AML/CFT Anti-Money-Laundering and Countering Financing of Terrorism policy of

Introduction: is a brand name of BestYolo B.V., having its registered address at Pareraweg 45 , Willemstad, Curacao. Licensed to conduct online gaming operations by the Government of Curacao under license 1668/JAZ. Official registration number 149847.

Objective of the AML/CFT Policy: We seek to offer the best security to all of our users and customers on for which a three-step account verification is done regularly of our customers and the reason behind this is to prove that the details of the person registered is actually correct and the deposit methods used are not stolen or being used by someone else, which is to establish the general framework for the fight against money laundering. We also take into account nationality, the method of payment and the method of withdrawing so that different safety measurements must be made. also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means. is committed to high standards of anti-money laundering (AML) compliance and requires management & employees to adhere to these standards in preventing the use of its services for money laundering purposes.

The AML/CFT program of is designed to be compliant with:

  • EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
  • EU : “Regulation 2015/847 on information accompanying transfers of funds”
  • EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
  • BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash”

Definition of money laundering:

Money Laundering means:

  • The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;
  • The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
  • The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
  • Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for

In accordance with the AML legislation, has appointed the “highest level” for the prevention of ML : Both general managers of Dota2BestYolo are in charge. Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System. (temporally Mr. Huy Duong with support of the Legal Department). The AMLCO is placed under the direct responsibility of the general manager:

AML policy changes and implementation requirements:

Each major change of AML policy is subject to be approved by the general manager of Dota2BestYolo and the Anti-money laundering compliance officer.

Three-step Verification:

Step one verification:

Step one verification must be done by every user and customer to withdraw. Regarding the choice of payment, the amount of payment, the amount of withdrawing, the choice of withdrawing and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender and full address.

Step two verification:

Step two verification must be done by every user which deposits over 2000€ (two thousand euros) or withdraws over 2000€ (two thousand euros) or sends another user over 1000€ (one thousand euros) Until step two verification is done the withdraw, tip or deposit will be held. Step 2 verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different. There will also be an electronic check if the filled-in data from the step one verification is correct. The electronic check will check via two different databanks to ensure the given information matches with the filled document and the name from the ID. If the electronic test fails or is not possible the user/customer is required to send in confirmation of his/her current residence. A certificate of registration by the government or a similar document is required.

Step three verification:

Step three verification must be done by every user which deposits over 5000€ (five thousand euros) or withdraws over 5000€ (five thousand euros) or sends another user over 3000€ (three thousand euros) Until step three verification is done the withdraw, tip or deposit will behold. For step 3 a user/customer will be asked for a source of wealth.

Customer identification and verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy. This identification relies on the following fundamental principles : A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning the six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides the date of birth, nationality, gender, first name, second name and the picture to secure their privacy. Please note that all four corners of the ID have to be visible in the same image and all details shall to be readable. An employee may do additional checks if necessary based on the situation.

Proof of Address:

Proof of address will be done via different electronic checks, which uses two different databases. If an electronic test fails, the user/customer has the option to submit proof manually. A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that prooves your state of residence. To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible, and all text is readable. An electricity bill, water bill, bank statement or any governmental post addressed to you is a good example.An employee may do additional checks if necessary based on the situation.

Source of funds

For step 3 verification, there is a process to understand the source of wealth (SOW)

Examples of SOW are:

  • Ownership of business
  • Employment
  • Inheritance
  • Investment
  • Family

It is critical that the origin and legitimacy of that wealth are clearly understood. The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to the threshold. An email will be sent to them manually to go through the above. also asks for a bank wire/credit card to further ensure the identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

The basic document for step one:

The basic document will be accessible via the setting page on Every user has to fill out the following information:

  • First name
  • Second name
  • Nationality
  • Gender
  • Date of Birth

The document will be saved and created by an AI, an employee may do additional checks if necessary based on the situation.

Sanctions, Persons and Entities of Special Interest as well as PEPS.

