THE FOREWORD.

Today, in the epoch of globalization and high-speed development of technologies, each technological company must apply special, enhanced measures to prevent being a part of any illegal, criminal or unlawful scheme. One of the main challenges to each company, that provides gambling services is to prevent been used for money laundering and terrorist financing purpose. This Anti-Money Laundering and Counter-Terrorist Financing Policy (“Policy”) was created in order to implement internal procedures of the Administration of gigaspinplay.com (“Company”) to combat money laundering, terrorist financing and other criminal and/or unlawful activity, that is connected with fraud, cheating or collusion.
THE GROUNDS OF THIS POLICY.
This Policy was created on the base of the following documents:
- Recommendations of The Financial Action Task Force (FATF Recommendations);
- Risk-based approach (RBA) guidance for casinos, issued by FATF;
- Legislation of the European Union, namely, the Directive 2015/849 (EU) of the European Parliament and of the Council and its supplementary documents, namely, the Commission Delegated Regulation (EU) 2016/1675;
- The Prevention and Suppression of Money Laundering Activities Amending Law 13(Ι) of 2018 of the Republic of Cyprus.
This list is not exhaustive. Additional pieces of the legislation or regulatory documents may be applied.

RISK ASSESSMENT.

The Company implements the risk-based approach, proposed by FATF in order to assess each customer (“player”) of the gigaspinplay.com (“website”) in the Frame of this Policy.
The categories of the risk are the following:
Country/Geographic risk. The Company checks the Country of the player`s residence/domicile by the following criteria (including, but not limited to):
- Whether country of player`s residence (jurisdiction) is defined as "Third country with the strategic deficiencies" by the European Commission and/or whether player`s jurisdiction is marked as "high-risk and other monitored jurisdiction" by The Financial Action Task Force.
Customer Risk. The Company checks the Player of the Website by the following criteria (including, but not limited to):
- Whether or not the player is the Politically Exposed Person;
- Whether or not the player is under sanctions of the European Union or the United Nations Organization;
- Whether or not the activity of the player is suspicious. Examples of the suspicious activity include, but not limited to: a) excessive depositing activity; b) usage of several devices to authorize on the Website in a short time-frame; c) usage of the player`s device by other players of the Website; d) usage of one IP address by several players; e) usage of one device by several players.
Transaction risk. The Company checks the spenders of the player to ensure, that they are not high and/or disproportionate. The Company also applies additional measures if the transaction of the player is suspicious (see “transaction monitoring”).

VERIFICATION.

The Company applies verification (or, as defined by the law, due diligence) if the following applies:
A) The total amount of the transactions, made through the Company by a player, reaches or exceeds USD/EUR 1000;
B) In the process of the risk assessment is determined, that a player has significant risk of money laundering or terrorist financing;
C) The behaviour of the player contains one or more factors, that gives the grounds to suspect a player in the usage of the Website in violation of the Terms and Conditions;
D) In other cases, when the personnel of the Company considers verification as a necessary measure.
When applying standard verification, the Company shall ask a player to submit the following documents:
- A copy or a photo of the identification document of the player;
- A photo of the payment card, used or intended to be used in depositing when playing on gigaspinplay.com. It is important, that the name of the ardholder must be the same that the name of the player, that passes a verification. CVV code, payment card number (except for first 6 and last 4 digits) may be hidden or covered. The cardholder`s name must not be hidden or covered in any manner.
- A photo of the player, bearing the documents that were required to pass the verification.
- In some situations - the player`s address confirmation. It may be utility bill, telephone bill or other documents, which, due to the local legislation, shall be deemed to be sufficient in order to confirm the address of the player.
- In some situations - bank statement, the letter from the duty station/from the workplace.
- In some cases - tax assessment notice.
- Photo of the player, holding a list of paper with a necessary data, written by hand: a) the e-mail of the player, used when registering an account; and b) the date of the photo request and the confirmation code.
- Other documents or data, that may be required by the particular situation.
- In some cases, the Company may ask a player to connect with the Website`s Support Team via the call (including the video call).

ADDITIONAL VERIFICATION FOR PEPS AND PLAYERS FROM HIGH-RISK JURISDICTIONS.

