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Anti-Money Laundering Policy

Platform1 is committed to preventing money laundering, terrorist financing, and maintaining the highest standards of compliance in accordance with international regulations and Estonian law.

πŸ“… Last Updated: January 15, 2025
πŸ›‘οΈ Compliance Officer: [email protected]
βš–οΈ Estonian FIU Registered

Policy Overview

As a provider of iGaming solutions, Platform1 operates in a regulated environment where Anti-Money Laundering (AML) compliance is essential. This policy outlines our commitment to detecting, preventing, and reporting suspicious activities that may indicate money laundering or terrorist financing.

Our Commitment

Zero Tolerance: We have a zero-tolerance approach to money laundering and terrorist financing
Full Compliance: We comply with all applicable Estonian and EU regulations
Continuous Monitoring: We continuously monitor transactions and client activities
Staff Training: All staff receive regular AML training and updates

Regulatory Framework

Our AML policy is based on and complies with the following regulatory requirements:

Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFPA)

The primary Estonian legislation governing AML/CTF requirements for financial institutions and service providers.

EU Fifth Anti-Money Laundering Directive (5AMLD)

European Union directive establishing comprehensive AML/CTF frameworks across member states.

Financial Action Task Force (FATF) Recommendations

International standards for combating money laundering and the financing of terrorism and proliferation.

Gaming Industry Specific Regulations

Malta Gaming Authority (MGA), UK Gambling Commission (UKGC), and other gaming regulators' AML requirements.

Customer Due Diligence (CDD)

We implement comprehensive Customer Due Diligence procedures to verify the identity of our clients and assess their risk profile:

Standard Due Diligence

All Clients

When applied: For all new business relationships and transactions above €1,000

Requirements:

  • Identity verification using government-issued documents
  • Proof of address verification
  • Business registration documents (for corporate clients)
  • Source of funds declaration
  • Beneficial ownership identification

Enhanced Due Diligence (EDD)

High Risk

When applied: For high-risk clients, PEPs, or transactions above €15,000

Additional requirements:

  • Enhanced identity verification and background checks
  • Source of wealth documentation
  • Ongoing monitoring of business relationship
  • Senior management approval for relationship
  • Regular review of risk assessment

Simplified Due Diligence (SDD)

Low Risk

When applied: For low-risk clients from low-risk jurisdictions

Reduced requirements:

  • Basic identity verification
  • Simplified documentation requirements
  • Reduced ongoing monitoring
  • Risk-based approach to verification timing

Risk Assessment Framework

We maintain a comprehensive risk assessment framework that evaluates various risk factors:

Geographic Risk

High Risk Countries: FATF blacklisted countries, countries with inadequate AML/CTF systems

Medium Risk Countries: Countries under FATF monitoring or with deficiencies

Low Risk Countries: EU/EEA countries, countries with robust AML/CTF frameworks

Customer Risk

High Risk: PEPs, sanctioned individuals, cash-intensive businesses, offshore entities

Medium Risk: High-value transactions, unusual business activities, complex ownership structures

Low Risk: Established businesses, transparent ownership, reasonable transaction patterns

Product/Service Risk

High Risk: Large cash transactions, anonymous transactions, cross-border services

Medium Risk: Digital payments, cryptocurrency integration, high-value gaming

Low Risk: Standard gaming services, transparent payment methods, regulated markets

Transaction Risk

High Risk: Transactions >€15,000, unusual patterns, frequent large deposits/withdrawals

Medium Risk: Transactions €1,000-€15,000, occasional large transactions

Low Risk: Transactions <€1,000, consistent patterns, reasonable gaming activity

Prohibited Activities

Platform1 strictly prohibits the following activities and will terminate business relationships where such activities are suspected:

Money Laundering

Zero Tolerance

Any attempt to disguise the origins of illicitly obtained funds through our gaming platforms or services.

  • Layering funds through multiple gaming transactions
  • Using gaming accounts for fund transfers
  • Converting criminal proceeds into gaming credits

Terrorist Financing

Zero Tolerance

Providing financial support or services to terrorist organizations or activities.

  • Transactions involving sanctioned individuals or entities
  • Fund transfers to terrorist-linked accounts
  • Services for individuals on terrorism watch lists

Sanctions Evasion

Zero Tolerance

Circumventing international sanctions or embargoes.

  • Services to sanctioned countries or regions
  • Transactions involving blocked persons
  • Facilitating sanctions circumvention

Structuring Transactions

Prohibited

Breaking down large transactions to avoid reporting thresholds.

  • Multiple transactions just below reporting limits
  • Coordinated activities across multiple accounts
  • Deliberate avoidance of CDD procedures

Transaction Monitoring & Reporting

We employ sophisticated monitoring systems and procedures to detect suspicious activities:

Automated Transaction Monitoring

Technology: AI-powered transaction monitoring system

Capabilities:

  • Real-time transaction screening
  • Pattern recognition and anomaly detection
  • Risk scoring and alerting
  • Integration with sanctions databases

Manual Review Procedures

Process: Human expert review of flagged transactions

Triggers:

  • High-value transactions (>€10,000)
  • Unusual transaction patterns
  • High-risk customer activities
  • Cross-border transactions

Suspicious Activity Reporting

Authority: Estonian Financial Intelligence Unit (FIU)

Reporting Requirements:

  • Suspicious transactions reported within 3 working days
  • Cash transactions >€10,000 reported
  • All terrorist financing suspicions reported immediately
  • Detailed documentation maintained for 5 years

Reporting Thresholds

Cash Transactions
€10,000
Mandatory reporting to FIU
Suspicious Activities
Any Amount
Report within 3 working days
Terrorist Financing
Any Amount
Immediate reporting required
Enhanced Due Diligence
€15,000
Enhanced verification required

Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

Customer Records

Retention Period: 5 years after relationship ends

Includes:

  • Identity verification documents
  • Proof of address documents
  • Business registration certificates
  • Beneficial ownership information
  • Risk assessment documentation

Transaction Records

Retention Period: 5 years after transaction

Includes:

  • Transaction details and amounts
  • Payment method information
  • Source and destination of funds
  • Purpose of transaction
  • Monitoring and review notes

Compliance Records

Retention Period: 5 years minimum

Includes:

  • Suspicious activity reports
  • Training records
  • Policy updates and approvals
  • Audit reports and findings
  • Regulatory correspondence

Training and Awareness

All Platform1 employees receive comprehensive AML training and regular updates:

Initial Training

Duration: Mandatory for all new employees within 30 days

Content includes:

  • AML/CTF legal requirements
  • Company policies and procedures
  • Risk identification and red flags
  • Reporting procedures and requirements
  • Customer due diligence procedures

Ongoing Training

Frequency: Annual refresher training plus ad-hoc updates

Content includes:

  • Regulatory updates and changes
  • New typologies and threats
  • Case studies and examples
  • System updates and procedures
  • Performance assessment and testing

Specialized Training

Target: Compliance officers and senior management

Content includes:

  • Advanced risk assessment techniques
  • Investigation procedures
  • Regulatory liaison and reporting
  • Industry best practices
  • Technology and system management

Contact Information

Money Laundering Reporting Officer (MLRO)

Secure Line: Available 24/7 for urgent reports
Address: Platform1, Tallinn, Estonia

Estonian Financial Intelligence Unit

Reporting: Electronic reporting system (goAML)
Hotline: Available for suspicious activity reports

Anonymous Reporting

Employees and third parties can report suspicious activities anonymously through our secure reporting channels. All reports are treated confidentially and investigated thoroughly.

Anonymous Email