1. Cash Deposits and Cash Withdrawals

www.cherrybet.com is operated by Luther Communication B.V., having its office at Abraham de Veerstraat 9, Willemstad, Curacao. Company Registration number: 166046.

Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on www.cherrybet.com. To ensure this, a three-step account verification process is implemented to verify the identity of our customers. This process aims to confirm that the registered details are correct, and the deposit methods used are not stolen or being misused, thereby creating a framework for combating money laundering. We also consider that, depending on nationality and origin, various safety measures must be applied to different payment and withdrawal methods.

www.cherrybet.com also implements reasonable measures to control and limit money laundering (ML) risks, including dedicating appropriate resources.

www.cherrybet.com is committed to high standards of anti-money laundering (AML) in accordance with EU guidelines. The company enforces these standards to prevent the use of its services for money laundering, and requires management and employees to uphold these standards.

The AML program of www.cherrybet.com is designed to comply with the following:

• EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
• EU: “Regulation 2015/847 on information accompanying transfers of funds”
• EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
• BE: “Law of 18 September 2017 on the prevention of money laundering and limitation of the use of cash”

2. Definition of Money Laundering

Money laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from participation in such activity, with the purpose of concealing or disguising the illegal origin of the property or assisting any person involved in the commission of such an activity to evade legal consequences.
• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from participation in such an activity.
• The acquisition, possession, or use of property, knowing at the time of receipt that such property was derived from criminal activity or from assisting in such activity.
• Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the aforementioned actions.

Money laundering is considered an offense even when the activities generating the property were carried out in the territory of another Member State or in a third country.

3. Organization of the AML for www.cherrybet.com

In accordance with AML legislation, www.cherrybet.com has appointed the “highest level” for the prevention of Money Laundering (ML): the full management of Luther Communication B.V. are responsible.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of enforcing the AML policy and procedures within the system.

The AMLCO operates under the direct responsibility of the general management.

4. AML Policy Changes and Implementation Requirements

Each major change to the www.cherrybet.com AML policy is subject to approval by the general management of Luther Communication B.V. and the Anti Money Laundering Compliance Officer (AMLCO).

5. Three-Step Verification

Step One Verification

Step one verification must be completed by every user and customer before making a withdrawal. Regardless of the payment method, payment amount, withdrawal amount, choice of withdrawal, or nationality of the user/customer, step one verification is mandatory. This involves filling out a document with the following details: first name, second name, date of birth, country of residence, gender, and full address.

Step Two Verification

Step two verification is required for any user depositing or withdrawing over $2000. Until this step is completed, the withdrawal, tip, or deposit will be held. Step two involves submitting an ID. The user/customer must take a picture of their ID alongside a paperclip holding a six-digit randomly generated number. Only official IDs are accepted, and the list of acceptable IDs varies by country. An electronic check will verify the information provided in step one. If the electronic check fails or isn’t possible, a proof of residence such as a government-issued certificate of registration will be required.

Step Three Verification

Step three verification is mandatory for users who deposit over $5000, withdraw over $5000, or send another user over $3000. Until this step is completed, the withdrawal, tip, or deposit will be held. In step three, users/customers must provide proof of the source of their wealth.

6. Customer Identification and Verification (KYC)

Customer Identification and Verification (KYC)

The formal identification of customers when entering into commercial relations is a crucial element, both for anti-money laundering regulations and the Know Your Customer (KYC) policy.

This identification process relies on the following key principles:

• A copy of your passport, ID card, or driving license is required. Each document must be shown alongside a handwritten note displaying six randomly generated numbers. Additionally, a second picture showing the user/customer’s face is necessary. The user/customer may blur out information except for the date of birth, nationality, gender, first name, second name, and the picture, to protect their privacy.
• All four corners of the ID must be visible in the same image, and the details, except for the ones allowed to be blurred, must be clearly readable. We may ask for additional details if deemed necessary.
• Employees may perform additional checks based on the specific circumstances of the situation.

7. Proof of Address

Proof of Address

Proof of address is verified through two separate electronic checks using different databases. If an electronic test fails, the user/customer will have the option to provide manual proof.

Acceptable documents include a recent utility bill issued within the last three months, or an official government document that verifies your place of residence.

To expedite the approval process, ensure the document is sent with a clear resolution where all four corners of the document are visible, and the text is fully readable.

Examples of acceptable documents include:

• Electricity bill
• Water bill
• Bank statement
• Any governmental document addressed to you

If necessary, an employee may conduct additional checks based on the specific situation.

8. Source of Funds

Source of Funds

If a player deposits over five thousand euros, www.website.com initiates a process to understand the source of wealth (SOW). This ensures the origin and legitimacy of the funds are clearly understood.

Examples of SOW include:

• Ownership of a business
• Employment
• Inheritance
• Investment
• Family

If it is not possible to verify the source of wealth, an employee may request additional documentation or proof.

In cases where a user deposits this amount either in a single transaction or through multiple transactions that total this amount, the account will be frozen. An email will be sent to the user manually, informing them of the process and providing additional information on the website.

www.website.com may also require a bank wire or credit card to further verify the user’s identity and provide additional insights into their financial situation.

9. Basic Document for Step One

Basic Document for Step One

The basic document required for Step One verification will be accessible via the settings page on www.website.com. Every user is required to fill out the following information:

• First name
• Second name
• Nationality
• Gender
• Date of Birth

The document will be generated and saved by an AI system. If necessary, an employee may perform additional checks depending on the situation.

