Objective and Scope

Tk71 adopts a formal anti-money laundering (AML) program designed to prevent the use of its platforms for money laundering and terrorist financing. This policy applies to all customers, prospective customers, employees, and business relationships, and covers all activities executed through Tk71 systems, payment channels, and related processes.

Definitions

Money Laundering refers to the process of concealing or disguising the illicit origin of funds or property, or facilitating the participation of others in such activity, through the conversion, transfer, or movement of assets. The policy also covers the concealment of the true nature, source, or ownership of funds, the acquisition or use of funds known to be derived from criminal activity, and participation in related acts. Money laundering includes activity conducted outside the jurisdiction where the underlying crime occurred and applies to both domestic and cross-border transactions.

Know Your Customer (KYC) means the procedures for identifying, verifying, and understanding the nature and purpose of a customer’s business and risk profile. Source of Funds (SOF) refers to the origin of the funds used in transactions. Source of Wealth (SOW) refers to the overall economic means by which a customer has acquired their wealth. Enhanced Due Diligence (EDD) denotes intensified controls for higher-risk customers or transactions.

Governance and Oversight

Tk71 assigns primary responsibility for AML compliance to a designated AML Compliance Officer who reports to the senior management team. The AML function implements and maintains the program, approves policy changes, and ensures alignment with applicable laws, regulations, and regulatory expectations. Major policy changes require approval by senior management and the AML Compliance Officer.

Customer Onboarding and KYC

  1. Step 1 – Customer Profile and Basic Information
    • Collect and verify full legal name, date of birth, country of residence, and current address.
    • Obtain contact details and confirm the customer’s status for age and eligibility in accordance with licensing requirements.
    • Record voluntary disclosures (e.g., gender) where applicable; all data handling complies with data protection standards.
  2. Step 2 – Identity Verification for Enhanced Screening
    • Triggered for deposits above 2,000 EUR or withdrawals of any amount, or as determined by risk profiling.
    • Require presentation of an official government-issued document (passport, national ID card, or driver’s license) and proof of address (recent utility bill, bank statement, or government communication).
    • Verification may be conducted via automated electronic checks against authorized databases. If the automated check is inconclusive or unavailable, manual verification methods shall be employed.
  3. Step 3 – Source of Funds and Enhanced Review
    • Triggered for deposits above 5,000 EUR or withdrawals above 5,000 EUR, or as dictated by risk assessment.
    • Obtain documentation describing the source of funds (SOF) and, where appropriate, the source of wealth (SOW). Acceptable evidence includes employment records, business ownership documentation, inheritance, investment activity, or other legitimate income sources.
    • If SOF/SOW cannot be established to Tk71’s satisfaction, or if documentation is unavailable, the account activity may be restricted or the transaction may be blocked until verification is completed.

Risk-Based Customer Profiling

Tk71 categorizes customers by regional and other risk factors into Low, Medium, and High risk. Low-risk jurisdictions undergo standard verification; Medium-risk customers are subject to enhanced screening and proportionate transaction thresholds; High-risk regions are subject to restrictions or prohibition of activity, with continuous monitoring and periodic reassessment based on evolving risk indicators.

Ongoing Transaction Monitoring

Tk71 employs a three-line defense approach to monitoring transactions and customer activity:

  1. First Line of Control – Transactional and onboarding controls via trusted payment service providers (PSPs) and internal screening to prevent high-risk activity from entering the system; KYC procedures are applied to all on-ramps and off-ramps.
  2. Second Line of Control – In-network surveillance and due diligence on transactions and customer behavior, including requests for financial transactions, payment method changes, and abnormal activity. The three-step verification framework supports ongoing risk assessment.
  3. Third Line of Control – Manual review by the AML team for higher-risk or atypical activity, with escalation to authorities as required by applicable law and internal procedures.

Reporting, Cooperation and Record Keeping

Suspicious transactions and activities are assessed by the AML function and, where appropriate, reported to the competent authorities in accordance with legal obligations. Tk71 reserves the right to terminate or suspend customer relationships where ongoing due diligence cannot be satisfied or where illicit activity is suspected.

All records relating to customer identification (KYC) and transactions must be retained for a minimum of ten years after the end of the business relationship or the completion of the relevant transaction. Records are stored in secure, access-controlled environments with appropriate encryption and data protection measures.

Data Privacy and Security

Tk71 implements technical and organizational measures to protect personal data, ensure data integrity, and restrict access to information to authorized personnel only. Data processing aligns with applicable data protection laws and regulatory expectations for online gambling platforms.

Source of Funds, Wealth and Sanctions Screening

Tk71 requires transparent SOF/SOW declarations for high-value transactions and conducts sanctions screening and adverse media checks in accordance with regulatory requirements. Sanctions lists and PEP considerations are integrated into risk scoring and ongoing monitoring processes.

Training and Awareness

All relevant staff receive ongoing AML training tailored to their role, including KYC procedures, transaction monitoring, escalation pathways, and reporting obligations. Training is risk-based and refreshed to reflect changes in regulation and business processes.

Policy Review and Continuous Improvement

The AML program is reviewed on a scheduled basis and amended as necessary to reflect regulatory changes, emerging risks, and operational learnings. Major amendments require authorization by senior management and the AML compliance function.

Contact and Implementation

Operational guidance, procedures, and supporting documentation are accessible to authorized personnel through Tk71’s internal systems. Any questions about this policy should be directed to the designated AML contact within Tk71’s compliance function.