AML Policy
1. Policy Overview
Betzillo is fully committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all operations.
This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy outlines the internal controls, risk-based measures, and due diligence procedures implemented to prevent the misuse of our platform for money laundering, terrorist financing, or any form of illicit activity.
The Policy is designed in accordance with international AML/CTF standards, including the recommendations of the Financial Action Task Force (FATF), applicable Curaçao regulations, and relevant national laws.
2. Purpose and Scope
This Policy applies to all Betzillo employees, partners, contractors, and account holders.
Its purpose is to:
Ensure compliance with AML/CTF laws and licensing obligations.
Establish effective procedures for identifying, monitoring, and mitigating risks associated with suspicious or illegal activities.
Protect Betzillo and its customers from fraudulent, criminal, or reputational harm.
3. Governance and Oversight
3.1 Money Laundering Reporting Officer (MLRO)
Betzillo has appointed a qualified Money Laundering Reporting Officer (MLRO) responsible for overseeing the implementation and ongoing effectiveness of this Policy.
The MLRO’s duties include:
Reviewing and verifying KYC documentation.
Monitoring player transactions and activity patterns.
Investigating and reporting suspicious activities to the Financial Intelligence Unit (FIU) or other competent authorities.
Maintaining AML/CTF records and ensuring timely reporting.
Training relevant staff on AML/CTF obligations and procedures.
The MLRO acts as the primary liaison between Betzillo and external regulators, financial institutions, and law enforcement bodies.
4. Risk Management Framework
Betzillo employs a risk-based approach to identify and manage potential AML/CTF threats. Each player is assessed based on multiple risk factors, including jurisdiction, transaction behavior, source of funds, and game activity.
Risk Classification
Low Risk:
Players subject to standard due diligence and continuous monitoring.High Risk:
Players exhibiting irregular or suspicious behavior are escalated for Enhanced Due Diligence (EDD).
Betzillo’s systems use automated and manual monitoring to detect anomalies, generate alerts, and ensure prompt review.
5. Know Your Customer (KYC) and Customer Due Diligence (CDD)
5.1 Identification and Verification
Before any financial activity is permitted, Betzillo verifies the identity of all customers. Registration requires:
Full legal name and residential address.
Date of birth and proof of age (18+).
Government-issued identification (passport, ID card, or driver’s license).
Proof of address (utility bill or bank statement).
Valid email address and payment method details.
Players must have only one verified account. Shared accounts or duplicate registrations are prohibited.
5.2 Ongoing Monitoring
KYC verification is not a one-time process. Betzillo continuously monitors transactions to detect unusual or suspicious activity, such as large deposits, minimal play, or frequent withdrawals.
Where inconsistencies or risk indicators are detected, Betzillo reserves the right to:
Request additional documentation.
Suspend or terminate the account.
Report the case to relevant authorities.
6. Enhanced Due Diligence (EDD)
EDD procedures apply to high-risk accounts or activities, including:
Players from high-risk or non-cooperative jurisdictions.
Politically Exposed Persons (PEPs).
Complex or unusually large transactions.
Suspicious betting patterns or account behavior.
EDD measures may include verifying source of funds, additional ID documents, video verification, or proof of wealth. Accounts may remain suspended until verification is completed satisfactorily.
7. Monitoring and Detection
Betzillo employs automated systems and manual reviews to track account activity in real-time.
Red flags include:
Irregular betting behavior or minimal play after large deposits.
Multiple accounts under different names or IP addresses.
Use of VPNs or logins from high-risk jurisdictions.
Cryptocurrency transactions inconsistent with gaming activity.
Detected anomalies trigger immediate investigation and, where required, escalation to the MLRO for formal review.
8. Cryptocurrency Transactions
Betzillo supports cryptocurrency transactions under strict AML/CTF controls:
The first deposit determines the transaction currency (all subsequent activity must use the same currency).
Cryptocurrency is not convertible to fiat through Betzillo.
Player identity, address, and age must be verified prior to any crypto transaction.
Wallet ownership and fund sources may be verified for authenticity.
Exchange rates are transparently displayed on the platform.
Funds deposited and withdrawn must originate from and return to the same verified wallet.
9. Reporting and Recordkeeping
Betzillo maintains detailed records of all customer identification, transaction history, and AML investigations for a minimum of five (5) years after the business relationship ends.
Records include:
Customer KYC data.
Transaction logs.
Internal reports and investigations.
Documentation of suspicious activity reports (SARs).
Any transaction deemed suspicious or unverifiable will be reported by the MLRO to the Financial Intelligence Unit (FIU) in accordance with Curaçao AML regulations.
10. Staff Training and Integrity
All Betzillo employees undergo AML/CTF training at onboarding and at regular intervals thereafter. Training ensures staff understand how to recognize, report, and prevent money laundering or terrorist financing activities.
Additionally, Betzillo conducts internal due diligence on staff members to maintain integrity and prevent internal risk exposure.
11. Policy Review and Continuous Improvement
This Policy is reviewed periodically by the MLRO and executive management to ensure compliance with evolving laws, best practices, and regulatory updates.
Betzillo reserves the right to amend this Policy as necessary to align with legal or operational requirements.