1. Introduction
Skybook.ag, operated by INTERNATIONAL RADICAL INVESTMENT SOCIEDAD ANONIMA (hereinafter "Skybook"), is dedicated to combating money laundering and adhering to all relevant laws and regulations aimed at preventing money laundering and terrorist financing activities. This AML Policy outlines Skybook’s commitment to implementing effective measures to detect, prevent, and report suspicious activities.
2. Legal and Regulatory Framework
Skybook operates under the laws of Costa Rica and holds a license in Curaçao under Licence GLH-OCCHKTW0703302016 issued by Gaming Services Provider N.V. Skybook adheres strictly to AML regulations and guidelines established by these jurisdictions, as well as international standards.
3. Appointment of AML Compliance Officer
Skybook has designated an AML Compliance Officer responsible for overseeing the implementation of this AML Policy, ensuring compliance with applicable regulations, and assessing the effectiveness of AML procedures on an ongoing basis.
4. Customer Due Diligence (CDD)
4.1 Identification and Verification: Skybook conducts comprehensive customer due diligence (CDD) on all customers to verify their identity using credible and independent sources. This process includes obtaining and verifying identification documents such as passports, or national ID cards to ensure the accuracy of provided information.
4.2 Enhanced Due Diligence (EDD): Enhanced due diligence is conducted for customers posing higher risks, including politically exposed persons (PEPs) and those from jurisdictions identified as high-risk. This involves gathering additional information and obtaining approval from senior management before establishing business relationships.
4.3 Ongoing Monitoring: Skybook continuously monitors customer transactions and account activities to identify any unusual or suspicious patterns that may indicate potential money laundering or terrorist financing activities.
5. Reporting of Suspicious Activity
5.1 Internal Reporting: Skybook employees are required to promptly report any suspicious transactions or activities to the designated AML Compliance Officer upon detection.
5.2 External Reporting: Skybook is committed to filing suspicious activity reports (SARs) with relevant authorities as mandated by law. Skybook also collaborates fully with law enforcement agencies during investigations related to money laundering or terrorist financing.
6. Record Keeping
Skybook maintains comprehensive records of all transactions, customer identification and verification documents, and SARs for a period stipulated by applicable laws and regulations.
7. Employee Training
Regular training is provided to all Skybook employees to ensure they are knowledgeable about identifying and handling transactions and activities that may be indicative of money laundering or terrorist financing. Training programs are regularly updated to align with current legal requirements and industry best practices.
8. Risk Assessment and Management
8.1 Risk Assessment: Skybook conducts periodic assessments to identify and evaluate the risks associated with money laundering and terrorist financing in its business operations. Factors considered include customer profiles, transaction volumes, geographical locations, and types of services offered.
8.2 Risk Mitigation: Based on the risk assessment findings, Skybook implements risk-based controls and mitigation measures, including:
- Enhanced Transaction Monitoring: Using automated systems to monitor transactions in real-time to detect suspicious patterns or behaviors.
- Transaction Limits and Controls: Setting transaction limits based on customer risk profiles and subjecting transactions exceeding predetermined thresholds to enhanced scrutiny.
- Enhanced Due Diligence: Implementing additional due diligence measures for high-risk customers, including more rigorous verification processes and ongoing monitoring.
- Suspicious Activity Reporting: Establishing clear procedures for promptly reporting suspicious activities both internally and externally to relevant authorities.
9. Definition of Money Laundering
Money laundering involves the process by which criminals attempt to conceal the illicit origins of their proceeds. This is typically achieved through a series of complex financial transactions designed to make illegally obtained money appear legitimate. The process often includes multiple stages: placement, where the illicit funds are introduced into the financial system; layering, where the money is moved through a series of transactions to obscure its origin; and integration, where the now-laundered money is reintroduced into the economy as apparently legitimate funds. Through these means, criminals aim to transform the proceeds of illegal activities into funds that can be used without suspicion.
10. Compliance Review
The AML Compliance Officer conducts regular reviews of Skybook’s AML Policy and procedures to evaluate their effectiveness and makes necessary updates or improvements as needed.
11. Conclusion
Skybook is dedicated to maintaining a robust AML compliance framework to safeguard its operations and contribute to global efforts against financial crimes. This AML Policy is periodically reviewed and updated to ensure compliance with evolving regulatory requirements and industry standards.