AML & KYC policy

1. Objective and scope of the policy
The purpose of this AML & KYC Policy or Policy on The Prevention of Laundering Proceeds of Crime and Financing of Terrorism and Know your Customer procedures is:
- To obtain information and develop employee awareness on the prevention of laundering proceeds of crime and financing of terrorism,
- To comply with the obligations regarding local regulations,
- To evaluate customers, transactions and services offered with a risk based approach
and to mitigate those risks.
This policy shall be composed of the following measures:
- Know your customer principle
- Monitoring and control activities
- Suspicious transaction reporting
- Training
- Internal audit
2. Cleo.bet guarantee
All Users of Cleo.bet sites ensure by accepting this Policy and Terms & Conditions at least the following:
a) The User has completed the registration form truthfully and correctly.
b) The User is not an individual under 18 years old or other legal age of majority in
User's jurisdiction.
c) The User is neither under legal supervision nor restricted in his business activities.
d) The User has registered personally and not on the behalf of someone else.
e) The User uses the account for personal use and has no commercial intentions.
f) The User has no knowledge about any bet result of the underlying bet before
placing it.
g) The User does not have multiple accounts on website.
h) The User has read and accepted this Policy.
i) The User cannot sell, transfer, assign and/or acquire by any other means the
accounts to/from other Users.
j) The User assures that he/she won’t use his/her account to transfer funds amongst his/her accounts
3. Know your customer (KYC) procedures
Both international and local regulations require "Cleo.bet" to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
4. Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (CDD). According to CDD, Cleo.bet establishes its own verification procedures
within the standards of anti-money laundering and “Know Your Customer” frameworks.
Cleo.bet identity verification procedure requires the User to provide Cleo.bet with reliable, independent source documents, data or information (e.g., national ID, international passport, high-quality photo or selfie, driving license, bank statement, utility bill).
Cleo.bet will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Cleo.bet reserves the right to investigate certain

Users who have been determined to be risky or suspicious as stated at the present T&C below.
Cleo.bet reserves the right to verify User’s identity in an on-going basis, especially when their activity seemed to be suspicious (unusual for the particular User). In addition, Cleo.bet reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared and protected strictly in accordance with the Cleo.bet Privacy Policy and related regulations including European Data Protection Regulations.
Once the User’s identity has been verified, Cleo.bet is able to remove itself from
potential legal liability in a situation where its Services are used to conduct illegal activity.
5. Know your customer (KYC)
After registration process the User shall provide Cleo.bet with valid identification information under these Know Your Customer (KYC) procedures. The User shall undergo KYC procedure after completing the registration of User’s Account and:
a) Before first withdrawal of funds irrespective of the amount;
b) In case of a deposit for the sum equal to or exceeding 2000 euros or its equivalent
in virtual currency;
c) In case of depositing in amount of 7 500 euros (or its equivalent in virtual currency)
or more (by several installments) by the same User during a month.
During the User’s KYC process an individual User provides the following identification information to the Company:
- User's full name (first name and last name);
- Country of residence/location of customer;
After receiving the identification information the Compliance officer or third party affiliated with Cleo.bet and entitled to perform KYC check should verify this information requesting the appropriate documents. Appropriate documents for verifying the identity of User include, but are not limited to, the following:

a) A high resolution scanned copy or photo of pages of a passport or any other national ID, indicating family name and name(s), date and place of birth, passport number, issue and expiry dates, country of issue and User’s signature;
b) A clear and high resolution photo of the User or selfie.
Users can be requested by Cleo.bet to undergo detailed KYC procedure under the present Policy before their first deposit that is lower than 2000 euros or its equivalent if such requirement is essential for processing payments through certain payment providers/institutions/banks.
Cleo.bet also reserves the right to carry out valid identification of a User under Know Your Customer (KYC) procedures in cases not covered at the paragraph hereinabove
if there’s strong grounds to believe that there’s risk of commitment of fraud, money- laundering or any abuse on the part of the User or in case of frequent and major withdrawals by one User during a reasonably short period of time.
In this case Cleo.bet shall contact the User by email or other means to obtain the information and documents needed, namely, either utility bill not older than 3 months confirming the User’s actual address or bank reference of the User not older than 3 months, or a high resolution scanned copy or a photo of valid driving license with clear and high resolution photo of the User.
The User acknowledges that he/she has to complete the noted KYC check for the withdrawal of funds or deposit in the noted cases, which must be in form and substance satisfactory to the Issuer.
The User is obliged to collaborate with regard to the AML/ KYC check and to provide any information and document deemed necessary by Cleo.bet.
The restricted countries are : Australia, Aruba, Bonaire, Curacao, France, The Netherlands, Saba, Statia, St. Maarten, Singapore, Spain, the United Kingdom, the USA and any other jurisdiction that the Central Government of UK deems online gambling illegal. This includes all of the named Nations' Territories and Possessions. Players from the following countries are not eligible to use the Website and play its games. Cleo.bet will make all reasonable efforts to prevent players from these countries to reach the games.
Cleo.bet may reject any User in its sole discretion without being obliged to disclose any reason for the rejection.

