments are not permitted.
- Like-for-like withdrawals: where feasible, withdrawals must be returned to the same instrument used for deposit up to the original deposit amount, to reduce ML risk.
- Velocity and pattern checks: automated systems flag unusual behaviors, including rapid deposit/withdraw without play, frequent currency changes, or device/IP anomalies.
- Manual review: flagged transactions are escalated to trained analysts for disposition; suspicious cases may be reported as required by law.
8) Sanctions, PEP, and Adverse Media Screening
Customers are screened against relevant sanctions and PEP lists at onboarding and periodically thereafter. Positive or potential matches result in immediate review, EDD, blocking, or offboarding where mandated. Media screening supplements list screening to identify reputational and legal risks. 🚫
9) Ongoing Monitoring
We operate multi-layer monitoring to detect unusual or suspicious activity compared with the customer profile. Monitoring includes rule-based alerts, statistical models, and analyst-led reviews.
- First line: trusted payment service providers with their own AML controls, plus Website-side automated pre-filters.
- Second line: AMLCO team oversight, investigation workflows, due diligence on requests for new payment instruments or limits.
- Third line: focused manual reviews of higher-risk cohorts and periodic thematic investigations.
10) Suspicious Activity Escalation and Reporting
Staff must escalate unusual activity to the AML team without delay. The AML team evaluates alerts using a documented methodology and may file suspicious activity reports with relevant authorities where required. Customers will not be notified where prohibition on “tipping off” applies. All decisions are recorded with reasoning and evidence trails.
11) Record-Keeping
- KYC records: retained for at least 10 years after the relationship ends, or longer if required by law.
- Transaction records: retained for at least 10 years from execution or relationship end, whichever is later.
- Security: records are stored securely using encryption and access controls, with segregation, audit logs, and disaster recovery provisions.
12) Data Protection and Privacy
We process personal data lawfully, fairly, and transparently for AML/CTF purposes. Data is used strictly for identification, verification, monitoring, and reporting obligations, and may be shared with competent authorities or partners where legally required. Customers can exercise applicable privacy rights subject to AML retention and legal constraints. 🔐
13) Training and Awareness
All relevant personnel receive mandatory AML/CTF induction and periodic refresher training covering typologies, red flags, escalation, record-keeping, and sanctions compliance. Training effectiveness is measured through testing, QA sampling, and audit feedback. 📚
14) Independent Testing and Audit
Internal audit and, where appropriate, external reviewers perform risk-based audits of AML/CTF controls, including design and operating effectiveness, with documented remediation plans and deadlines. Findings are reported to senior management for oversight.
15) Prohibited and Restricted Activity
- Accounts used on behalf of third parties or for anonymous/obfuscated payments.
- Use of forged or altered identity documents, or attempts to bypass controls.
- Transactions involving sanctioned persons, vessels, or jurisdictions.
- Structuring deposits/withdrawals to avoid thresholds or monitoring.
16) Consequences of Non-Compliance
Breaches may result in immediate account suspension or termination, transaction reversals, reporting to authorities, and retention of records for investigative purposes. Where losses or costs arise from misuse or fraud, the Operator may pursue recovery to the fullest extent permitted by law. ⚖️
17) Customer Guidance and Best Practices
- Use only your own payment instruments; ensure your name matches account details.
- Respond promptly to KYC/EDD requests to avoid delays in withdrawals.
- Keep contact details current; maintain access to your registered email and phone.
- Do not share your account; safeguard credentials and enable available security features.
18) Contact
For AML/KYC questions or to submit documents, contact our Compliance team:
- Email: [email protected]
Please include your registered full name, account ID, and a concise description of your request. We aim to respond within stated service levels, subject to complexity and regulatory timelines. ✉️
19) Amendments
This Policy may be updated to reflect changes in law, guidance, risk appetite, products, or processes. The most current version will be published on acebet90.co. Continued use of the Website after an update constitutes acceptance of the revised Policy.
Annex A: Illustrative CDD/EDD Thresholds
| Control Layer | Illustrative Trigger | Examples of Documents/Actions |
|---|---|---|
| Step 1 (CDD) | Account activation / prior to withdrawals | Identity data capture; automated checks; basic document review |
| Step 2 (Threshold CDD) | ≥ USD/EUR 2,000 cumulative deposits/withdrawals or risk flags | Full ID image with code note; face match; recent proof of address |
| Step 3 (EDD) | ≥ USD/EUR 5,000 cumulative or high-risk indicators | Source of funds/wealth evidence; enhanced screening; management approval |
Annex B: Common Red Flags
- Frequent in-and-out transactions with minimal gameplay activity.
- Use of multiple cards or accounts with differing names.
- Rapid change of devices, IPs, or geographies inconsistent with profile.
- Reluctance to provide KYC/EDD documents or unverifiable documentation.
- Transactions linked to sanctioned or high-risk jurisdictions.
Disclaimer
This Policy is provided for transparency and customer awareness. It does not constitute legal advice and may be supplemented by jurisdiction-specific notices. Where conflicts arise between this Policy and mandatory local law, the latter prevails.