1. Governance
A designated Money-Laundering Reporting Officer ('MLRO') owns this program and reports to the Board. Compliance is independent of commercial functions. Policies are reviewed annually and after material regulatory change.
2. Risk Assessment
We conduct an enterprise-wide risk assessment covering customer, geographic, product, delivery-channel, and payment-method risk. Findings drive control calibration, thresholds, and monitoring rules. The assessment is refreshed annually or on material change.
3. Customer Due Diligence (CDD)
All customers complete identity verification before withdrawing funds. See KYC Policy. Simplified due diligence is not offered for real-money play. Enhanced due diligence ('EDD') is applied to high-risk customers (large volume, unusual patterns, PEPs, high-risk jurisdictions).
4. Sanctions and PEP Screening
Every account is screened against consolidated sanctions lists (OFAC SDN, EU, UN, HMT, and equivalents) at onboarding and continuously thereafter. PEP status is assessed and refreshed. Positive matches trigger immediate account freeze pending investigation, and reporting where required.
5. Source of Funds and Wealth
We may request evidence of source of funds and source of wealth at any time, including for cumulative deposits exceeding 1,000 USDT and always for cumulative deposits exceeding 10,000 USDT. Acceptable evidence includes payslips, tax returns, sale contracts, exchange statements, or on-chain records supported by exchange KYC.
6. Blockchain Analytics
Deposit and withdrawal addresses are screened using industry-standard blockchain-analytics providers. Funds traced to sanctioned addresses, mixers, darknet markets, ransomware, thefts, or exchanges with hostile compliance postures are frozen pending investigation and may be reported to authorities and refused withdrawal to the same origin.
7. Transaction Monitoring
Automated monitoring rules cover structuring, rapid deposit-and-withdrawal ('peeling'), unusual gameplay velocity, chip-dumping, dormant-account reactivation, geolocation anomalies, and device-linked multi-accounting. Alerts are triaged by trained analysts. Suspicious activity is escalated to the MLRO.
8. Reporting
We file Suspicious Activity Reports (SARs) with the competent Financial Intelligence Unit (FIU) as required by law and cooperate with law-enforcement requests supported by valid legal process. We do not tip off the subject of a report.
9. Record Keeping
KYC records, transaction data, alerts, investigations, and SARs are retained for at least 5 years after the end of the customer relationship, or longer if required by local law.
10. Training
All staff receive annual AML/CFT training. Compliance and risk staff receive advanced training including virtual-asset typologies.
11. Independent Testing
The program is subject to independent internal audit and, where required, external assurance. Findings are tracked to remediation.
12. Prohibited Activity
- Using the Service to launder, layer, structure, or integrate proceeds of crime.
- Financing of terrorism, sanctioned parties, or proliferation.
- Depositing from addresses associated with mixers, darknet markets, or sanctioned entities.
- Attempting to withdraw to a different beneficial owner than the depositor.
13. Contact
MLRO / Compliance: compliance@tethbet.com.