1. Introduction
Caxino is committed to preventing all forms of money laundering, terrorist financing, and other financial crimes in accordance with applicable laws and regulations. This Anti-Money Laundering (AML) Policy outlines the procedures, controls, and internal frameworks in place to detect, report, and deter suspicious activity on our online casino platform.
2. Purpose of the Policy
The primary objectives of this AML Policy are to:
- Prevent Caxino from being used as a platform for criminal activity
- Comply with all relevant AML/CFT legislation in New Zealand and internationally
- Establish robust internal controls and procedures to identify and report suspicious transactions
- Promote a culture of AML awareness and compliance within the organization
3. Legal Framework
Caxino adheres to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) of New Zealand, as well as relevant international standards, including those set by the Financial Action Task Force (FATF).
4. Customer Due Diligence (CDD)
We apply strict Customer Due Diligence (CDD) procedures to verify the identity of all customers before allowing them to deposit or withdraw funds.
a. Identification Requirements:
Customers must provide:
- Full name
- Date of birth
- Residential address
- Valid government-issued identification (passport, driver’s license, etc.)
- Proof of address (utility bill, bank statement, etc., not older than 3 months)
b. Enhanced Due Diligence (EDD):
EDD is applied in higher-risk scenarios, such as:
- High-value transactions
- Customers from high-risk jurisdictions
- Politically Exposed Persons (PEPs)
- Complex ownership structures
5. Ongoing Monitoring
Caxino monitors all customer activity continuously to detect anomalies, suspicious behavior, or patterns consistent with money laundering.
Examples of monitored behavior:
- Frequent deposits and withdrawals with no gameplay
- Use of multiple accounts
- Use of third-party payment methods
- Irregular transactions inconsistent with a player’s profile
Automated systems are used in conjunction with manual reviews to flag unusual activity for investigation.
6. Record Keeping
Caxino securely retains all AML-relevant documents and data for a minimum of 7 years, including:
- Customer identification documents
- Account and transaction history
- Communication logs
- Internal investigation records
These records may be disclosed to law enforcement or regulatory authorities when required by law.
7. Reporting Obligations
a. Suspicious Activity Reports (SARs):
Caxino files SARs with the New Zealand Financial Intelligence Unit (FIU) when there is reasonable suspicion of money laundering or terrorist financing.
b. Threshold Transactions:
Transactions exceeding NZD $10,000 (or equivalent in other currencies) in a single or related operation are subject to review and may be reported.
8. Staff Training
All employees at Caxino, especially those involved in customer interaction, finance, and compliance, receive mandatory AML training upon hiring and at regular intervals thereafter. Training covers:
- Understanding money laundering and terrorist financing
- Identifying red flags
- How and when to escalate suspicious activity
- Legal and regulatory obligations
9. AML Compliance Officer
Caxino has appointed a qualified AML Compliance Officer responsible for:
- Overseeing the implementation of AML procedures
- Ensuring regulatory compliance
- Handling internal reports and filing SARs
- Liaising with authorities and regulators
- Conducting regular audits and risk assessments
For any AML-related concerns, contact the Compliance Officer via [email protected].
10. Risk-Based Approach
Caxino follows a Risk-Based Approach (RBA) to assess and manage the risks associated with different customers, transactions, and geographic locations. This allows us to apply appropriate levels of scrutiny where the risk is greatest.
11. Prohibited Activities
Caxino prohibits the following:
- Use of false or stolen identity documents
- Deposits or withdrawals by third parties
- Use of anonymous or prepaid accounts without verification
- Transfers from sanctioned countries or blacklisted entities
12. Sanctions Compliance
Caxino conducts screening against international sanctions lists, including:
- United Nations Sanctions List
- OFAC (Office of Foreign Assets Control) Sanctions List
- EU and UK Sanctions Lists
Users associated with sanctioned individuals, entities, or jurisdictions will be restricted or banned immediately.
13. Policy Review
This AML Policy is reviewed at least annually or whenever there are significant changes in the legal, regulatory, or business environment. Updates will be communicated internally and published on our website where applicable.
14. Contact
For questions or reports related to AML compliance, contact:
Caxino Compliance Team
📧 Email: [email protected]
🏢 Address: 193 Bond Street, West Invercargill, Invercargill 9879, New Zealand
