1. Definitions
For purposes of the AML Policy, the following definitions apply:
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•
Money Laundering: Engaging in acts designed
to conceal or disguise the true origins of illegally or
criminally-derived proceeds so that the proceeds appear to
have legitimate origins or to be legitimate assets.
- ◦ Terrorism Financing: The provision of funds or financial support to individual terrorists or terrorist organizations.
- • Other Criminal Activity: The provision of funds or financial support to further criminal activity of any kind.
- • Politically Exposed Person (PEP): An individual who is or has been entrusted with prominent public functions, including their family members and close associates.
- • Ultimate Beneficial Owner (UBO): Any natural person(s) owning or controlling at least 25% of the Company through direct or indirect means.
2. Processes and Procedures
Aurora International Limited (Aurora) shall maintain processes and procedures designed to ensure compliance with applicable AML and counter-terrorism financing laws and regulations, including:
2.1 Customer Due Diligence (KYC)
Before allowing any player to use our platforms, Aurora will complete due diligence, including Know-Your-Customer ("KYC") procedures, which requires provision of the player's registered phone number and national ID number.
2.2 Third-Party Due Diligence
Aurora has established procedures for conducting risk-based due diligence on all Third Parties to ensure they are appropriate and legitimate for their contemplated role.
2.3 Enhanced Due Diligence
Where necessary, Aurora will conduct Enhanced Due Diligence ("EDD") on players found to have moderate or high-risk of potential involvement with money laundering.
3. Red Flags
Aurora employees should be vigilant for warning signs that may indicate money laundering activity. Red flags include:
- • A party that places multiple transactions regularly
- • A party intends to make payments in cash or cash equivalents
- • A party that refuses to disclose or provide documentation concerning identity
- • A party requests monetary transfers to or from a high-risk country
- • A party is a trust, shell company or private investment company reluctant to provide information
4. Risk Assessment
Aurora employs a risk-based approach to combatting money laundering and terrorism financing. The Compliance Team shall conduct an AML risk assessment to identify risks specific to Aurora's business, including:
- • Products and services offered
- • Customers and transactions
- • Payment channels
- • Geographic locations of operation
The risk assessment will be updated at least annually.
5. Suspicious Activity Reporting Requirements
Aurora will report any suspicions of money laundering or terrorism financing activity to the Financial Intelligence Units or other relevant authorities in jurisdictions where Aurora operates.
6. Reporting Concerns
All employees must notify the General Manager immediately if they become aware of a suspected violation of the AML Policy. Reports can be made verbally, in writing or by telephone.
The Company protects employees who report concerns in good faith from retaliation.
7. Record-Keeping and Document Retention
The General Manager is responsible for keeping AML compliance records. Documents will be kept for 5 years or longer as required by law after the end of the business relationship.
All transactions must be accurately recorded and supported by proper documentation.
8. Awareness and Training
Aurora requires relevant employees to participate in AML training. Periodic training will be provided to reflect updates to legislation and requirements.
9. Monitoring and Review
The Compliance Team will monitor and review compliance with the Policy through regular reviews. The Policy will be updated as needed to remain compliant with applicable laws and regulations.