In case the automatic procedures fail, Cleo.bet shall contact the User by email or other means to obtain the information and documents needed. In case the User does not provide the documents in the requested form and any other information requested to
satisfy the AML/KYC check, Cleo.bet may deny the User’s withdrawal or “freeze” the account of the User for playing (in case of KYC check during depositing) until such document or information is provided.
6. Compliance officer
The Compliance Officer is the person or a company, duly authorized by Cleo.bet, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Cleo.bet
LTD anti-money laundering and counter-terrorist financing, including but not limited to:
a) Collecting Users’ identification information.
b) Establishing and updating internal policies and procedures for the completion,
review, submission and retention of all reports and records required under the
applicable laws and regulations.
c) Monitoring transactions and investigating any significant deviations from normal
activity.
d) Implementing a records management system for appropriate storage and retrieval
of documents, files, forms and logs.
e) Updating risk assessment regularly.
f) Providing law enforcement with information as required under the applicable laws
and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
7. Special provisions with regard of KYC when accepting virtual currency
One of the principal goals of the KYC for virtual currency acceptance is to assure proper Age and Identity Verification.
The Terms & Conditions of the present part are additionally required terms and conditions
of the Master License Holder, which need to be abided by and proven by each licensee with regard of KYC when accepting and withdrawing virtual currency.

Cleo.bet as an operator assures that it:
- Collects and verifies proof of identity and proof of address of its Users.
Passport, ID card, driving license are accepted proof of identity, as well as proof of residence can be an electricity or telephone bill or a letter from the employer or any recognized public authority certifying the address;
- Verifies that the player is over 18 and that he/she has a valid email address;
- Collects and stores hardware KYC carried out during withdrawals and deposits in amounts noted at the present Policy, included but not limited to: IP address, mac address and browser information to ensure that all withdrawals are to/from the same User (IP and computer).
8. Anti-money laundering policy
Cleo.bet enforces a strict anti-money laundering policy with zero tolerance to money laundering activities. We define money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.
All Cleo.bet affiliates are obligated to comply with this anti-money laundering policy and internal AML Manuals and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.
Cleo.bet ensures complete compliance with laws pertaining to anti-money laundering through its related policy.
Cleo.bet implements a range of filtration operations for swift and accurate identification of any financial activities that may constitute or are related to money laundering. This helps ensure a money laundering-free financial operations throughout the Cleo.bet Platform.
All Users acknowledge, undertake and agree that:
a) The User will comply (while being a Cleo.bet client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities.
b) Cleo.bet operates under certain obligations known as “know-your- client” obligations which grant Cleo.bet the right to implement anti-

money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity.
c) The User agrees fully cooperate with Cleo.bet with respect to anti-money laundering efforts. This involves providing information that Cleo.bet requests regarding the client’s business details, account usage, financial transactions etc. to help Cleo.bet perform its duties as dictated by Applicable laws regardless of jurisdiction.
d) Cleo.bet reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices.
e) Cleo.bet reserves the right to suspend or cancel any account or freeze
the funds at the account if there is reason to believe that the account is being used
for activities that are deemed unlawful or fraudulent.
f) Cleo.bet has the right to use client information for the investigation
and/or prevention of fraudulent or otherwise illegal activities.
g) Cleo.bet has the right to share client information with:
- Investigative agencies or any authorized officers who are helping Cleo.bet to comply with applicable law, including anti-money laundering laws and know-your-client obligations on the basis of the Non-disclosure agreement concluded between Cleo.bet and such agencies or officers;
- Organizations that help Cleo.bet to provide the services that it offers to its clients on the basis of the Non-disclosure agreement concluded between Cleo.bet and such organizations;
- Government, law enforcement agencies and courts;
- Regulatory bodies and financial institutions.
Activities that Cleo.bet considers possible indications of money laundering include:
a) The client showing unusual apprehension or reservations about Cleo.bet’s anti-money laundering policies.
b) The client’s interest in conducting financial transactions which are contrary to good
business sense or are inconsistent with the client’s business policy.
c) The client failing to provide the proof of legitimate sources for their funds.

d) The client providing false information regarding the source of their funds.
e) The client having a history of being the subject of news that is indicative of civil or
criminal violations.
f) The client seems to be acting as a ‘front man’ for an unrevealed person or business, and does not satisfactorily respond to requests for identifying this person or business.
g) The client not able to easily describe the nature of his/her industry.
h) The client frequently makes large deposits and demands dealing in cash only.
i) The client maintains multiple accounts and conducts an unusually high number of
inter-account or 3rd party transactions.
j) The client’s previously usually inactive account starts receiving a surge of wire
activity.
The above list is by no means an exhaustive list. Cleo.bet monitors its client and account activity in light of several other red flags and takes appropriate measures to prevent money laundering.
9. Training
The purpose of Cleo.bet training is ensuring compliance with obligations imposed by Law and the regulation, creating an institution culture by increasing the sense of responsibility of staff on policy and procedures of institution and on risk-based approach and updating of staff information.
Education programs are prepared by Compliance Officer and classroom trainings can be
given by the Compliance Officer.
It is essential to train the new employees about the subject during the basic training period. The existing personnel shall regularly be trained with classroom and e-learning methods.
The trainings to be given to staff by obliged parties shall at least cover the following subjects;
- Laundering proceeds of crime end terrorist financing;
- The stages, methods of laundering proceeds of crime and case studies on
this subject;

- Legislation regarding prevention of laundering proceeds of crime and terrorist financing;
- Risk areas;
- Principles relating to customer identification;
- Principles relating to suspicious transaction reporting;
- Obligation of retaining and submitting;
- Obligation of providing information and documents;
- Sanctions to be implemented in violation of obligations;
- The international regulations on combating laundering and terrorist
financing.
10. Internal audit
The Compliance Officer is responsible to audit periodically on a risk sensitive basis whether the activities of Cleo.bet related to anti-money laundering law and regulations thereunder are conducted in compliance with the aforementioned legislation and policies and procedures of Cleo.bet.
The Compliance Officer reports directly to Director with regard of results of such checks and audit.