This page sets out the official AML and KYC standards, controls, and procedures applicable to services delivered via betrira.com. It is written to align with E-E-A-T best practices and the high-risk nature of YMYL content. The intent is protective and educational. Nothing herein promotes or facilitates gambling; all references are compliance-oriented. 🔒
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Purpose, Scope, and Governance
The policy aims to prevent and detect money laundering (ML), terrorism financing (TF), fraud, and other financial crimes; to safeguard users and payment systems; and to ensure transparent record-keeping. It applies to all users, visitors, contractors, and employees who interact with identification, onboarding, payments, withdrawals, refunds, and support processes related to betrira.com.
- Oversight: Senior management approves the AML/KYC framework, sets risk appetite, and allocates resources.
- AML Compliance Officer (AMLCO): Responsible for day-to-day implementation, independent monitoring, reporting of suspicious activity, staff training, and policy maintenance.
- Three Lines Model: 1) Operational controls; 2) Compliance monitoring; 3) Periodic internal audit with findings tracking.
Legal and Regulatory Alignment
Controls are benchmarked to internationally recognized standards and supervisory expectations, including:
- EU Directive (EU) 2015/849 and amending measures on preventing misuse of the financial system.
- EU Regulation (EU) 2015/847 on information accompanying transfers of funds (Travel Rule context).
- FATF Recommendations and risk-based approach guidance on CDD, PEPs, sanctions, and new technologies.
- Applicable sanctions programs and restrictive measures concerning persons, entities, and embargoed jurisdictions.
- Data protection obligations consistent with GDPR-style principles of lawfulness, purpose limitation, and security.
Where local laws impose stricter requirements, the stricter control prevails. Nothing in this policy shall be interpreted to allow activity prohibited by applicable law. ⛔
Definition of Money Laundering
Money laundering includes converting, transferring, concealing, or disguising the nature, source, location, disposition, movement, ownership, or rights of property knowing it derives from criminal activity; acquiring or using such property; or aiding, abetting, or conspiring to do so. ML is prosecutable even if the predicate offense occurred in another country.
Risk-Based Approach (RBA)
Controls scale with the inherent and residual risks arising from users, products, delivery channels, and geographies. A documented Enterprise-Wide Risk Assessment (EWRA) is reviewed at least annually or upon material changes. Key dimensions include:
- User Risk: residency, nationality, PEP exposure, occupation, adverse media, and historical behavior.
- Transactional Risk: value/velocity, funding methods, counterparties, and circular or rapid flows.
- Geographic Risk: sanctions lists, high-risk jurisdictions, and correspondent exposures.
- Channel Risk: non-face-to-face onboarding, remote payments, and third-party PSPs.
Illustrative Country Risk Tiers
| Tier | Risk Attributes | CDD Trigger Examples |
|---|---|---|
| Tier 1 (Lower) | Stable AML regime, effective supervision, low corruption perception | Standard KYC; EDD only on alerts or unusual behavior |
| Tier 2 (Medium) | Developing controls, elevated predicate-crime exposure | Earlier document checks; tighter transaction thresholds |
| Tier 3 (High/Restricted) | Sanctions, strategic deficiencies, or embargo | Access limited or blocked; mandatory EDD and senior approval |
Customer Due Diligence (CDD) and KYC
Formal identification is mandatory prior to establishing or continuing any relationship that involves money movement or value storage. Identity is verified using reliable, independent sources. Where digital identity tools are used, liveness and spoof-resistance are required. 😊
Standard KYC (CDD)
- Legal name, date of birth, nationality, and gender.
- Residential address and contact information.
- Verification with one valid government ID (passport, national ID, or driver’s license) with all four corners visible.
- Selfie or live video match, with a short note showing a random 6-digit code for anti-impersonation.
Proof of Address (POA)
- Electronic checks against two independent databases where available.
- If e-checks fail, upload a document issued within the last 90 days: utility bill, bank statement, or government letter.
- Documents must be clear, complete, and readable. Cropped or blurred images will be rejected.
Enhanced Due Diligence (EDD)
- Applied to PEPs, Tier-3 jurisdictions, adverse media, or unusual behavior.
- Obtain Source of Funds (SoF) and, where relevant, Source of Wealth (SoW) evidence: employment income, audited business profits, investments, inheritance, or verifiable family transfers.
- Senior management approval may be required for onboarding or continuation.
Three-Step Verification Thresholds
Thresholds reflect typical AML practice and may be adjusted by risk. Transactions can be held pending completion of the required step.
- Step 1 – Basic Profile & ID capture prior to any withdrawal. Required data: legal name, date of birth, usual residence, gender, and full address.
- Step 2 – Documentary verification if cumulative deposits or withdrawals exceed USD 2,000. Includes government ID and address checks.
