AML Policy
1. INTRODUCTION
D1CE ("we," "our," or "D1CE"), as a globally recognized and reputable entity in the gambling sector, strictly opposes, prohibits, and rejects the misuse of its platform and services for any illegal activities, including but not limited to money laundering, terrorism financing, and other forms of financial crimes.
We are fully committed to complying with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, ensuring that our platform remains secure, transparent, and in full compliance with international standards.
2. WHAT IS MONEY LAUNDERING AND TERRORISM FINANCING?
Money Laundering – Money laundering refers to the process by which individuals or entities disguise the origins of illicit funds obtained through criminal activities, in order to make them appear legitimate. The process typically involves three stages: (a) Placement: Introducing illicit funds into the legitimate financial system. (b) Layering: Conducting complex and often opaque transactions to obscure the origin of the funds, making detection more difficult. (c) Integration: Reintroducing the funds into the economy as legitimate assets or income.
Terrorism Financing – Terrorism financing refers to the collection, provision, or transfer of funds intended to support terrorist activities, either directly or indirectly.
3. HOW DO WE FIGHT IT?
D1CE has implemented a comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) program, structured around the following key areas:
(a) Internal Policies & Procedures We maintain and regularly update internal policies and procedures designed to detect, prevent, and report money laundering and terrorist financing activities.
(b) Know Your Customer (KYC) We implement robust KYC procedures to verify the identity of our customers and ensure that they are not engaged in illicit activities. This process includes gathering and verifying information about customers' identities, sources of funds, and other relevant details.
(c) Transaction Monitoring We use advanced systems to monitor customer transactions in real-time. This helps us detect and investigate any suspicious activity promptly and take appropriate action when necessary.
(d) Governance & Training Our staff members undergo regular training on AML and CTF compliance to ensure they are well-equipped to identify and address potential risks. We also maintain a governance framework that oversees our compliance program and ensures Accountability.
(e) Reporting D1CE is committed to fulfilling all regulatory reporting obligations. We report any suspicious activity to the relevant authorities in accordance with applicable laws and regulations, ensuring full cooperation with law enforcement agencies.
(f) Restricted Territories D1CE prohibits users residing in restricted territories, as outlined in the Terms of Service, from accessing any platform services. This restriction ensures compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations in high-risk or prohibited jurisdictions. Transactions or activities originating from restricted territories will be flagged and reported to the relevant authorities.
Through these measures, D1CE remains committed to maintaining the integrity of its platform and contributing to the fight against money laundering and terrorism financing.
4. KNOW YOUR CUSTOMER (KYC)
D1CE enforces rigorous due diligence and KYC procedures to verify customer identities and assess potential risks. These measures are applied during the registration process and throughout the customer’s ongoing relationship with us, including:
(a) Identity Verification We collect official documents (e.g., passport, driver’s license) to confirm the Player's name, date of birth, and address. This process ensures that the individual is who they claim to be.
(b) PEP and Sanctions Screening We screen Players to determine whether they are classified as Politically Exposed Persons (PEPs) or are listed on international sanctions lists. This helps us mitigate risks associated with high-profile individuals and those subject to sanctions.
(c) Source of Funds Checks When necessary, we request proof of income or wealth to ensure that transactions are legitimate and in compliance with applicable laws. This process ensures that funds used for gambling activities come from lawful sources.
(d) Notification and Grace Period Users who fail to comply with KYC requirements will receive written notification via email, detailing the required actions and providing a grace period of 14 days to resolve the issue.
If the issue remains unresolved after the grace period, the Account will be suspended or closed in accordance with AML regulations. In cases of suspected fraud, criminal activity, or other high-risk behavior, D1CE reserves the right to suspend Accounts immediately without prior notice.
Failure to comply with KYC requirements may result in Account suspension or closure. D1CE reserves the right to request additional documentation or conduct further checks if necessary.
5. ENHANCED DUE DILIGENCE (EDD)
In addition to standard KYC measures, D1CE applies Enhanced Due Diligence (EDD) procedures to address higher-risk situations, including but not limited to:
(a) Identifying High-Risk Customers
Customers residing in high-risk jurisdictions identified by international bodies such as the FATF.
