Smokos Casino › Anti-money-laundering policy
Anti-money-laundering policy
Gambling operators are an obvious target for anyone trying to move criminal money, and the rules that apply to us reflect that. This page sets out what we do about it and where it touches you as a customer.
Smokos operates a risk-based programme covering customer due diligence, ongoing transaction monitoring, record keeping, reporting and staff training. It is maintained under the supervision of a designated compliance officer with authority independent of the commercial side of the business.
1. Knowing who our customers are
Every account is verified before a first withdrawal is released, and earlier where activity warrants it. Identity, age, address and ownership of the payment method are all confirmed against independent sources. The detail of that process sits in our KYC policy.
Enhanced due diligence applies where the risk is higher: politically exposed persons, customers connected to a high-risk jurisdiction, accounts funded in ways that obscure the origin of the money, and accounts whose turnover is out of proportion to what we know about the customer.
2. Source of funds and source of wealth
We may ask you to show where the money you are playing with came from. This is a legal requirement rather than curiosity, and it is triggered by thresholds and by patterns, not by whether you have won.
- Documents we typically ask for: recent payslips, a bank statement covering the deposits in question, a tax assessment, or evidence of a sale, inheritance or settlement.
- Until the request is satisfied the account is restricted. Deposits are stopped and withdrawals are held.
- If the request cannot be satisfied, the account is closed and the balance is returned to its source where the law permits.
3. Monitoring
Transactions are monitored automatically and reviewed manually where a rule fires. Patterns that draw attention include deposits followed immediately by a withdrawal with little or no play, deposits broken into amounts that sit just under a reporting threshold, frequent changes of payment method, funding from instruments in other people's names, and activity that does not match the profile of the account.
An alert is not an accusation. Most are resolved in minutes with no contact with the customer at all.
4. Things we do not allow
- Third-party funding. Deposits must come from an instrument in your own name. Money arriving from anyone else is returned and the account is reviewed.
- Using the account as a transfer service. Depositing and withdrawing without genuine play is not permitted, and where we see it we may charge back the processing costs.
- Transfers between player accounts. There is no mechanism for it and requests are refused.
- Anonymous or obscured funding. Payment routes designed to hide the origin of funds are not accepted.
5. Reporting
Where a transaction gives reasonable grounds for suspicion, we are required to report it to the relevant financial intelligence unit. The law prohibits us from telling the customer that a report has been made, and prohibits our staff from doing so. That is why support cannot always explain a restriction in detail, and it is not evasiveness on their part.
6. Records and training
Identification documents, transaction records and the reasoning behind decisions are retained for the period required after an account closes, normally five years. Every member of staff who deals with customers or payments completes anti-money-laundering training on joining and refreshes it annually, with additional training for the compliance and payments teams.
7. Review
The programme is reviewed at least once a year and whenever the law, our licence conditions or our risk profile change. Findings go to the compliance officer, who reports directly to the board.
8. How risk is scored
Every account carries a risk rating, set when it opens and revised as it is used. The rating decides how much evidence we ask for and how closely activity is watched, which is why two customers can have very different experiences of the same rules.
- Standard. Verified identity, ordinary deposits from an instrument in the customer’s own name, play that matches the profile. Checks happen once and stay in the background.
- Elevated. Funding routes that are harder to trace, turnover out of step with what we know, a country on a watch list. Source of funds is requested earlier and reviewed more often.
- High. Politically exposed persons and their close associates, accounts with an adverse media match, anything that looks like money passing through. Senior approval is needed before the account continues, and it is reviewed on a fixed cycle.
9. Sanctions and watch-list screening
Names are screened against international sanctions lists, terrorist financing lists and politically exposed person data when an account opens, and re-screened as those lists change. A match stops the account until it is resolved, because the alternative is breaking the law.
Most matches are coincidences of name and date, and they clear within a day once the paperwork confirms it. Where a genuine match is found, we freeze the account and report it, and we are not permitted to say more than that.
10. Thresholds and cumulative activity
Obligations do not only attach to one large transaction. They attach to a run of smaller ones that adds up to the same thing, which is why a series of modest deposits can trigger the same request as a single big one.
Deliberately splitting transactions to sit under a threshold is itself a reportable pattern. Nobody needs to worry about this when they are playing normally; it exists because some people do it on purpose.
11. Relying on other people’s checks
Where a payment provider or identity service has already verified a customer, we may take that into account, but it does not replace our own obligation. We stay responsible for the checks on our own customers, and we keep our own copies of the evidence rather than pointing at somebody else’s file.
12. Training and independent review
Every new starter who will touch customers or payments completes anti-money-laundering training before they take their first shift, and everyone refreshes it annually. Compliance and payments staff take a longer course covering typologies specific to gambling: chip dumping, bonus abuse rings, third-party funding, mule accounts.
The programme itself is reviewed by someone outside the team that runs it, so the people writing the rules are not the only ones marking their own work. The report goes to the board with the compliance officer’s response attached.