- Step 3 – SoF/SoW when deposits exceed USD 5,000 or transfers exceed USD 3,000 equivalent. Account may be frozen until satisfactory review.
Users should use the same method for withdrawals as for deposits up to at least the deposited principal to mitigate layering risks.
Ongoing Monitoring
Transactions are monitored against the expected user profile. Automated analytics and case-management tools generate alerts based on patterns such as:
- Rapid deposit-withdrawal cycles without legitimate activity.
- Third-party funding, card-mismatch, or repeated payment instrument changes.
- Frequent currency switching without economic rationale.
- Nationality, location, or device fingerprint anomalies.
Alerts are reviewed by trained analysts, escalated to AMLCO if warranted, and documented with a complete audit trail. Where suspicion persists, a Suspicious Activity/Transaction Report (SAR/STR) may be filed with competent authorities, subject to applicable law. 🚨
Sanctions, PEP, and Adverse Media Screening
- Real-time screening against consolidated sanctions lists (e.g., UN, EU, OFAC), PEP lists, and watchlists at onboarding and periodically thereafter.
- Hits trigger manual review and, where applicable, denial or termination of access.
- Adverse media monitoring helps identify hidden risks related to fraud, corruption, or organized crime.
Record-Keeping and Data Protection
- Identification and transaction records are retained for at least 10 years after the end of the business relationship or transaction date, as permitted by law.
- Data are stored securely with encryption, access controls, need-to-know segregation, and tamper-evident logs.
- Personal data are processed under lawfulness, fairness, purpose limitation, and minimization principles. Users may exercise applicable privacy rights subject to AML retention obligations.
Reporting, Tipping-Off, and Confidentiality
- Employees must promptly escalate unusual or suspicious activity to Compliance. Silent monitoring prevents “tipping-off.”
- Where required, SAR/STR filings are confidential and must not be disclosed to the subject.
- Law-enforcement requests are handled through authenticated channels only.
Controls over Cash, Cards, and Digital Assets
- Only payment methods owned by the verified user are accepted. Third-party or anonymous methods are prohibited.
- Card-not-present safeguards include 3-D Secure where available. Repeated declines or mismatches are investigated.
- If digital assets are supported, Travel-Rule-compatible information sharing, blockchain analytics, and risk scoring apply.
Training and Awareness
- Mandatory induction training for new staff covering CDD, EDD, sanctions, SARs, and data protection.
- Annual refreshers and ad-hoc briefings when regulations or risks evolve.
- Role-specific modules for support, risk, engineering, and product teams with scenario-based exercises. 🎓
Independent Testing and Audit
- Periodic internal audit evaluates design and operating effectiveness of AML/KYC controls, sample reviews alerts and SARs, and verifies remediation.
- Key performance and risk indicators are reported to senior management and, where applicable, the board.
Change Management and Versioning
Material policy changes require senior approval and are recorded in a change log indicating rationale, effective date, and impacted procedures. Users may be notified where changes affect their rights or obligations. The policy is reviewed at least annually. 📅
User Responsibilities
- Provide accurate, complete, and up-to-date identification information and promptly respond to Compliance queries.
- Use only personal, legitimate funding sources; do not process payments for others.
- Avoid high-risk behavior such as structuring, circular withdrawals, or multi-accounting.
Illustrative Threshold Table
| Control | Typical Trigger | Documentation | Possible Action |
|---|---|---|---|
| CDD (Step 1) | Account creation / pre-withdrawal | Gov-ID + selfie, basic profile data | Enable standard access |
| Document Check (Step 2) | ≥ USD 2,000 cumulative in/out | ID verification + Proof of Address | Hold transactions pending review |
| SoF/SoW (Step 3) | ≥ USD 5,000 deposits or ≥ USD 3,000 transfers | Payroll, bank statements, inheritance, investment proofs | Freeze until satisfactory evidence |
| Sanctions/PEP | Onboarding and periodic | Screening hits and adjudication | Reject or continue with EDD |
Prohibited and Restricted Activity
- Use of stolen or synthetic identities, forged documents, or non-self payment instruments.
- Payments on behalf of third parties or to anonymizing services designed to obscure provenance.
- Interactions with sanctioned persons or entities and activity involving embargoed jurisdictions.
Complaints and Contact
Questions about this AML/KYC Policy, reports of suspicious activity, or privacy concerns can be submitted to:
- Email: [email protected]
- Abuse/Security: [email protected]
Please include a clear description, relevant timestamps, and supporting evidence. We will acknowledge receipt and respond consistent with our compliance obligations. ✅
Final Notice
This policy is protective, not promotional. If any provision is found inconsistent with applicable law, the lawful, stricter interpretation prevails. Users are responsible for complying with the laws of their jurisdiction. Continued use of betrira.com signifies acceptance of these terms and cooperation with AML/KYC requests. 🤝