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AML/KYC

Money laundering is the process whereby a criminal or criminal organization seeks to conceal the true origin of funds or proceeds of crime in order to create the impression that these funds have a legitimate and lawful source. Criminal activity can include any kind of conduct that would be a criminal offense in Curacao or any other country in which Madnix operates, including but not limited to terrorism, drug trafficking, activities of criminal organizations, corruption, fraud, theft, and tax evasion or other tax-related offenses.

Objective of the AML Policy:

  • To comply with requirements from the regulatory bodies.
  • To provide the highest security to all of our customers on Madnix and to ensure the risks involving transactions and our products are mitigated.
  • To evaluate that the details of the person registered are correct and that the deposit methods used are not stolen or being used by someone else.
  • To prevent the use of services offered by Madnix for money laundering purposes.

Customer identification and verification (KYC)

The initial identification of customers on entry into a business relationship with Madnix is essential, both for the regulations relating to money laundering and for the KYC policy.

Identification

Identification takes place at registration, when the customer is asked to provide personal details, including:

  • First and last name
  • Date of birth
  • Email
  • Home address
  • Country

At this stage, the company may carry out additional checks or request further information or documentation if necessary, based on the situation (e.g., place of birth; nationality; proof of identity, payslips, bank statements).

Verification

Verification takes place at the first request for withdrawal of real money or at intervals defined by the regulatory bodies. This includes:

  • Proof of Identity, in the form of a valid identity document;
  • Proof of Address, in the form of a credible and up-to-date document (not older than 6 months) to confirm the residential address of a customer;
  • Copies of all credit cards used (photo or scan of the card, both sides (front and back) and the 4 corners of the card need to be visible - entire image of the card). Due to PCI DSS Compliance, it is mandatory that the copy of the card that we have stored in our Back Office is hiding 6 middle digits.

CDD aims at verifying the ownership of the payment methods and therefore their legitimate use of funds by the customer. We have an obligation to verify that the account holder is the same person as the owner of the payment method.

Madnix follows the principle of “closed-loop”, meaning that the payment method used to withdraw (Money Out) should be exactly the same as the payment method used to deposit (Money In).

Madnix does not allow funding a player's account by payments that belong to a third party. The use of third-party payment methods is strictly forbidden. If in the course of the verification a third-party payment method (including payment card) is identified, such a payment method shall be blocked, and the player is asked to use and provide proof of ownership of a method they own along with proof of identity in the name of the third party who the payment method was identified as belonging to.

Madnix does not allow funding a player's account by the means of depositing with a business card. If in the course of the verification a business card is identified, such a card shall be blocked and blacklisted from future use, and the player is asked to use and provide proof of ownership of a method they own.

Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) measures are also undertaken at any point, regardless of transaction values, when there is suspicion of money laundering or terrorist financing, or there is doubt about the veracity or adequacy of previously obtained customer identification data. The Company has the right to request additional copies of the customer’s identity confirmation documents and copies of bank cards used to top up the account, copies of payment documents and other documents confirming the lawful possession and legal origin of the funds being deposited into the customer’s account.

If evidence of suspicious transactions is discovered on the customer’s account or documentation provided, deposits from questionable sources (for example, when details of the sender and the account holder do not match) and/or any actions with signs of fraud (including any refunds or cancellation of payments), the Company reserves the right to request further documentation (including but not limited to payslips, bank statements, selfie photo with an identity document), block or close the customer’s account, cancel any payments and suspend operations on the account until the end of the official investigation. When making a decision, the Company is guided by the provisions of the applicable law.