Nova88 (the “Company”) is subject to anti-money laundering and counter terrorist financing (AML) legislations, rules and regulations of the Tobique First Nation, which require the Company to have adequate policies, procedures and controls that will identify, assess, and mitigate the risk of money laundering and terrorist financing activities.
The Company, in compliance with the directives and regulations of its relevant regulatory agency, hereby expresses its commitment to combat any potential abuse of its Services and the Website for the purpose of money laundering (ML) and terrorist financing (TF) activities. It is the declared policy of the Company to comply with existing and relevant anti-money laundering and counter terrorist financing legislations and regulations, as well as provisions and guidelines regarding customer due diligence and the reporting of threshold and suspicious transactions.
The Company shall adopt and establish policies and programs consistent with relevant regulations for Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT), that will effectively identify, assess, monitor and control risks associated with ML and TF activities in the regulated jurisdiction. It is likewise the policy of the Company to adopt a Risk-Based AML program that will help mitigate and actively prevent the money laundering and terrorist financing risks that the Company may encounter.
The Company, through its management and responsible senior officers, shall ensure that the business is conducted in conformity with all relevant legislations, rules and regulations and best industry practices and standards in the regulated jurisdiction. The Company commits to fully cooperate with the relevant regulatory agency and other enforcement agencies, within lawful restrictions and regulations. Furthermore, adequate procedures and actions shall be taken when there are reasonable grounds to believe that money laundering and/or terrorist financing activities are being conducted. To ensure awareness, competence and compliance with existing and relevant legislations, rules and regulations relating to AML and CFT, the Company shall provide its management, officers, authorized representatives and employees based in the regulated jurisdiction, to be adequately informed of relevant basic AML/CFT legislations and regulations.
Since the Company is prohibited from keeping anonymous accounts or obviously fictitious names, it shall ensure that effective procedures for securing Player information and verifying the true identity of Players are in place, and that it is not in any way used as an instrument to facilitate money laundering and terrorist financing activities. The Company will establish and verify the true identity of its Players, including the validation of the truthfulness of the information and the authenticity of the Identification Documents presented by its Players and by checking reliable and independent sources and available online databases. The Company collects information from all customers who avail of the Company’s products and services, which emphasizes on measures taken to identify and continuously monitor Players who are engaged in gaming activities. It shall be the policy of the Company to apply a Risk-Based Approach in performing Customer Due Diligence (CDD) measures for all its customers regardless of their economic standing, whenever applicable in the regulated jurisdiction. In this regard, the Company shall apply simplified CDD measures for customers classified as Low-Risk and Normal-Risk, and Enhanced Due Diligence (EDD) measures for High-Risk Customers. On all occasion, the Company shall document how a specific customer was profiled and what standard of customer due diligence measure was applied. It shall be the policy of the Company not to enter into business relationships with individuals who refuse to provide the required Identification Documents, and to terminate business relationships with Players, who after several requests, unreasonably fail and refuse to submit Player Identification Documents.
If the Company suspects or has reasonable grounds to suspect that funds are linked or related to or are to be used for money laundering or terrorism activities, or for funding terrorist acts or terrorist organizations, it shall promptly report its suspicion to the relevant regulatory agencies. The Company shall likewise be responsible for the identification and reporting to the relevant regulatory agency of transactions that will be qualified as suspicious.
With these policies and programs, the Company hopes to promote full compliance with all the relevant legislations, rules and regulations of the Tobique First Nation regarding anti-money laundering and countering terrorist financing, which are at the same time complemented by its KYC policies on its Players.