The database is used for screenings of open sanctions. The website is a global database of persons and companies of political, criminal, or economic interest. It combines the most important sanctions lists, databases of politically exposed persons and other public information into a single easy-to-access dataset. It cross-checks leeks and public databases for possible conflicts of interests and signs of illicit activity, it tracks political conflicts and compare worldwide sanctions policies and checks potential customers and partners in international dealings. The project includes sanctions lists, lists of politicians, ban lists used in government procurement, lists of known terrorists and other data sources relevant to journalistic research and due diligence.In order to facilitate the use of this database, has created a script that incorporates the OpenSanctions search engine on the website. The user will sign up and must add his/her name, address and email address. Before they move onto the next stage, a script extracts their name and scans this through the database to ensure that they are not a listed person. If the results come back positive, the customer will be given a notice of reason and he/she will be not able to enter the site. However, the customer can dispute that he/she is not the listed person by going through the first 2 steps of verification. will also have a subscription to

Risk management:

In order to deal with the different risks and different states of wealth in different regions on the earth. will categorize every nation in three different regions of risk.

  • Region one - Low risk: For every nation from the region one the three-step verification is done as described earlier.
  • Region two - Medium risk: For every nation from region two the three-step verification will be done at the lower deposit, withdraw and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000€ (one thousand euros), withdrawing 1000€ (one thousand euros) or tipping another user/customer 500€ (five hundred euros.) Step three will be done after depositing 2500€ (two thousand five hundred euros), withdrawing 2500€ (two thousand five hundred euros) or tipping another user/customer 1000€ (one thousand euros).
  • Region three - High risk: Region of high risks will be banned.

Additional measurements

In addition, an Automated Screening Bot which is overseen by the AML compliance officer will look for any unusual behavior and report it right to an on-site admin available at the time. The on-site human admin will recheck all suspicious criteria which are identified by the Automated System and may redo or do additional screening according to the situation.

Enterprise-wide risk assessment

As part of its risk-based approach, has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services its offered, the customers to whom services are offered, transactions performed by these customers, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks. The identification of AML risk categories is based on understanding of regulatory requirements, regulatory expectations and industry guidance. The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML/CFT-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions that are unusual or suspicious compared to the customer profile. This transaction monitoring is conducted on two levels :

1) The First Line of Control: works solely with trusted Payment Service Providers who all have effective AML policies in place as to prevent the large majority of suspicious deposits onto from taking place without proper execution of KYC procedures onto the potential customer.

2) The Second Line of Control: makes its network aware that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular, these include:

  • Requests for the execution of financial transactions on the account;
  • Requests in relation to means of payment or services on the account;

The three-step verification with adjusted risk management should provide all necessary information about all costumers of at all times. Also, all transactions must be overseen by employees supervised by the AML compliance officer who is supervised by the general manager. The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence. Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behavior and the transaction counterparty. The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable). Any staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.

3) The third Line of Control:

As the last line of defense against AML will do manual checks on all suspicious and higher risk users in order to fully prevent money laundering.

Reporting of suspicious transactions on

In its internal procedures, describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting. Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures. Depending on the result of this examination and on the basis of the information gathered, the AML team:

  • will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
  • will decide whether or not it is necessary to terminate the business relations with the customer.

Record keeping

Records of data obtained for the purpose of identification must be kept for at least five years after the business relationship has ended. Records of all transaction data must be kept for at least five years following the carrying-out of the transactions or the end of the business relationship.

Training: uses an advanced automated system and machine learning to further improve our AML defense. Also, trained developers constantly improve the system in order to prevent any security flaws. While at the same time our human employees will check and overlook the system at any time and make manual controls on a risk-based approval for which they get special training. The training and awareness program is reflected by its usage:

  • A mandatory AML training program in accordance with the latest regulatory evolutions
  • Academic AML learning sessions for all new employees
  • The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold.
  • These sessions are given by an AML Compliance Officer, assisted by a Legal Consultant


Internal audit regularly establishes missions and reports about AML activities.

Data Security:

All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state. will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

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