The Company applies additional verification measures in the following circumstances:
- The player falls within the definition of the Politically Exposed Person (PEP). Politically exposed person means a natural person who is or who has been entrusted with prominent public functions and includes the following: (a) heads of State, heads of government, ministers and deputy or assistant ministers; (b) members of parliament or of similar legislative bodies; (c) members of the governing bodies of political parties; (d) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances; (e) members of courts of auditors or of the boards of central banks; (f) ambassadors, chargés d'affaires and high-ranking officers in the armed forces; (g) members of the administrative, management or supervisory bodies of State-owned enterprises; (h) directors, deputy directors and members of the board or equivalent function of an international organisation.
- If the Country of the residence of the player is defined as "Third country with the strategic deficiencies" by the European Commission or is defined as " high-risk and other monitored jurisdiction " jurisdiction by FATF.
- In other cases, when the Company considers this procedure as a necessary measure.
When applying additional verification, the Company requires to submit the document(s) or data on the source of player`s income in accordance with a country’s legal and regulatory requirements. Additionally, in case of additional verification, the final approval on the verification shall be done by senior management of the Company.
The Company reserves the right to collect additional verification data of the player for the purposes of this Policy. Additionally, in cases when a) a player refuses to pass verification; and/or b) the Company has ample grounds to suppose, that a player uses the Company for illegal purposes, and the player does not provide evidence to the contrary, the Company may inform proper regulatory/governmental/financial authorities on this case.

ACTIVITY MONITORING.

All operations of the players are checked on the absence of the suspicious activity. Suspicious activity includes, but not limited to:
• Usage of several cards through different payment agents, proposed by the Company;
• Obtaining a specific error code when making a payment;
• Usage of payment cards, issued by different emitters, that are located in different regions;
• Usage of different payment instruments within a short term (cards, electronic wallets, banking transactions);
• Opposition or unwillingness of the player of verification of his/her account or payment instrument or his/her account as a whole;
• Mismatch of the geolocation of player`s key elements (citizenship/residency, mobile carrier provider, IP address geolocation, BIN number of the card etc.);
• Principal opposition to any phone or video call, non-provision by the player of his/her photo of him/her with the identification document in hands (upon request);
• Matching of the player`s device ID (telephone, computer, tablet) with the device ID of another account in our system.

In case of any suspicious activity, mentioned above, this issue shall be directed to the antifraud department in order to evaluate a risk of this player and to conduct further actions. The antifraud department shall evaluate this issue and further direct it to the relevant department for further consideration.

TRANSACTIONS MONITORING.

All the transactions of players on withdrawal and deposits shall comply with the following conditions:
• If the transaction is made by using a payment card, the name of the holder shall be the same as the name of the Website account owner. It means that any usage of third-party payment card is prohibited.
• If the transaction is made by using an electronic wallet, this wallet`s electronic mail may be the same, that was used by a player when registering an account on the Website.
• In case if a deposit is made from the payment instrument, placement of funds to which is unavailable, the withdrawal shall be made to the player`s banking account, or to another payment instrument, if it is possible to reliably ascertain that this payment instrument really belongs to the player in question.
• The Company does not accept payments from the anonymous payment instruments (cryptocurrencies, anonymous wallets etc.).
• The Company does not withdraw funds, that were deposited by the player, to the payments instrument of another player.

TRAINING OF THE PERSONNEL ON CURRENT AML PROCEDURES.

All personnel of the Company, whose duties relates to the current Policy, shall pass training and special instructions, elaborated by the compliance department of the Company. They shall comprise the following:
• What is terrorist financing, money laundering in accordance with the applicable legislation;
• The best practices for combating money laundering and terrorist financing;
• How to recognize suspicious transactions;
• The Company`s obligation under AML/CFT regulations;
• The information on the procedures the Company elaborates in course of combating ML/TF:
• The instructions and guidelines about the other procedures, that the Company applies for mitigation of judicial, financial and reputational risks.

RECORD-KEEPING OF PLAYER`S DOCUMENTS AND DATA.

The documents and data, obtained when verifying the player of the gigaspinplay.com, and other financial data (including transaction information and its supportive evidence) shall be stored, kept, shared and protected in strict compliance with:
• The Legislation of the European Union on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing;
• The Legislation of the European Union on personal data protection;
• The Privacy Policy of the gigaspinplay.com.

AMENDMENTS AND MODIFICATIONS.

This Policy may be modified or amended at any time, at the sole discretion of the Company. You acknowledge and agree that it is your own responsibility to review the Policy periodically and become aware of amendments and modifications. If you do not wish to accept the modified and/or amended Policy, you should not continue to use the Website. Your continued use of the Website and/or the service following the posting of changes to the Policy will be deemed as your acceptance of those changes.
If there are any questions concerning this Policy, please, do not hesitate to contact us.

DATE: April 2020