Roku Casino (We, Us) Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Roku Casino being involved in any kind of illegal activity.
Gaming environments are often targeted by those wishing to launder money. The speed of transactions and use of multiple payment processing options make gaming businesses especially vulnerable to this activity.
As a result we in Roku Casino are combating these threats and do our best to protect our clients from any interruptions which may occur with the website as the results of such risks.
AML/KYC Policy covers the following matters: monitoring activity, representations and warranties, prohibited jurisdictions, verification procedures (KYC), identity verification.1. Monitoring activity
1.1. Roku Casino employees will be given training in Money Laundering indicators such as (but not limited to):
- Unusual Gaming Patterns;
- Suspicious deposit and withdrawal patterns (size and frequency);
- Reliability of Card Data;
- Customer verification issues and Identity Theft;
- Account linkage/multiple accounting.
1.2. All instances of suspected Money Laundering attempts must be reported to the MLRO or management, but that suspicion must not be conveyed to the customer and further actions must await consents.
1.3. Roku Casino does not have any cash element to it, mitigating risks associated with counterfeit monies and cash money laundering.
1.4. Systems will be operating to record all transactions for an account. These account histories will be subject to a programme of regular and continual checks against fraud. Where unusual gaming patterns and winning patterns are detected, these will also be cross- referenced to call and messaging history to ensure that staff are not colluding with customers or acting illicitly.
1.5. Company will also keep a register of those customers that it identifies as high risk or politically exposed. Those accounts will be subject to greater scrutiny and frequency of checks.
1.6. We are also implementing adequate monitoring procedures in our gaming business across equipment, people, communications and transactions. Company will implement a range of measures and procedures to ensure security and safety in these areas (which includes, but not limited to staff training, call recording technologies and storing communications with clients).2. Clients’ representations and warranties
2.1. Clients’ representations and warranties related to Anti-Money Laundering (AML) Compliance and fighting Transaction Frauds.
2.2. Considering the rights given to you for using the Services, you guarantee, covenant and agree to the following:
- your age is at least 18 years or you are of age, which is legally accepted for gambling in accordance with the legislation of your jurisdiction;
- you are the lawful owner of the money on your account. All information provided by you to the Company during the registration process or at any time thereafter, including information as part of any payment transaction requiring money depositing, is true, valid, correct and complete and matches the name (names) on the credit/debit card(s) or in other payment accounts that are used to deposit or receive funds on your account.
2.3. By accepting the Terms and Conditions you give us the right to perform periodic inspections (at our sole discretion), or checks, which may be required by third parties (including regulatory authorities) to confirm your identity and contact details (”Check”).
2.4. During such checks we may restrict the possibility of money withdrawal from Your account.
2.5. If any information that you provided to us is false, inaccurate, misleading or otherwise incomplete, it will be in breach of contract, and we reserve the right to terminate your account immediately and/or refuse you the use of Services in addition to other measures we may choose to take in our sole discretion.3. Prohibited jurisdictions
3.1. You are prohibited from creating accounts and / or depositing any funds if you are located or reside in the following states: USA, UK, Spain, Israel, France, Netherlands, Belarus, Ukraine, Aruba, Curacao, Bonaire, Saba and Saint Eustatius, Saint-Marten.4. “Know your customer” (KYC) policy
4.1. One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Roku Casino establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.5. Identity verification
5.1. Roku Casino's identity verification procedure requires the User to provide Roku Casino with reliable documents, data or information (e.g., national ID, international passport, bank statement). For such purposes Roku Casino reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
5.2. Roku Casino will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Roku Casino reserves the right to investigate certain Users who have been determined to be risky or suspicious.
5.3. Roku Casino reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Roku Casino reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
5.5.Once the User’s identity has been verified, Roku Casino is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.