Introduction
Fg66 maintains an anti money laundering and countering the financing of terrorism (AML/CFT) program for all services offered on the platform. This policy governs all customer interactions, account management activities, and commercial arrangements across on-boarding, ongoing supervision, and reporting. The objective is to prevent illicit activity while enabling legitimate gaming operations in a compliant, transparent manner.
Scope
This policy applies to all products and services provided by Fg66, including online casino offerings, live services, sports betting, payments, and related technology platforms. It covers customer on boarding, account management, transaction processing, identity verification, risk assessment, and cooperation with the relevant authorities.
Regulatory Framework and Compliance Authority
Fg66 operates under applicable AML/CFT laws and guidance in the jurisdictions where it offers services. The compliance program integrates risk based controls, suspicious activity reporting, and regulatory monitoring in line with recognized international standards. The Compliance Officer leads the program and reports to the Board on material AML/CFT matters.
Governance, Roles and Responsibilities
The governance structure assigns responsibilities for AML/CFT to the Board, the Compliance Officer and the risk management function. Key duties include policy approval, risk evaluation, control design, monitoring, audit coordination, and the timely escalation of issues. Staff at all levels must understand their obligations, participate in training, and promptly report concerns to the Compliance Officer.
- Board of directors: approves AML/CFT policies, monitors risk and resources, and oversees overall program effectiveness.
- Compliance Officer: develops and maintains policies, conducts risk assessments, delivers training, and supervises monitoring and reporting.
- Internal Audit: conducts independent reviews to verify compliance and remediate deficiencies.
Risk Based Approach
Fg66 applies a risk based framework to identify, assess, and mitigate money laundering and terrorist financing risks. The framework considers customer base, product structure, channels of delivery, and geographic considerations. Risk is reviewed on onboarding and revisited at regular intervals or upon significant change in the business environment.
- Customer risk: evaluation based on identity, source of funds, expected activity, and geography.
- Product risk: different gaming products carry distinct risk profiles that require tailored controls.
- Geographic risk: jurisdictions with heightened risk receive enhanced monitoring or are restricted as applicable.
- Third party risk: diligence applied to payment processors and vendor relationships.
Customer Due Diligence (CDD) and Verification
On registration, customers must provide verifiable information to establish identity and assess risk. Verification methods include automated identity verification, document checks, and manual review when necessary. Sanctions screening is performed on all new and existing customers where applicable. Customer data are retained for regulatory purposes and auditability.
- Collected information: full legal name, date of birth, residential address, nationality, and government issued identification.
- Onboarding verification: automated checks augmented by human review for flagged cases.
- Sanctions screening: against recognized lists to identify prohibited or restricted individuals or entities.
- Ongoing monitoring: periodic reviews of customer profiles and activity patterns.
- Record retention: strict holding periods are maintained per legal requirements, typically not less than five years after the end of the business relationship.
Enhanced Due Diligence (EDD)
High risk customers and transactions are subject to enhanced due diligence. Measures include deeper source of funds verification, verification of beneficial ownership where relevant, biometric identity checks, enhanced monitoring, and frequent reviews. Decisions to apply EDD are documented and reviewed by the Compliance Officer.
Transaction Monitoring and Investigation
Fg66 maintains real time transaction monitoring to identify unusual or suspicious patterns. Monitoring considers transaction size, frequency, velocity, and deviations from expected customer behavior. Alerts trigger further analysis by the Compliance team, including review of KYC data, historical activity, and external data sources such as blockchain analytics for crypto related activity. Suspicious activity is escalated for investigation and, where appropriate, reported to the relevant authorities in accordance with law. All actions are logged for audit purposes.
- Cryptocurrency transactions: monitored with blockchain analytics and enhanced due diligence when warranted.
- Escalation: structured investigations may involve clarifying questions to the customer and obtaining additional documentation.
- Reporting: suspected illicit activity is reported in accordance with regulatory requirements.
Sanctions, PEPs and Prohibited Jurisdictions
Fg66 screens customers and transactions against applicable sanctions and politically exposed persons lists. In cases of potential matches, the account is blocked or restricted pending further investigation. Enhanced due diligence or refusal may be applied based on risk assessment. False positives are managed through manual review to confirm matches before any action is taken.
Third-Party and Vendor Oversight
Due diligence and ongoing monitoring apply to third party service providers and payment processors. Contracts incorporate AML/CFT requirements and audit rights. Vendor risk is reviewed as part of the overall risk management framework and is updated in response to regulatory or business changes.
Data Retention and Record Keeping
All AML/CFT records, including KYC information, risk assessments, due diligence documents, and monitoring logs, are retained for a minimum period of five years or longer if required by law. Records are stored securely with access limited to authorized personnel and protected by appropriate technical controls.
Education and Training
Fg66 provides ongoing AML/CFT training to all employees. Training covers regulatory obligations, identification of red flags, escalation procedures, and specific procedures for complex scenarios. Onboarding training is complemented by annual refreshers and role specific programs for Compliance, Risk, and Customer Services units. Training records are maintained for audit and regulatory review.
Reporting and Cooperation with Authorities
All staff are required to report suspicious activity promptly to the Compliance Officer. The Compliance Officer coordinates internal escalation, prepares essential documentation, and submits Suspicious Activity Reports or equivalent notifications to the appropriate authorities as required by law. Co operation with investigators is provided as part of the regulatory framework and internal procedures.
Record of Violations and Corrective Action
Any identified AML/CFT control deficiencies are documented, assessed, and remediated through timely corrective actions. The Board and Compliance Officer oversee corrective programs and track outcomes until closure.
Continuous Improvement
The AML/CFT program is reviewed on an annual basis and more frequently in response to regulatory changes, new products, or material changes in risk. Changes to policies and procedures are communicated to all staff and implemented with updated training materials where required.