BATBET AML POLICY
1. Company Business Model
Batbet is a company registered and operating under the laws of the Republic of Seychelles, providing services via a blockchain-based platform for esports betting on the Solana network. The platform offers users the opportunity to place bets, participate in lotteries, and utilize NFTs and tokens for additional features. The company serves users in multiple countries and, in this context, has implemented a comprehensive Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) compliance program.
As part of its global operations, the company applies AML compliance measures tailored to its services and products to prevent illegal activity on the platform. These measures include client verification during registration and transaction monitoring.
2. Company Policy Statement
The company is not a financial institution under the legal definition of its jurisdiction and is therefore not subject to direct regulation as a financial institution, money transmitter, or virtual asset service provider. Nevertheless, in accordance with the laws of the Republic of Seychelles, the company adopts strict measures to prevent the use of its platform for any form of illicit activity, including money laundering, terrorist financing, and violations of trade sanctions.
The company is committed to following global best practices in AML and CFT, which include:
Adoption of written policies and procedures designed to prevent money laundering, terrorist financing, and sanctions violations.
Appointment of a dedicated Compliance Officer responsible for monitoring compliance with policies, procedures, and controls.
Ongoing AML training for relevant employees and periodic independent audits to verify adherence to the policy.
3. Definitions
Money Laundering: The process of making illegally obtained funds appear legitimate, generally conducted in three stages: placement, layering, and integration.
Placement: Introducing illicit funds into the financial system through deposits or other means.
Layering: The process of separating illicit funds from their source through complex layers of financial transactions.
Integration: The use of legitimate transactions to obscure the origin of illicit funds and reintroduce them into the economy.
Suspicious Activity: Actions that may indicate an attempt to launder money or finance terrorism.
Sanctions: Measures imposed by the international community to restrict the actions of certain countries, organizations, or individuals, including those associated with terrorist financing.
4. Governance and Oversight
The company appoints a Chief Compliance Officer (CCO) who is responsible for coordinating the implementation of the AML policy, developing initiatives to ensure legal compliance in anti-money laundering matters, and investigating suspicious or unusual activities.
5. Know Your Customer (KYC) and Transaction Monitoring
Batbet applies appropriate customer due diligence measures and continuously monitors user transactions as required by applicable laws. The goal is to prevent users from engaging in unlawful or unauthorized activities. The company uses both internal tools and third-party service providers to fulfill its AML compliance obligations.
5.1 Customer Verification (KYC)
The company has developed and implemented a comprehensive customer verification system that includes the collection and validation of documents at all stages of interaction with users. At the time of registration and thereafter, we reserve the right to request verification of the following:
Identity (name, address, date of birth, country);
Screening against Politically Exposed Persons (PEP) and sanctions lists;
Verification of source of funds.
5.2 Enhanced Due Diligence and Transaction Monitoring
Enhanced due diligence is conducted for users classified as high-risk. In addition, we regularly monitor all platform transactions. This includes the use of specialized software to detect suspicious activity and analyze user behavior.
5.3 Customer Acceptance Policy
We do not accept and will block users who:
Fail to provide the required documents or submit falsified documents;
Use methods to bypass controls (e.g., location spoofing);
Are from sanctioned or prohibited jurisdictions;
Are associated with activities subject to anti-money laundering or counter-terrorism financing laws.
6. Transaction Monitoring
The company has implemented a transaction monitoring system to detect suspicious activity potentially related to money laundering or terrorist financing. This system is based on the analysis of:
Unusual transactions in terms of volume, frequency, or pattern;
Transactions originating from or directed to high-risk jurisdictions;
Unusual payment schemes.
Batbet also utilizes third-party services to detect fund mixing and other suspicious activities on the platform.
7. Employee Training and Development
We conduct regular training for our staff, including:
Education on AML and CFT fundamentals;
Ongoing professional development in accordance with changes in legislation;
Training on detection and investigation of suspicious activity.
8. Reporting and Cooperation with Regulators
Batbet is committed to reporting suspicious transactions to the relevant regulatory authorities (e.g., the Financial Intelligence Unit). Any customer identified as sanctioned or suspected of involvement in money laundering or terrorist financing will be flagged and reported as suspicious activity to the appropriate enforcement bodies.
9. Conclusion
We are committed to complying with all applicable laws and standards on anti-money laundering and countering the financing of terrorism. We take all necessary measures to ensure user safety and to prevent any illegal financial activity on our platform.