AML Policy

Objective of the AML Policy: We aim to provide the highest level of security for all our users and customers on khelo-star.in. To achieve this, we implement a three-step account verification process to ensure the identity of our customers. This procedure is designed to confirm that the details of the registered individual are accurate and that the deposit methods used are not stolen or misused by others. Our goal is to establish a robust framework to combat money laundering. Additionally, we recognize that different safety measures must be applied depending on the nationality and origin of the user, as well as the payment methods and withdrawal processes involved.

khelo-star.in also implements reasonable measures to control and mitigate money laundering (ML) risks, including allocating the necessary resources and means.

khelo-star.in is dedicated to upholding high standards of anti-money laundering (AML) in accordance with EU guidelines. We require both management and employees to actively enforce these standards to prevent the use of our services for money laundering activities.

The AML program of khelo-star.in 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 is understood as:

• The conversion or transfer of property, particularly money, with knowledge that it is derived from criminal activity or involvement in such activity, is aimed at concealing or disguising the illegal origin of the property. This also includes assisting any individual involved in committing such acts to evade the legal consequences of their actions or those of their companies.
• The concealment or disguise of the true nature, source, location, disposition, movement, rights regarding, or ownership of property, with knowledge that such property is derived from criminal activity or from participation in such activity.
• The acquisition, possession, or use of property, with knowledge at the time of receipt that such property was obtained from criminal activity or from assisting in such activity.
• Participation in, or association to commit, attempts to commit, and aiding, abetting, facilitating, or counseling the commission of any of the actions described in the preceding points.

Money laundering shall be considered as such even if the activities that generated the property to be laundered were conducted in the territory of another Member State or in a third country.

Organization of the AML for khelo-star.in

Furthermore, an AMLCO (Anti-Money Laundering Compliance Officer) is responsible for enforcing the AML policy and procedures within the system.

The AMLCO is placed under the direct responsibility of the general Management:

AML policy changes and implementation requirements:

Each major change of khelo-star.in AML policy is subject to be approved by the Anti money laundering compliance officer.

Three step Verification

Step one verification:

Step one verification is required for every user and customer before making a withdrawal. This verification must be completed prior to selecting the payment method, withdrawal amount, withdrawal choice, and nationality of the user/customer. Step one verification involves a document that must be completed by the user/customer themselves. The following information must be provided: first name, last name, date of birth, country of usual residence, gender, and full address.

Step two verification:

Step two verification is mandatory for every user who deposits over $2,000 (Two Thousand Dollars) or withdraws over $2,000 (Two Thousand Dollars). Until step two verification is completed, any withdrawal, tip, or deposit will be held.

This verification process will direct the user or customer to a subpage where they must submit a picture of their ID. The user/customer must take a photo of their ID alongside a paperclip displaying a six-digit randomly generated number. Only official IDs may be used for verification, and the variety of accepted IDs may differ depending on the country.

An electronic check will also be performed to verify that the information provided in step one matches the data on the ID. This check will cross-reference two different databases to confirm that the information is consistent. If the electronic verification fails or cannot be conducted, the user/customer will be required to provide proof of their current residence, such as a certificate of registration from the government or a similar document.

Step three verification:

Step three verification is required for every user who deposits over $5,000 (Five Thousand Dollars), withdraws over $5,000 (Five Thousand Dollars), or sends another user over $3,000 (Three Thousand Dollars). Until step three verification is completed, any withdrawal, tip, or deposit will be held.

Customer identification and verification (KYC)

The formal identification of customers upon entering into commercial relationships is a crucial component, both for compliance with money laundering regulations and for our KYC policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card, or driving license must be provided, each displayed alongside a handwritten note that includes six randomly generated numbers. Additionally, a second photo showing the user’s/customer’s face is required. The user/customer may blur out all information except for the date of birth, nationality, gender, first name, last name, and the photo to protect their privacy.

Please ensure that all four corners of the ID are visible in the same image, and all details must be clearly readable, except for the information specified above. We may request all details if necessary.

An employee may do additional checks if necessary, based on the situation.

Proof of Address:

Proof of address will be verified through various electronic checks that utilize two different databases. If the electronic verification fails, the user/customer will have the option to provide manual proof of their address.

A recent utility bill sent to your registered address, issued within the last 3 months, or an official government document that verifies your place of residence.

To ensure the approval process is as swift as possible, please make sure the document is submitted in clear resolution, with all four corners visible and all text legible..

For example, acceptable documents include an electricity bill, water bill, bank statement, or any official government correspondence addressed to you.

An employee may do additional checks if necessary, based on the situation.

Source of funds

If a player deposits over a five thousand euro there is a process of understandings the source of wealth (SOW)

Examples of SOW are:

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

It is essential that the origin and legitimacy of that wealth are clearly established. If this cannot be verified, an employee may request an additional document or proof.

The account will be frozen if the same user deposits this amount in a single transaction or through multiple transactions that total this amount. A manual email will be sent to them, outlining the above information and providing details available on the website.

khelo-star.in also requests a bank wire or credit card to further verify the identity of the user/customer. This additional information helps us gain a better understanding of the user/customer’s financial situation.

Basic document for step one

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

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

The document will be generated and stored by an AI, and an employee may conduct additional checks if necessary based on the circumstances.

Risk management

To address the various risks and states of wealth across different regions of the world, khelo-star.in will categorize each nation into three distinct risk regions.

Region one: Low risk:

For every nation from region one the three-step verification is done as described earlier.

