LottoHQ is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.
Objective of the Policy
LottoHQ is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimise and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.
LottoHQ will endeavour to keep itself updated with developments both at a national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, LottoHQ and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.
Obligations
In order to adhere to any requirements, regulations and or any guidance notes shall as a minimum:
Appoint one of its senior officers as the designated Money Laundering Reporting Officer (MLRO) whose responsibilities will include the duties required by the laws regulations and guidance notes.
Take reasonable steps to establish the identity of any person for whom it is proposed to provide its service. For this purpose, the process for the registration of Players provided for under the General Terms and Conditions provides for the due diligence process that must be carried out before the opening of a User Account.
Keep at all times a secure online list of all registered Players.
Retain identification and transactional documentation as defined by any regulations and guidance notes.
Provide initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions.
Ensure that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities.
Examine with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.
Report any suspicion, knowledge of money laundering, or terrorism financing to the Authority or Government Agency responsible for the collection, collation, processing, analysis and dissemination of information with a view to prevent money laundering and combat the funding of terrorism.
Cooperate with all relevant administrative, enforcement and judicial authorities in their endeavour to prevent and detect criminal activity.
AML Operational Procedures
In addition to customer registration, and verification policies and procedures, LottoHQ also operates a strict set of AML operational procedures to ensure its risk and exposure to money laundering is reduced and managed effectively.
Will not accept to open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known.
Will not accept cash from customers. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method approved by any licencing authority.
Will not register a Player who is under eighteen (18) years of age.
Will only register a single account in the name of a particular person: multi-account practices are strictly prohibited.
Will monitor all large regular purchases by an individual customer.
All Credit Card Purchases require CVC/CV2 number.
Use a Tokenised System for Credit and Debit Card Transactions.
Restrict the Number of Cards and Payment Sources as Customer may have, and verify those payment sources.
A Daily Spend limit is mandatory for all customers.
All customer interactions with the website will be logged and kept in live transaction audit logs for a rolling 24 month period, older transaction data will be stored in archive databases.
Interaction data captured is all recorded against;
Unique Customer Id Number.
IP Address.
Other Browser data as available (Geocoding/machine address )
All customer winnings and withdrawal request over $500AUD are also subject to automatic flagging for review by the AML Officer, these include;
Checking the source of the payment used to purchase the winning game for validity
Checking the game entries are all correct and no manipulation has occurred.
Transfer payments of winnings or refunds back to the same route from where the funds originated, where possible. Where not possible to transfer back to source credit card due to local or jurisdiction laws, a bank account, verified to the account holder may be used.
Will not accept a wager unless a User Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager.
Will not accept a wager unless the funds necessary to cover the amount of the wager are provided in an approved way.
Will not accept Players residing or playing from non-reputable jurisdictions
Will not make a payment out of a User Account to a Player until the Player’s identity, age and place of residence have been verified.
Will automatically check if no transaction has been recorded on a User Account for thirty months, close the User Account and remit the balance in that account to the Player, or if the Player cannot be satisfactorily located, to the appropriate Lotteries & Gaming Authority.
LottoHQ, where it deems necessary, may verify creditworthiness of the Player with third parties who previously provided any information on the Player.
LottoHQ along with its banking institution and merchant processing facilities investigate and provide evidence against any credit card chargebacks enacted by customers.
LottoHQ Suspends all customer accounts who have issued a chargeback if it is deemed to be valid, the suspension is lifted, if the chargeback is of a fraudulent nature, then the customer account is closed and the user flagged in the database as not to be reactivated or reregistered.
On becoming aware that a person has provided false information when providing due diligence documents, not register such person. Where that person has already been registered, shall immediately cancel that person’s registration as a Player with the company.
