AML Policy

Last updated: 28.04.2025

Regulatory Compliance Framework

We adhere strictly to the 2016 Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations. Our operations prohibit any illicit activities, including money laundering, terrorist financing, or violations of trade sanctions, in line with various global AML regulations.

Our compliance team actively monitors updates from the Financial Action Task Force (FATF) and the GCB to maintain high compliance standards. Our key practices include:

During this process, the user will have to input some basic details about themselves and then upload:

  • Developing and maintaining policies, procedures, and controls to combat money laundering, terrorist financing, and sanctions violations.
  • Establishing an internal AML/KYC team to oversee these protocols.
  • Providing ongoing training to our staff.
  • Conducting regular independent reviews to ensure compliance and address any identified deficiencies.

Glossary of Terms & Definitions

  • Money Laundering: Transforming illegal gains into seemingly legitimate funds, typically through placement, layering, and integration stages.
  • Placement: Introducing illegal proceeds into financial systems via deposits or other means.
  • Layering: Disguising the origins of criminal proceeds through complex financial transactions.
  • Integration: Reintroducing laundered money into the economy as legitimate to evade detection.
  • Suspicious Activity: Transactions that suggest fraud or illegal activities by users or non-users.
  • Sanctions: Measures imposed by international bodies to restrict activities of targeted entities or nations.
  • Our Chief Compliance Officer oversees the implementation of our AML policies, driving initiatives, and ensuring adherence to evolving regulatory requirements.
  • Client Due Diligence (CDD)

    We apply rigorous due diligence and continuous monitoring using advanced software to comply with legal standards.

Know Your Customer (KYC)

Our KYC process, based on a Risk-Based Approach (RBA), helps us understand and assess the profiles of our players. This includes collecting essential information at registration and during account management. Our Customer Identification Program (CIP) includes:

  • Collecting key data such as wallet addresses and email at account creation.
  • Monitoring the risk associated with the cryptocurrency wallets used for funding.
  • Keeping records of identification data.
  • Screening against lists of known or suspected terrorists or their organizations.

Identity and Age Verification

To ensure the validity of the user information and compliance with KYC requirements, BINOBI.COM employs third-party services. These services verify users' identity and age to confirm they are eligible and not from restricted or sanctioned jurisdictions. They also check global sanctions lists to ensure users do not appear on them, based on the onboarding information such as wallet addresses.

Customer Information

BINOBI.COM collects detailed user information to establish a well-informed belief regarding the identity of its users, aligned with their risk profile. This information may include wallet address, name, address, country, date of birth, and postal code, collectively known as "KYC Information".

Prior to issuing BINOBI.COM funding addresses for deposits, we ensure all necessary KYC Information is collected. We do not permit corporate entities. Depending on the situation, BINOBI.COM may rely on third-party institutions to perform some or all aspects of our Customer Identification Program (CIP).

Geo-blocking for Prohibited and Sanctioned Jurisdictions

BINOBI.COM requires clients to certify that they will not offer services in countries where such activities are illegal through IP address-based geo-blocking. We also ensure that users are not subject to sanctions from Austria, France and it's territories, Germany, Netherlands and it's territories, Spain, Union of Comoros, United Kingdom, USA and it's territories, All FATF Blacklisted countries, and any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.

Enhanced Due Diligence (EDD)

For users who display indicators of suspicious behavior or those involved in high-risk transactions, BINOBI.COM conducts enhanced due diligence. This may include verifying the user's full legal name, country of citizenship, permanent address, identification number (such as taxpayer identification, passport number, or alien identification card number), and documentation of their source of funds and wealth.

Restrictions

BINOBI.COM will block users who:

  • Fail to provide requested identification information.
  • Submit fraudulent identification documents.
  • Attempt to misrepresent their location.
  • Are from restricted or prohibited jurisdictions.
  • Are subject to global sanctions or watch lists.
  • Are identified as being addicted to gambling or having mental health issues.
  • Have funds originating from restricted jurisdictions.
  • BINOBI.COM reserves the right to suspend or block players for any other reasons deemed necessary.

Transactions Monitoring

BINOBI.COM is committed to adhering to economic and trade sanctions and has established a transaction monitoring program. This includes both manual and automated processes to identify and address any unusual activities in real-time and through ongoing monitoring. Our systems review user history and activity patterns to detect and report unusual behavior and implement necessary controls.

Ongoing Monitoring of Transactions

In addition to the above, BINOBI.COM implements procedures for ban evasion detection, time zone monitoring, and product and service reviews to prevent misuse of our platform and ensure compliance with our terms of service. We periodically evaluate our third-party service providers to ensure they meet our compliance requirements.

These comprehensive measures ensure BINOBI.COM maintains high standards of regulatory compliance and safeguards against illegal activities, reinforcing our commitment to operating with integrity and responsibility in the gaming industry.

Vendor Management

BINOBI.COM collaborates with reputable third-party service providers as part of our compliance infrastructure. We regularly assess the performance of these providers to ensure they meet our operational and compliance standards. If a service provider is not meeting expectations, or if additional services are required, we may take remedial action or seek alternative solutions to maintain our compliance with regulatory requirements.

Compliance Innovation

In our pursuit of continuous improvement, BINOBI.COM actively explores and tests non-documentary compliance mechanisms to evaluate their effectiveness for our platform. This includes experimenting with blockchain-native compliance tools such as fraud prevention services and on-chain KYC providers, which are designed to leverage the unique technological features of blockchain platforms. We may run pilot programs with compliance vendors to determine the viability of these tools in enhancing our regulatory framework.

Internal Training

BINOBI.COM ensures that our employees receive regular training on Anti-Money Laundering (AML), anti-terrorist financing, and compliance with trade sanctions. These training sessions are conducted periodically and are tailored to the specific needs of our staff, based on the latest regulatory developments and best practices in the industry.

Suspicious Transaction Reporting (STR)

BINOBI.COM is committed to adhering to the National Ordinance concerning the reporting of unusual or suspicious transactions. If a customer is identified as being linked to money laundering, terrorism financing, or other criminal activities, such activity will be reported as suspicious to the relevant regulatory authorities. This is part of our broader effort to maintain a safe and legal gaming environment and to fulfill our regulatory obligations.