AML Policy

The policy against money laundering aims to ensure the best security to all users and casino clients. The account verification consists of three steps to confirm that the registered person’s data is accurate, and the deposit instrument is not stolen by someone else or is not applied by someone else. All this is required to maintain the everyday procedures of anti-money laundering.

Now let us tell you more about safety measures that shall be applied at casinos depending on the nationality, payment method, and the way of withdrawal of gambling winnings. To minimize the risk of money laundering, a casino applies reasonable security measures, including adequate special measures. 

We are committed to the most rigorous criteria of the policy against money laundering. Our management and personnel are required to check each and every casino for complying with the rules aimed at limiting the use of services for money-laundering purposes. 

The program for anti-money laundering at the best casinos according to Gamdom Casino management is developed to comply with:

  • 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 repealing Regulation (EC) No 1781/2006 
  • 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 preventing money laundering.”

Money Laundering Definition

Before you register and start esport betting, learn what Money Laundering means:

  • The transfer or conversion of property, while being aware that such property is acquired from acts of crime or participation in such acts, for the purpose of disguising or concealing the illicit origin of the property or supporting any person who performs such an act to avoid the legal consequences of that person’s action;
  • The disguise or concealment of the real nature, source, location, assignment, movement, rights, or ownership of property, knowing that such property is acquired from acts of crime or participation in such acts;
  • The procurement, ownership, or use of property, being aware, at the time of obtaining, that such property was acquired from acts of crime or participation in such acts;
  • Participation, joining to commit, and the attempt to engage in, assist, provoke, facilitate, and consult on any actions mentioned before.

Money laundering shall be considered an event where the activities, which generated the property to be laundered, were performed in the territory of another Member State or in that of a third country.

Organization of AML according to Gamdom Casino

According to the AML legislation, online casinos are required to assign the “highest level” for preventing money laundering. Moreover, there is the Anti-Money Laundering Compliance Officer (AMLCO) who is responsible for the AML Policy enforcement in the System. The AMLCO is under the immediate supervision of the general management.

Requirements for AML Policy Changes 

Every major change of the AML policy shall be approved by the general management of a casino and the Anti-Money Laundering Compliance Officer. This is to maintain the transparency of bets and sign-up processes.

Three Steps of Verification

  • Step one of the verification: Every user or client shall perform step one of the verification to make a withdrawal. Step one of the verification shall be done first with regard to the payment option and amount, withdrawal amount, the choice of withdrawal, and nationality of the user/client. Step one of the verification is a form that shall be filled out by the user/client himself/herself. The following information shall be included: first name, second name, date of birth, usual residence country, gender, and full address. After that, it is possible to sign in, claim free coins, and go gambling.
  • Step two of the verification: Every user who deposits over $2,000 (two thousand dollars), withdraws over $2,000 (two thousand dollars), or sends another user over $1,000 (one thousand dollars) shall perform step two of the verification. The withdrawal, tip, or deposit will be held until step two of the verification is completed. Step two of the verification will lead the user or client to a subpage where he/she shall provide the ID. The user/client shall take a photo of his/her ID. A paperclip with a random six-digit number is next to his/her ID. Only an official ID shall be used for ID verification. The number of accepted IDs may be different depending on the country. If the filled-in data from step one verification is correct, there will also be an electronic check. The electronic check is performed using two different databanks to ensure the provided information matches the provided document and the ID’s name. The user/client must confirm his/her current residence if the electronic test fails or is impossible to pass. A registration certificate issued by the government authority or a similar document is required.
  • Step three of the verification: Step three of the verification shall be performed by every user who deposits over $5,000 (five thousand dollars), withdraws over $5,000 (five thousand dollars), or sends another user over $3,000 (three thousand dollars). Until step three of the verification is completed, the withdrawal, tip, or deposit will be held. The user/client will be asked to confirm the origin of the money for step 3.

Identification and Verification of the Customer (KYC)

It is critical to have a formal identification of customers entering into commercial relations to comply with the money laundering regulations and KYC policy. This identification is based on the following fundamental documents — a copy of the passport, ID card, or driving license. Each is shown together with a handwritten note mentioning random six-digit numbers. A second photo with the face of the user/client is also required. To secure their privacy, users/clients may blur out any information besides the date of birth, nationality, gender, first name, second name, and photo. All four corners of the ID shall be visible in the same image, and all details shall be readable. An employee may do additional checks if necessary.

Proof of Address 

An address proof shall be validated via electronic verifications using two different databases. If an electronic test fails, the user/client has an option to submit evidence manually. A recent utility bill sent to your registered address, issued within the last three months, or an official document that proves your residence. To speed up the approval process, please make sure that the paper you submit has high resolution where all four corners of the form are visible and all text is legible. A bank statement, electricity/water bill, or any mail addressed to you by a governmental authority is a good example. An employee has the right to perform additional checks, if necessary, depending on the situation.

Source of Wealth

If a customer deposits over five thousand dollars, there is a process of enquiring about the source of wealth. 

Examples of SOW: 

  • Ownership of a business
  • Employment
  • Inheritance
  • Investments
  • Family Money

The origin and legitimacy of that wealth shall be clearly understood. The account will be frozen if the same user deposits this amount in either one or multiple transactions. Such users will receive an email to go through the above.

Essential info for step one

One can access the sign-up form via the setting page on a casino website. The following information has to be provided by every user:

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

The document will be saved and created by an AI. The personnel may perform additional checks if necessary.

