AML policy

CRIMINAL ACTIVITY & DISORDER (INCLUDING FRAUD AND AML)

OVERVIEW

1. TITANZENITH VENTURES LIMITADA (hereinafter referred to as the “Company”) has significant expertise in protecting gaming operations from criminal exploitation. This includes the implementation of robust anti-fraud and anti-money laundering systems, procedures, and comprehensive staff training initiatives.
2. Future training programs will be grounded in a solid understanding of the Proceeds of Crime Act and the typical signs of money laundering activity within gaming environments, especially where transactions are completed without physical card presence.
3. The Company’s director has an in-depth understanding of the Proceeds of Crime Act, their associated obligations, and is well-equipped to provide expert guidance on AML compliance, having previously overseen security measures for both remote and land-based gaming businesses.

PREVENTION OF MONEY LAUNDERING & TRANSACTIONAL FRAUD

1. Online gaming platforms are frequently targeted by individuals attempting to launder illicit funds. The fast-paced nature of digital transactions and the availability of various payment methods increase the vulnerability of such platforms to this type of criminal activity.
2. As a result, many of the Company's initial operational decisions and trading strategies are purposefully designed, or naturally evolve, to mitigate these risks.
3. All employees will receive training to identify common indicators of money laundering, which may include (but are not limited to):
4. 3.1: Abnormal or inconsistent betting behaviors
5. 3.2: Suspicious deposit or withdrawal patterns (in size and frequency)
6. 3.3: Questionable or mismatched card information
7. 3.4: Difficulties in verifying a customer’s identity or signs of identity theft
8. 3.5: Indicators of account sharing or multiple accounts linked to the same user
9. Any suspected instance of money laundering must be reported immediately to the Money Laundering Reporting Officer (MLRO). Staff must refrain from alerting the customer to the suspicion. No further action should be taken without MLRO instruction. The MLRO will be responsible for filing Suspicious Activity Reports (SARs) and maintaining the necessary reporting logs and documentation.
10. The Company will enforce a full Know Your Customer (KYC) policy. This will serve not only as a safeguard against money laundering but also against wider fraudulent behavior. Customers will be informed during registration and on relevant pages of the website that the Company employs digital verification tools. If verification criteria are not met automatically, official documents for identity and address confirmation will be requested.
11. Additional protective measures include withdrawal velocity limits, such as requiring director-level approval and further checks before processing:
12. Any single card withdrawal or bank transfer over €3,000
13. A maximum of 3 withdrawals per day
14. A total daily withdrawal limit of €9,000
15. The following thresholds will automatically trigger Enhanced Due Diligence (EDD) procedures, requiring official proof of identity and address beyond standard online verification:
16. 
    
17. Withdrawals over €3,000 within a 24-hour period
18. Withdrawals exceeding €9,000 within any 90-day period
19. The Company will operate entirely without a cash-handling element, effectively removing the risk of counterfeit currency.
20. All account transactions will be recorded systematically. These records will be reviewed continuously to detect signs of fraud or potential breaches of responsible gambling practices. Any unusual patterns, such as irregular betting or winning trends, will be cross-checked against customer interaction logs to prevent potential staff collusion or misconduct.
21. A register will be maintained for all customers identified as high-risk or Politically Exposed Persons (PEPs). These accounts will undergo enhanced scrutiny and more frequent reviews.
22. In cases where staff are suspected of illegal or unethical behavior, including transactional fraud, disciplinary measures will follow company procedures as outlined in employment contracts and in compliance with labor laws. This includes, where necessary, precautionary suspension pending investigation.

ETHICAL RELATIONSHIPS WITH CUSTOMERS AND PARTNERS

1. The Company will clearly publish its Terms & Conditions, KYC, and AML policies on its website. These documents will detail actions the Company may take when fraud, prior knowledge of match results, match-fixing, or any other suspicious behavior is detected. The policies will also outline the extent of cooperation with regulatory authorities and sports governing bodies, maintaining transparency with users in such cases.
2. In situations where serious criminal conduct is suspected or discovered, the director and staff are responsible for ensuring that suspects are not alerted ("tipped off") to ongoing investigations. Specific escalation protocols and staff training will be in place to handle such sensitive scenarios.
3. The Company is committed to conducting ethical business relationships. This includes a standard due diligence process when forming partnerships, often secured with Non-Disclosure Agreements (NDAs) where appropriate. These checks will include confirmation of ownership, management structures, company registration, and verified contact information. All due diligence efforts will be documented and stored for reference.