Yy123 operates under the authority of the Curaçao Gaming Control Board. This policy governs Know Your Customer and anti‑money laundering controls for all players and all gaming transactions conducted on the platform, including deposits, bets, and withdrawals. The policy aligns with applicable Curaçao statutory instruments and international best practices for customer due diligence and suspicious activity reporting.
The Company appoints a Compliance Officer responsible for implementing this policy, maintaining records, and coordinating regulatory reporting. The Board conducts an annual review of the policy and facilitates relevant governance processes. Records of decisions made under this policy are retained and available to the Curaçao Gaming Control Board upon request. All regulatory reporting is performed in accordance with applicable law and protection of personal data.
During onboarding, each player is assigned a risk rating based on factors including source of funds, geographic origin, product usage patterns, and channel of onboarding. Risk levels are designated as low, medium, or high. The outcome of the CRA dictates the level of CDD and ongoing monitoring required for the relationship. CRA documentation is maintained by the Compliance Department and subject to regular audit.
CDD is implemented on a risk‑based basis. Triggers for CDD include: a player engaging in transactions equal to or above NAf 4,000; an occasional transaction exceeding NAf 4,000 (individually or as linked transactions); suspicion of ML/TF; doubts about previously obtained information. CDD comprises:
Documents are submitted by players via the Documents tab within the My Account section. Verification timelines are as follows: standard review of submitted documents is completed within three (3) business days after receipt, subject to clarifications or requests for additional information. If withdrawal is requested prior to verification, updated documentation must be provided within 30 days to avoid suspension of the payout request.
On onboarding, players are prompted to upload required documents from the Documents tab. The Compliance team may request additional information if any document is unclear or inconsistent. The process aims to prevent the use of the platform for illicit purposes and to protect players and the operator alike.
All customers undergo ongoing sanctions and PEP screening on onboarding and at regular intervals. If a customer is identified as a PEP or appears on sanctions lists, higher level review and ongoing monitoring are applied. The platform maintains ongoing surveillance of activity patterns to detect unusual or suspicious behavior and to identify potential ML/TF risk throughout the relationship.
EDD is applied where the assessed risk exceeds the institution’s baseline. Measures include: heightened source of funds validation, enhanced review of transaction patterns, increased monitoring frequency, and management approval for continued activity. EDD may involve additional data collection, geo‑fencing, device fingerprinting, or location verification where appropriate and permissible under law.
The Company maintains ongoing monitoring of all active accounts to detect and report suspicious activity. Suspected ML/TF activity is reported to the appropriate authority in accordance with applicable law. The Company will file a UTR where required and will preserve client confidentiality in line with regulatory obligations.
All records generated under this policy, including identities, verification documents, risk assessments, and transaction records, are retained for a minimum of five years following account closure or as otherwise required by law. Access to records is restricted to authorized personnel and regulatory authorities in accordance with data protection provisions.
The operator restricts cash‑based transactions in accordance with applicable law. Cash transfers between individuals in amounts equal to or greater than EUR 12,500 are prohibited; such transactions must be conducted via regulated banking channels, such as bank transfers or electronic payments, where available and compliant with policy rules.
The Compliance Officer is responsible for day‑to‑day AML/KYC operations, including maintaining records, enforcing controls, and coordinating regulatory reporting. Any concerns or requests for information from regulators should be escalated through the formal channels outlined in the governance framework.
Players may contact the Compliance team through the designated secure channels for questions about identity verification, data retention, or requests to review or rectify personal data in accordance with applicable data protection laws.
