Aml

Introduction

777lw operates under the Curaçao Gaming Authority license and maintains this Anti-Money Laundering (AML) policy to prevent money laundering and terrorist financing across all activities and markets. This policy applies to all employees, contractors, agents, and customers and governs all services provided by 777lw, including games of chance and related financial transactions.

Regulatory framework and risk-based approach

777lw implements a risk-based framework for AML compliance. The operator conducts an initial customer risk assessment during onboarding, performs ongoing monitoring based on risk profiles, and maintains an auditable record of actions to support regulatory inquiries. Senior management bears ultimate responsibility for AML compliance and allocates appropriate resources.

Customer due diligence and verification

Customers must undergo verification of identity, address, and payment methods before engaging in certain activities or before withdrawals are permitted. Documentation accepted includes the following:

• Identity verification: government-issued documents showing name, date of birth, and photograph. Acceptable documents include a passport, national identity card, or driver’s license, provided the document is valid and clearly legible.
• Address verification: utility bill, bank statement, or official government correspondence dated within the last three months.
• Payment verification: for card payments, a copy of the front of the card showing the first six and last four digits (CVV redacted); for electronic wallets or bank transfers, a screenshot or statement confirming ownership of the payment method.

Age verification: all players must be at least 18 years old or the legal age in their jurisdiction. If underage status is suspected, the account is suspended pending verification.

Enhanced Due Diligence

High-risk customers or transactions trigger Enhanced Due Diligence (EDD). 777lw may request additional documentation and apply heightened monitoring, including:

• Proof of source of funds or wealth, such as bank statements or third-party verification where appropriate.
• Additional identity verification measures and updating risk profiles.
• Ongoing, intensified monitoring of transactions and activity patterns.

Ongoing monitoring and risk assessment

777lw conducts ongoing monitoring of customer activity on a risk-sensitive basis. The operator reviews deposits, wagering, turnover, and payout patterns to identify anomalies or deviations from established profiles and to ensure funds are not used to move value illicitly. Risk profiles are updated in response to significant events or new information.

Suspicious activity reporting and escalation

Employees must report grounds for knowledge or suspicion of money laundering or terrorist financing to the Money Laundering Reporting Officer (MLRO). Suspicious Activity Reports (SARs) are submitted confidentially and escalated promptly. Disclosure or tipping off to the customer or any other person is strictly prohibited and may carry criminal penalties. AML concerns are handled discreetly to preserve investigation integrity.

MLRO and governance

777lw designates a Money Laundering Reporting Officer who has authority to receive disclosures, liaise with regulators, and file required external reports. The MLRO has independent authority and access to resources necessary to perform duties and may act promptly to protect the business and customers from risk.

Withdrawal and transaction controls

Before processing any withdrawal, 777lw reviews the following: (1) customer deposit history to confirm consistency with wagering activity; (2) customer turnover and whether funds are being moved without legitimate gaming activity; (3) ownership of the funding source and consistency with the customer profile. Where possible, funds are returned to the original payment method used for the deposit.

Record keeping and data retention

777lw maintains an auditable trail of AML-related activity. Records include identification and verification materials, transaction monitoring results, SARs, internal communications, training records, and regulator or law enforcement communications. Records are retained for as long as required by applicable law to assist investigations and regulatory reviews.

High-risk jurisdictions

When a customer is located in or transacts with a high-risk jurisdiction identified by FATF guidance or relevant regulators, 777lw applies Enhanced Due Diligence or may restrict or refuse service in accordance with applicable law and supervisory expectations.

Training and awareness

All staff receive AML/CTF training on appointment and at regular intervals thereafter. Training covers customer due diligence, SAR reporting, escalation procedures, and the legal consequences of non-compliance. Personnel are expected to apply training to daily operations and gaming activities.

Data protection and privacy

Personal data collected for AML purposes is processed in compliance with applicable data protection laws. Access to such data is restricted to authorized personnel and is used solely for compliance, regulatory reporting, and related investigations.

Compliance, risk governance, and penalties

777lw maintains a formal compliance and risk governance framework. The Compliance Officer and MLRO meet with senior management no less than quarterly. Non-compliance by any employee may result in disciplinary action, including termination, and may entail penalties under AML and counter-terrorism legislation. Regulators may impose sanctions for tipping off, failure to report, or enabling money laundering.