Anti-Money Laundering (AML) Policy for Online Competition Websites

1. Purpose

This policy outlines the commitment of Red Hot Raffles Ltd  to preventing money laundering and terrorist financing in compliance with the UK Anti-Money Laundering (AML) regulations, including the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering Regulations 2017.

2. Scope

This policy applies to all employees, agents, and third-party partners involved in the operation of Red Hot Raffles Ltd’s online competition platform.

3. Definitions

• Money Laundering: The process of concealing the origins of illegally obtained money, typically by passing it through a complex sequence of banking transfers or commercial transactions.
• Terrorist Financing: The act of providing financial support, funded by either legal or illegal means, to individuals or groups involved in terrorism.

4. Risk Assessment

Regular risk assessments will be conducted to identify potential vulnerabilities related to money laundering and terrorist financing within our operations. This includes evaluating customer profiles, transaction patterns, and the nature of competitions offered.

5. Customer Due Diligence (CDD)

• Verification: We will implement robust customer verification procedures, including:
  • Collecting personal information (name, address, date of birth).
  • Verifying identities using government-issued identification documents (e.g., passport, driver’s license).

• Ongoing Monitoring: Continuous monitoring of customer activity will be maintained to identify suspicious transactions or patterns indicative of money laundering.

6. Reporting Suspicious Activity

Employees must report any suspicious activity to the designated Money Laundering Reporting Officer (MLRO) immediately. Suspicion indicators may include, but are not limited to:

• Unusual transaction sizes or frequencies.
• Inconsistent customer information.
• Reluctance from customers to provide information.

7. Record Keeping

All records related to customer due diligence, transactions, and internal reports of suspicious activity will be maintained for a minimum of five years. This will include:

• Customer identification documentation.
• Transaction histories.
• Records of internal communications regarding suspicious activity.

8. Staff Training

Regular training will be provided to all employees to ensure awareness of money laundering risks, the importance of compliance, and the procedures to follow in identifying and reporting suspicious activities.

9. Compliance and Review

This policy will be reviewed annually and updated as necessary to ensure ongoing compliance with UK AML laws and regulations. The MLRO is responsible for ensuring adherence to this policy and for reporting to senior management on AML issues.

10. Conclusion

Red Hot Raffles Ltd is committed to maintaining the highest standards of compliance to prevent money laundering and terrorist financing. This policy reflects our dedication to ethical business practices and the integrity of our operations.