# Anti-Money Laundering Policy

**For Deposits and Withdrawals.**

_Rollblock's AML (Anti-Money Laundering) Policy_

_**Introduction**_

Rollblock, managed by owned and operated by Muchogaming N.V, located at Abraham de Veerstraat 9 Curaçao P.O. Box 3421, with registered number 153069, is dedicated to providing a secure environment for all users and customers. To ensure the legitimacy of our customers' identities and their payment methods, a comprehensive three-step account verification process is implemented. This approach aims to prevent the misuse of stolen or unauthorized payment methods and to establish a robust framework for combating money laundering. Recognizing the varied payment and withdrawal preferences across different nationalities, we tailor our security measures accordingly.

Rollblock is committed to adhering to the highest anti-money laundering (AML) standards as set forth by EU guidelines, ensuring compliance and obligating its management and employees to prevent the service's misuse for money laundering activities.

The AML program at Rollblock is designed to comply with various EU directives and regulations, including Directive 2015/849, Regulation 2015/847, and sanctions or restrictive measures against specified persons and goods. Additionally, it aligns with the Law of 18 September 2017 on preventing money laundering and limiting cash use in Belgium.\


_**Definition of Money Laundering**_

Money Laundering is defined as activities including the conversion, transfer, concealment, or acquisition of property, knowing its criminal origin, to conceal its illegal source or assist any involved person in evading legal consequences. It encompasses the engagement, association, attempt, and facilitation of such activities, regardless of where the generating activities occurred.



_**Organization of Rollblock's AML:**_

In line with AML legislation, Rollblock's management oversees its AML strategies, with an Anti Money Laundering Compliance Officer (AMLCO) responsible for policy enforcement within the system.



_**AML Policy Changes and Implementation:**_

Significant alterations to Rollblock's AML policy require approval from general management.



_**Three-Step Verification Process:**_

1\. \*\*Step One Verification\*\*: Mandatory for all users for withdrawal, covering basic personal information.

2\. \*\*Step Two Verification\*\*: Required for users depositing over €2000 or withdrawing any amount, necessitating ID verification and electronic data validation.

3\. \*\*Step Three Verification\*\*: Applies to transactions over $5000, asking for source of wealth documentation.\


_**Customer Identification and Verification (KYC):**_

Identifying customers upon commercial engagement is essential, with requirements including:

\- Valid ID documentation, alongside a handwritten note with a six-digit number.

\- Proof of address through utility bills or official government documents.



_**Risk Management:**_

Countries are categorized based on their risk level, with specific verification procedures adapted for each category, including adjusted thresholds for the three-step verification process.



_**Additional Measures:**_

An AI system, supervised by Rollblock monitors for unusual behaviour, with manual checks by employees for high-risk users or suspicious activities.\


_**Enterprise-wide Risk Assessment:**_

An annual AML "Enterprise-wide risk assessment" identifies specific risks to Rollblock, forming the basis for the AML risk policy.



_**Ongoing Transaction Monitoring:**_

Consists of trusted Payment Service Providers (first line of control) and due diligence checks on customer transactions (second line of control), with manual checks as the third line of defense.



_**Reporting Suspicious Transactions:**_

Staff are trained to report atypical transactions, with a structured analysis process determining necessary actions, including potential reporting to the FIU or terminating business relationships.\


_**Record Keeping:**_

Identification and transaction records are maintained for at least ten years post-relationship or transaction.



_**Training:**_

Employees undergo regular AML training, tailored to their specific roles within the company.



_**Data Security:**_

Customer data is securely stored, not sold or shared unless required by law or for preventing money laundering, adhering to data protection guidelines.



_**Contact Us:**_

For questions or complaints about our AML and KYC Policy:

\- Email: Contact@rollblock.io
