Stake Anti-Money Laundering Policy

The Stake Anti-Money Laundering Policy is a set of measures established to combat financial crimes such as money laundering or terrorist financing, as well as to comply with current laws and regulations of India.The Casino applies several procedures to ensure the protection of players and the security of financial operations. This includes verifying the identity of users, monitoring large transactions in INR, and tracking and documenting any suspicious activity on the website.

Stake's anti-money laundering policy

About the Owner Company

The Stake Casino is owned by Medium Rare N.V. The company was officially registered under the leadership of the Curacao Gaming Authority in 2017. The Casino is licensed by the document # 1668/JAZ. This gives the company the ability to provide gambling services legally in India.

For safe operation in this market, the Casino has established a number of common measures that contribute to the rapid detection and suppression of criminal activity on the site. The protective principles come into effect from the moment of registration. All new players who’ve created an account in the Stake Casino are checked for compliance (identification procedure) and financial reliability through transaction monitoring.

Financial Policy of the Casino

Stake provides services in the field of casino games, and all operations are regulated by gambling legislation. Because the Casino is not a financial institution, the laws applicable to various types of financial establishments don’t apply to it. Nevertheless, the jurisdiction of Curacao is subject to the AML/CFT (Anti-Money Laundering and Combating the Financing of Terrorism) Regulations adopted in 2016. Based on these Provisions, the Stake Casino officially prohibits the use of the website in order to carry out illegal activities ‒ playing with stolen or counterfeit money, financing terrorist organizations, or violating trade sanctions. The Casino is monitoring updates of the AML/CFT Regulations and making appropriate changes in this Policy to comply with current laws.

The Stake Casino strives to ensure that gambling services are used only for legal entertainment purposes, not for the organization of criminal activity. To guarantee this, the administration implements various global methods to combat financial fraud:

Employee training. Stake workers attend special courses and undergo training on anti-money laundering issues. This helps them to be aware of the possible danger and understand the measures and procedures applied;
Compliance Officer. The hired employee is responsible for ensuring compliance with the law and the company’s internal financial policy. The main task of the compliance officer is to monitor transactions in Stake Casino, identify suspicious payments, and timely report to management or regulatory authorities on detected violations and measures taken;
Approval of a written version of the Policy. The document contains information about all the specific measures that must be taken promptly to prevent problems;
Regular inspections by independent authorities. The casino attracts experts to analyze and evaluate their Anti-Money Laundering Policy for effectiveness.

Common Terms

When it comes to the Anti-Money Laundering Policy, the Stake Casino uses the following definitions to describe the problem and implement appropriate control measures:

Money Laundering. This is the process of transferring illegally obtained money into supposedly clean funds by conducting financial operations through a Casino. The scammer deposits the «dirty» money, masks its illegality by making complex financial transactions, and eventually withdraws «clean» money;
Placement. The first stage of using illegally gained funds. The «dirty» money is deposited at the Casino;
Layering. The player carries out a complex chain of financial transactions to make it difficult to trace the origin of the used funds. In the context of the Stake Casino, this means conducting multiple consecutive payments ‒ money transfers between accounts, money exchange for in-game currency, and so on. This creates a thick layer of operations and makes the financial trace confusing;
Integration. The «clean» money claimed in the Сasino through making bets or performing other transactions is integrated into new financial flows. That is, criminals can use this money again without fear that its illegal status will be tracked. After laundering, the disclosure of the true source from which the funds were received becomes far more complicated;
Suspicious activity. Actions that indicate that players are using the casino website to conduct illegal activities. For example, depositing huge amounts of money to the balance, making complex transactions, and so forth;
Retaliatory sanctions. These are measures aimed at establishing responsibility and imposition of punishment for players who participate in illegal financial transactions.

Monitoring Compliance with the Requirements

In order to carefully monitor compliance with the provisions of the Anti-Money Laundering Policy, the Stake Casino has hired a Chief Compliance Officer. The specialist is responsible for:

Сreating, approving, and implementing updates to the AML Policy;
Liaising with external authorities and regulators to increase the effectiveness of the program;
Investigating suspicious actions on the part of players;
Conducting training for other employees of the Casino to inform them about the problem and ways to solve it in accordance with legal norms.

Know Your Customer (KYC)

One of the measures to prevent players from being involved in illegal activities is the Know Your Customer procedure. This is the identification of the user’s personality and their financial status. Through the analysis of previous transactions, the Casino quickly identifies suspicious activity that doesn’t correspond to the usual lifestyle or financial status of the player. This helps to determine potentially dangerous users, as well as uncover real cases of money laundering, terrorist financing, and other crimes. The KYC procedure consists of 3 components.

Customer Due Diligence (CDD)

The purpose of the CDD is to identify and analyze the risks associated with the player’s activities on the Casino website. When a user registers a new account, the administration requests data for a more detailed acquaintance with their personality. This includes name, date of birth, physical address, citizenship, and identification documents.

