AML Policy

1, Harju maakond, Tallinn, Kesklinna linnaosa, Masina tn 22, 10113, Estonia

(AML) Anti-Money Laundering Policy of

Introduction: is a brand name of Big Corgi Development OÜ (ESTONIA) LIMITED, REG NO. 16252850, Having it's registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Masina tn 22, 10113, Estonia

Objective of the Policy: We hope to offer the best security to all of our users on for which account verification is done regularly of our customers and the reason behind this is to simply prove that the details of the person registered is actually correct and that the deposit methods used are not stolen or being used by someone else, which Is to establish the general framework with for the fight against money laundering (ML). also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means. is committed to high standards of anti-money laundering (AML) compliance and requires management & employees to adhere to these standards in preventing the use of its services for money laundering purposes.

The AML program of is designed to be compliant with:

EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”

EU: “Regulation 2015/847 on information accompanying transfers of funds”

EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash


Money Laundering means:

  • The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;
  • The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
  • The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;
  • Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (a), (b) and (c).

Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.


In accordance with the AML legislation, has appointed the “highest level” for the prevention of ML : The D Level Management (Company Management)

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the

The AMLCO is placed under the direct responsibility of the Compliance Officer under the direct responsibility of the Chief Executive Officer.


Each major change of AML policy is subject to approval by the, D Level Management. Enterprise-wide risk assessment

As part of its risk-based approach, has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the products and services the website offers.The customers to whom such products and services are offered, transactions performed by these customers, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.

The identification of AML risk categories is based on understanding of regulatory requirements, regulatory expectations and industry guidance.

The EWRA is yearly reassessed.

MINIMUM STANDARDS has established standards regarding Know-Your-Customer (“KYC”). These standards require due diligence on each risk-associated customer before providing the ability to receive items as offered on via identification and verification of his identity and his representatives and beneficial owners on the basis of documents, data or information obtained from a reliable and independent source compliant with the domestic and European AML legislation and regulation.

Interpretation of the KYC principle begins with identification of the customer by means of the necessary identification documents.

All geographical and user-provided data we obtain enables the Customer Acceptance Policy to be applied. In addition to these objective criteria, there are subjective elements which may arouse suspicions regarding a customer and to which particular attention should be paid.

Finally, as KYC does not involve static data, but dynamic data through the relationship with the customer, it also needs follow-up and ongoing monitoring of the customer.


The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles :

A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning Please note that all four corners of the ID has to be visible in the same image and all details has to be readable.


A recent utility bill sent to your registered address, issued within the last 3 months.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible and all text is readable.

An electricity bill, water bill, bank statement or any governmental post addressed to you is a good example.


For some dedicated higher risk customer categories, a periodically risk-based review is carried out to ensure that customer-related data or information is kept up-to-date.
The current KYC review process regarding the other customer categories is essentially based on an “awareness principle” following the examination of a dedicated file by the AML team. This awareness principle consists in asking the customer’s relationship manager henceforth to closely perform a periodic KYC review of the customer.


AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile. This transaction monitoring is conducted on two levels :

1) The first Line of Control: works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto from taking place without proper execution of KYC procedures onto the potential customer.

2) The second Line of Control: makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:

  • Requests for the execution of financial transactions on the account.
  • Requests in relation to means of payment or services on the account.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behavior and the transaction counterparty.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable). Any staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.

3) The third Line of Control:

The second line of control is supplemented by a risk-based automation and second line of control should include an increased monitoring of transactions of customers considered as high risk.

To accompany these due diligence measures more structural measures should be progressively put in place, like the limitation of cash deposits applicable for each category of customer.

Organization of internal control Suspicious transactions reporting

In its internal procedures, describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, the AML team :

  • Will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
  • Will decide whether or not it is necessary to terminate the business relations with the customer.


The AML rules, including minimum KYC standards have been translated into operational guidance or procedures that are available on the Intranet site of


Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.


CSGORoll has developed different ways of training and awareness in order to keep its staff aware of the AML duties. The training and awareness program is reflected by its usage:

  • A mandatory AML training program in accordance with the latest regulatory evolutions
  • Academic AML learning sessions for all new employees

The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML-specialist working in AML team.


Internal audit regularly establishes missions and reports about AML activities.