Politically Exposed Persons (PEPs) and their close associates.
Customers conducting transactions above a specified threshold or exhibiting unusual patterns.
(b) Collecting Additional Information For high-risk customers or transactions, we may request:
Detailed source of funds and source of wealth information.
Proof of recent income (e.g., salary slips, bank statements).
Enhanced verification documents, such as notarized IDs or utility bills.
(c) Continuous Monitoring
Real-time transaction monitoring for flagged Accounts.
Regular reviews of high-risk Accounts, including periodic updates of KYC details.
Escalation of suspicious activity to the Money Laundering Reporting Officer (MLRO) for immediate investigation.
(d) Approval by Senior Management
High-risk Accounts, including those flagged through EDD processes, require approval by senior compliance officers or management prior to Account activation or continuation of services.
(e) Enhanced Record-Keeping
All EDD documentation and findings are retained for at least 10 years, in compliance with applicable regulations, and are made available for audits or regulatory inquiries.
6. TRANSACTION MONITORING
D1CE utilizes advanced transaction monitoring systems, combining automated tools and manual reviews to analyze Player activities. These systems are designed to:
(a) Identify Unusual Transaction Patterns: The system detects transaction patterns that may indicate suspicious activities, including those typically associated with money laundering or terrorism financing.
(b) Flag High-Risk Transactions: High-risk transactions are flagged for further investigation, ensuring that any potential threats are thoroughly reviewed.
(c) Report Suspicious Transactions: Confirmed suspicious transactions are reported to the appropriate authorities, in compliance with regulatory obligations and legal requirements.
We continuously refine and improve our transaction monitoring systems to adapt to emerging threats and evolving regulatory changes, ensuring a secure and compliant platform for all Users.
7. GOVERNANCE & TRAINING
D1CE has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for overseeing the AML/CTF program. The MLRO's duties include:
(a) Ensuring Compliance: Ensuring the company’s operations comply with all legal and regulatory obligations related to anti-money laundering (AML) and counter-terrorist financing (CTF).
(b) Developing and Updating Procedures: Continuously developing, updating, and enhancing internal AML/CTF procedures to stay aligned with evolving laws, regulations, and industry best practices.
(c) Investigating Suspicious Activities: Investigating any suspected suspicious activities and submitting reports to the relevant authorities when required, in accordance with regulatory standards.
(d) Evaluating AML Controls: Regularly evaluating the effectiveness of the company’s AML and CTF controls through audits and reviews to ensure their robustness and efficiency.
We are committed to fostering a culture of compliance and ensuring that our employees are well-equipped to detect and report suspicious activities. To support this, we provide mandatory annual AML/CTF training programs for all employees, ensuring they remain well-informed of the latest compliance requirements and are capable of performing their duties effectively.
8. ADDRESSING EMERGING THREATS
D1CE recognizes the evolving nature of money laundering and terrorism financing risks, including the misuse of emerging technologies such as cryptocurrencies. To address these challenges, we:
(a) Monitor and assess trends in cryptocurrency-related money laundering activities.
(b) Implement specialized tools to track, trace, and analyze blockchain transactions where cryptocurrencies are used.
(c) Collaborate with international organizations and regulatory bodies to stay updated on best practices and regulations for combating cryptocurrency-related financial crimes.
9. REPORTING & COLLABORATION
D1CE is fully committed to cooperating with regulatory authorities, law enforcement agencies, and other relevant entities in investigations related to money laundering, terrorism financing, and other illicit activities. We prioritize transparency and compliance, ensuring that all required reports are submitted in a timely manner and that we actively support efforts to investigate and prevent illegal activities. Our collaboration with authorities is integral to maintaining the integrity of our platform and protecting the broader financial ecosystem.
10. PERIODIC REVIEW
D1CE conducts periodic reviews and audits of its AML/CTF program to ensure:
(a) Compliance with the latest legal and regulatory changes.
(b) Effectiveness of internal policies and procedures.
(c) Identification of areas for improvement to adapt to emerging risks.
Last updated