10. Risk Management

Risk Management

To address the varying risks and differing states of wealth across regions, www.cherrybet.com will categorize every nation into three different regions of risk.

11. Region One: Low Risk

Region One: Low Risk

For every nation classified in Region One, the three-step verification process is conducted as previously described.

12. Region Two: Medium Risk

Region Two: Medium Risk

For every nation classified in Region Two, the three-step verification process will be implemented at lower deposit, withdraw, and tip amounts compared to Region One:

• Step One: Conducted as usual.
• Step Two: Required after depositing $1000, withdrawing $1000, or tipping another user/customer $500.
• Step Three: Required after depositing $2500, withdrawing $2500, or tipping another user/customer $1000.

Additionally, users from a low-risk region who convert cryptocurrency into any other currency will be treated as users/customers from a medium-risk region.

13. Region Three: High Risk

Region Three: High Risk

Regions classified as high risk will be banned from using www.cherrybet.com. This policy helps mitigate risks associated with high-risk regions.

High-risk regions will be regularly updated to adapt to the changing environment of a fast-evolving world.

14. Additional Measures

Additional Measures

In addition to the established procedures, an AI system overseen by the AML Compliance Officer will monitor for any unusual behavior and report it immediately to an employee of www.website.com.

Based on a risk-based view and general experience, human employees will recheck all checks performed by the AI or other employees and may perform additional checks as needed.

Furthermore, a data scientist, supported by modern electronic analytic systems, will investigate unusual behavior such as:

• Depositing and withdrawing without extended betting sessions
• Attempts to use a different bank account for deposit and withdrawal
• Nationality changes
• Currency changes
• Behavior and activity changes
• Verification to ensure an account is used by its original owner

Additionally, users must use the same method for withdrawal as they used for the deposit, up to the amount of the initial deposit, to prevent money laundering.

15. Enterprise-wide Risk Assessment

Enterprise-wide Risk Assessment

As part of its risk-based approach, www.cherrybet.com has conducted an AML “Enterprise-wide Risk Assessment” (EWRA) to identify and understand risks specific to www.cherrybet.com and its business lines. The AML risk policy is developed after identifying and documenting the risks inherent to its business lines, such as the services the website offers.

The EWRA takes into account the following factors:

• The Users to whom services are offered
• Transactions performed by these Users
• Delivery channels used by the website
• Geographic locations of the website’s operations, customers, and transactions
• Other qualitative and emerging risks

The identification of AML risk categories is based on www.cherrybet.com’s understanding of regulatory requirements, regulatory expectations, and industry guidance. Additional safety measures are implemented to address the unique risks associated with the global nature of the internet.

16. Ongoing Transaction Monitoring

Ongoing Transaction Monitoring

AML-Compliance ensures that ‘ongoing transaction monitoring’ is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on three levels:

1. The First Line of Control:
   www.cherrybet.com works solely with trusted Payment Service Providers who have effective AML policies in place. This prevents the majority of suspicious deposits from taking place without proper KYC procedures being executed.
2. The Second Line of Control:
   www.cherrybet.com ensures that its network is aware of any interactions with customers or their authorized representatives. This includes due diligence on transactions such as:
   • Requests for the execution of financial transactions on the account
   • Requests in relation to means of payment or services on the account

   The three-step verification with adjusted risk management should provide all necessary information about customers at all times. Transactions must be overseen by employees, with oversight by the AML Compliance Officer, who is in turn supervised by the general management.
   Transactions that are difficult to justify or understand in terms of lawful activities or source of funds are considered atypical. These are flagged by an automated system and cross-checked by employees for additional security. Any atypical transactions observed must be reported to the AML division.

3. The Third Line of Control:
   As a final defense against money laundering, www.cherrybet.com performs manual checks on all suspicious and higher-risk users. If fraud or money laundering is identified, authorities will be informed.

17. Reporting of Suspicious Transactions on www.website.com

Reporting of Suspicious Transactions

In its internal procedures, www.website.com specifies in detail when it is necessary to report suspicious transactions and the process for doing so.

Reports of atypical transactions are analyzed by the AML team according to the methodology outlined in the internal procedures.

Based on this examination and the gathered information, the AML team will:

• Decide whether it is necessary to submit a report to the Financial Intelligence Unit (FIU), in accordance with the legal obligations provided in the Law of 18 September 2017.
• Determine whether it is necessary to terminate the business relationship with the customer.

18. Procedures

Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures. These are accessible on the Intranet site of www.website.com.

19. Training

Training

www.cherrybet.com human employees will conduct manual controls based on a risk-based approach for which they receive special training.

• A mandatory AML training program in accordance with the latest regulatory evolutions, for all employees involved in financial activities.
• Academic AML learning sessions for all new employees.
• These sessions are given by an AML-specialist working in Luther Communication B.V. AML team.

20. Auditing

Auditing

Internal audit regularly establishes missions and reports about AML activities.

21. Data Security

Data Security

All data provided by any user/customer will be kept secure and will not be sold or shared with anyone else. Data may only be shared with the AML authority of the affected state if required by law or to prevent money laundering.

www.cherrybet.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC).

22. Contact Us

Contact Us

If you have any questions about our AML and KYC Policy, please contact us:

By email: [email protected]

If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us:

By email: [email protected]