Region two: Medium risk:

For every nation classified in region two, the three-step verification will be implemented at lower deposit, withdrawal, and tip amounts. Step one will be conducted as usual. Step two will occur after depositing $1,000 (one thousand dollars), withdrawing $1,000 (one thousand dollars), or tipping another user/customer $500 (five hundred dollars). Step three will take place after depositing $2,500 (two thousand five hundred dollars), withdrawing $2,500 (two thousand five hundred dollars), or tipping another user/customer $1,000 (one thousand dollars). Additionally, users from a low-risk region who convert cryptocurrency into any other currency will be treated as users/customers from a medium-risk region.

Region three: High risk:

Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.

Additional measurements.

Additionally, an AI monitored by the AML Compliance Officer will analyze for any unusual behavior and report it immediately to an employee of khelo-star.in.

Based on a risk-based approach and general experience, human employees will review all checks previously performed by AI or other staff and may conduct additional or repeat checks as needed, depending on the circumstances.

Additionally, a data scientist, aided by advanced electronic analytics systems, will monitor for unusual behaviors, such as making deposits and withdrawals without extended betting sessions, attempts to use different bank accounts for deposits and withdrawals, changes in nationality or currency, shifts in behavior and activity, and verifying whether the account is being used by its original owner.

Furthermore, a user is required to use the same method for withdrawals as was used for the initial deposit, up to the amount of the initial deposit, to prevent any potential money laundering activities.

Enterprise-wide risk assessment

As part of its risk-based strategy, khelo-star.in has carried out an AML “Enterprise-wide Risk Assessment” (EWRA) to identify and understand risks specific to its operations and business lines. The AML risk policy is established after recognizing and documenting the risks inherent to its business activities, including the services provided by the website, the users who receive these services, the transactions conducted by these users, the delivery channels utilized by the bank, as well as the geographic locations of the bank’s activities, customers, and transactions, along with other qualitative and emerging risks.

The identification of AML risk categories is based on khelo-star.in’s understanding of regulatory requirements, expectations from regulators, and industry guidelines. Additional security measures are implemented to address the extra risks associated with the use of the internet.

The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML compliance ensures that “ongoing transaction monitoring” is carried out to identify transactions that are unusual or suspicious when compared to the customer’s profile. This monitoring is performed on two levels:

1) The first Line of Control:

khelo-star.in partners exclusively with trusted Payment Service Providers, all of which have robust AML policies in place. This ensures that the majority of suspicious deposits on khelo-star.in are prevented, with proper execution of KYC procedures for potential customers.

2) The second Line of Control:

khelo-star.in ensures that its network is aware that any interaction with a customer, player, or their authorized representative should trigger due diligence on transactions related to the account in question. This includes, in particular:

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

Additionally, the three-step verification process, combined with adjusted risk management, is designed to ensure that khelo-star.in has all necessary information about its customers at all times.

Moreover, all transactions must be monitored by employees, who are supervised by the AML compliance officer, with oversight from the general management.

Specific transactions that are submitted to the Customer Support Manager, potentially through their Compliance Manager, must also undergo due diligence.

Determining the unusual nature of one or more transactions largely relies on a subjective assessment, based on knowledge of the customer (KYC), their financial behavior, and the transaction counterparty.

These checks are carried out by an automated system, with an employee conducting cross-checks to provide an additional layer of security.

Transactions observed on customer accounts, where it is challenging to understand the legitimacy of activities and the origin of funds, should be promptly considered atypical, as they cannot be directly justified.

Any khelo-star.in staff member must report any atypical transactions they observe to the AML division if they cannot attribute them to a known lawful activity or source of income of the customer.

3) The third Line of Control:

As a final line of defense against AML, khelo-star.in will conduct manual checks on all suspicious and higher-risk users to thoroughly prevent money laundering activities.

If fraud or Money Laundering is found the authorities will be informed.

Reporting of Suspicious transactions on khelo-star.in

In its internal procedures, khelo-star.in provides clear and detailed guidelines for its staff members, outlining when it is necessary to report suspicious activities and the proper procedures for making such reports.

Reports of atypical transactions are analyzed by the AML team following a precise methodology that is thoroughly detailed in the internal procedures.

Depending on the results of this examination and based on the information gathered, the AML team may:

• Decide whether it is necessary to submit a report to the Financial Intelligence Unit (FIU), in compliance with the legal obligations outlined in the Law of 18 September 2017;
• Determine whether it is necessary to terminate the business relationship with the customer.

Procedures

The AML rules, including the minimum KYC standards, will be translated into operational guidelines and procedures that are accessible on the intranet site of khelo-star.in.

Record keeping

Records of data obtained for identification purposes must be retained for at least ten years after the business relationship has ended.

Records of all transaction data must be retained for at least ten years after the completion of the transactions or the termination of the business relationship.

These data will be safely, encrypted, stored offline and online.

Training

Human employees at khelo-star.in will perform manual checks based on a risk-based approval process, for which they receive specialized training.

The training and awareness program is reflected by its usage:

– A mandatory AML training program, aligned with the latest regulatory developments, is required for all staff members involved in financial activities.

– Academic AML learning sessions for all new employees

The content of this training program must be tailored to the specific type of business the trainees are involved in and the roles they hold. These sessions are conducted by an AML specialist from the AML team.

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security

All data provided by any user or customer will be kept secure and will not be sold or disclosed to any third party. Data may only be shared with the AML authority of the relevant state if required by law or to prevent money laundering.

khelo-star.in will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

Contact us

If you have any questions about our AML and KYC Policy, please contact us:

• By email: [email protected]

If you have any complaints regarding our AML and KYC policy or about the checks conducted on your account and personal information, please contact us:

• By email: [email protected]