Sanctions, Persons, and Entities of Special Interest, PEPs

The database may be used for screenings of available sanctions. The website is a global database of companies and persons of economic, criminal, or political interest. It combines the most critical sanctions lists, databases of politically exposed persons (PEPs), and other public information. It cross-checks lists and public databases for possible conflicts of interests and signs of illegitimate activity, tracks political conflicts, and compares worldwide sanctions policies, checking potential clients and partners in international dealings.

The database includes sanctions lists, lists of politicians, ban lists used in public procurement, lists of known terrorists, and other data sources relevant to a journalistic investigation. A casino might create a script that incorporates the OpenSanctions search engine on the website to facilitate this database usage. The user will sign up and must add his/her name, residence, and email address. Before he/she moves to the next stage of checks, a script takes the name and scans through the database to ensure that this user is not included in the list. If the result is positive, the user will not be able to enter the casino site.

Risk Management 

A casino will categorize every nation into three different risk regions to deal with the various risks and different states of wealth. 

  • Region one with low risk. The three-step verification described earlier is done for every nation from region one. 
  • Region two with medium risk. Three-step verification will be done at the lower deposit, withdrawal, and tip amounts for every nation from region two. Step number one is a usual one. Step number two will be performed after depositing $1,000 (one thousand dollars), withdrawing $1,000 (one thousand dollars), or tipping another user/client $500 (five hundred dollars.) Step number three will be performed after depositing $2,500 (two thousand five hundred dollars), withdrawing $2,500 (two thousand five hundred dollars), or tipping another user/client $1,000 (one thousand dollars). The users from a low-risk region that exchange cryptocurrency like BTC or ETH for any other currency will be treated like users/clients from a medium-risk region. 
  • Region three with high risk. Regions of high risks will be banned. 

Additional Measurements

Besides, an AI overseen by the AML Compliance Officer will examine any unusual behavior and immediately report it to the Gamdom Casino personnel. Considering risk and general experience, the human personnel will revise all checks that have earlier been performed by the AI or other personnel and may redo or do additional reviews according to the circumstances.

Enterprise-Wide Risk Assessment 

To define and realize risks peculiar to an online casino and its business lines, some operators have performed an AML “Enterprise-Wide Risk Assessment” (EWRA). The AML risk policy is figured out after identifying and documenting the risks associated with its business lines such as the website’s services. These include clients to whom the services are offered, transactions performed by these clients, the channels of delivery used by the bank, the geographic locations of the bank’s operations, and other qualitative and emerging risks. The AML risk categories are classified based on the knowledge of the regulatory requirements, expectations, and industry guidance. Generally, the EWRA is revised every year.

On-Going Transactions Monitoring 

AML-compliance ensures that an “ongoing transaction monitoring” is conducted to detect unusual or distrustful transactions compared to the customer profile. 

1) First Line of Control

Gamdom team ensures that a casino cooperates only with reliable Payment Service Providers, which have well-established and effective AML policies to prevent doubtful deposits from taking place on our site without proper KYC procedures implemented. 

2) Second Line of Control

A casino operator makes its network aware that any contact with the client or player or authorized representative must cause the examination of due diligence on transactions on the account. 

Three-step verification with improved risk management should give all critical data about all clients of a casino at all times. All transactions must also be examined by personnel supervised by the AML Compliance Officer, who is, in turn, supervised by the general management. Determining the unusual nature of one or more transactions’ depends on a subjective evaluation concerning the customer’s knowledge (KYC), their financial behavior, and the transaction counteragent. The transactions for which it is complicated to obtain an adequate understanding of the legal activities and origin of funds must be considered atypical (as they are not directly lawful). Any casino personnel member should inform the AML division of any atypical transactions that they observe and cannot refer to a client’s legal activity or source of income. 

3) Third Line of Control

Online casinos’ managers do manual checks on all suspicious and high-risk users in order to completely prevent money laundering as a last line of defense against AML.

Reporting Suspicious Transactions at Online Casino

The internal procedures of a casino shall describe when it is necessary to report and proceed with such reporting. According to the methodology described in the internal policies, reports of atypical transactions shall be analyzed by the AML team.

Depending on the result of this survey and based on the data obtained, the AML team:

  • will decide whether it is necessary or not to send a report to the FIU, under the legal obligations provided in the Law of 18 September 2017;
  • will decide whether or not it is necessary to terminate the business relations with the client.


The AML regulations, including minimum KYC standards, will be adapted into operational instructions available on a gambling portal.

Keeping Records 

Records of data collected for the identification purpose should be kept for at least ten years after the business relationship has ended. Records of all transaction data should be kept for at least ten years after performing the transactions or the end of the business relationship.


The best casinos use advanced AI and machine learning to improve the AML defense. Highly qualified developers permanently improve the AI to prevent any security problems. While at the same time, the human personnel will check and supervise the AI all the time and perform the manual control of a risk-based approval for which they get special training. Training program content will be adapted to the kind of business the trainees are working for and the posts they hold.


The internal audit establishes reports about AML activities.

Data Security

All data provided by any user/client shall be kept secure, will not be sold or submitted to anyone else. Only if envisaged by law or for preventing money laundering, data may be shared with the AML authority of the affected state. team also watches after a casino whether it follows all rules and guidelines of the data protection directive (Directive 95/46/EC).

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