Based on the collected data, the Casino generates a profile of potential risks that the player may be exposed to. A high level of risk most often leads to the establishment of restrictions or a complete refusal to provide services to the gambler.

The identification of players under the CDD method is carried out in 4 stages:

Getting personal information about a new player. To register on the Stake site, the user is required to provide contact information and date of birth. Only real users who can be identified by the system are allowed to play in the Casino;
Analyzing the user’s wallet. The balance that is used to replenish the player’s account in Stake Casino is undergoing a detailed check. The stage helps to detect illegal transactions and other suspicious actions with finances;
Keeping a record of collected personal information. Over time, this can be very effective to track anomalies on the account;
Conducting regular checks of lists of suspected terrorists for the presence of Stake players in them. If the user is part of a terrorist organization or is somehow associated with it, then termination of their membership in the Casino also helps to curb potential financing of terrorism.

Prevention Measures

In addition to detecting fraudsters in the process of using Stake gambling services, the Casino also blocks access to the website to prevent suspicious Indian players from committing illegal actions:

Ban for players from prohibited jurisdictions. The Casino may use special software to detect the gambler’s IP and, if the location is in a prohibited zone, restrict further access to the website;
Ban for players from sanctioned territories. To successfully join the Stake Casino and use all services to the fullest, the player must provide proof that they aren’t under the sanctions of the United States, the European Union, and other global jurisdictions;
Ban on registration for users from prohibited countries. The company strictly adheres to international norms and laws in the field of gambling. Therefore, it’s not possible to provide casino services to players from countries with restricted access.

Enhanced Due Diligence (EDD)

The EDD is an enhanced verification of players. The procedure involves a more detailed and thorough analysis of the gambler’s profile to identify alarming indicators in their activities. To get permission to block an account, it’s enough for the administration to see that at least one of the indicators is triggered.

To pass the EDD procedure, the user must provide basic personal data:

Full name specified in the passport;
Citizenship;
Permanent place of residence;
ID number or any other identification document confirming official citizenship;
Source of income (salary, pension, savings, etc.).

The Stake Casino reserves the right to involve third parties to verify the accuracy of the data provided.

Reasons for Blocking Users

Account blocking is a precautionary measure to protect casino users from fraud. The Stake Casino has the right to prevent suspicious players from playing on the website or to completely cease cooperation if they:

Refuse to provide personal information;
Attempt to deceive the administration by sending fake identification documents;
Use additional software to hide their real geolocation;
Located in a prohibited jurisdiction;
Fall under the sanctions of the USA, the EU, and other global jurisdictions;
Suffer from gambling addiction;
Are not mentally stable;
Receive income in prohibited jurisdictions

Transaction Control

During the transaction monitoring, every payment carried out by players is analyzed for suspicious or illegal activity. Security specialists use various methods and technologies, such as pattern analysis, comparison with typical behaviors, tracking large and unusual transactions, and other tools.

To ensure security for both parties, the Stake Casino India checks financial transactions in several ways:

Country where the money is being transferred. Deposits and withdrawal of funds cannot be made from/to wallets registered in prohibited jurisdictions;
Sanctions lists. The Casino issues the Stake funding address only after making sure that the player is not under sanctions of the US, EU, and other countries;
Nature of previous payments. The administration examines the size, volume, and type of financial transactions. This data is entered into the report and is regularly rechecked for signs of suspicious activity;
Indications of fraud. Before the Casino approves the transaction, it will be checked by the Chainalysis service. If the program reveals a high level of risk, the account may be blocked on suspicion of violating the Anti-Money Laundering Policy. To clear themselves of charges, high-risk profile owners have to provide real proof of their well-being.

Additional Control Measures

Financial criminals are constantly developing new methods to bypass existing control systems. For such cases, the Stake Casino has spare measures to ensure transparency and legality of all transactions:

Using software for detecting multiaccounting. A special program establishes a connection with the device that the player uses to log in to different profiles in the Casino. Such actions violate the rules of Stake and all accounts of one user will be blocked eventually;
Comparing time zones. The Casino can determine the user’s time zone and compare it with the time zones of different jurisdictions. If the time zone indicates that the player is located in a restricted jurisdiction, access to the website may be banned;
Checking suppliers. To maintain the Anti-Money Laundering Policy, the Stake Casino uses the services of several third-party organizations (for example, consulting companies). From time to time, the administration of the website checks partners too. This is necessary to identify their reliability and assess whether they fulfill their contractual obligations.

Employee Training

The Stake Casino conducts regular training for workers to ensure that they are constantly aware of new money laundering methods and updated legal requirements. Employees learn how to identify suspicious activity, what to do, and where to report it.

Reporting on Suspicious Activity

According to National Money Laundering and Terrorist Financing Resolutions, the Stake Casino is obliged to report any suspicious activity noticed on the website.