I. INTRODUCTION
This Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applies to all employees of the Company and is designed to support the prevention and detection of money laundering and terrorism financing activities. The Company maintains a strict zero-tolerance stance toward money laundering, terrorism-related activities, and any other forms of financial crime.
Magix.bet (hereinafter referred to as the “Company” or “Magix.bet”) is committed to proactively ensuring its services are not misused by criminals or terrorist organizations for illegal financial transactions. The key goals of this policy include:
Ensuring full compliance with relevant laws, regulations, and supervisory requirements;
Safeguarding the Company and its employees from legal, regulatory, and financial risks;
Protecting the Company’s reputation from potential damage due to association with money laundering or terrorism financing;
Contributing meaningfully to global efforts aimed at fighting crime and terrorism.
1.1 ANTI-MONEY LAUNDERING
Money laundering refers to the process by which criminals disguise the origins of illicit funds, making them appear to come from lawful sources. This may involve altering the nature, location, or ownership of the funds to avoid detection.
Anti-money laundering (AML) involves the implementation of legal frameworks and controls that compel financial institutions and regulated businesses to prevent, detect, and report suspicious activity.
A comprehensive AML framework requires a jurisdiction to:
Officially recognize money laundering as a criminal offense;
Empower relevant authorities and law enforcement with appropriate investigative tools;
Require organizations to verify customer identities, apply risk-based measures, maintain records, and flag suspicious behavior;
Enable international cooperation and information sharing when necessary.
2. REGULATORY RESPONSIBILITIES
Staff involved in the remote gaming sector must report any information they acquire in the course of business when:
They have knowledge of;
They suspect; or
They have reasonable grounds to suspect that a person is engaged in money laundering or terrorism financing, including spending from criminal proceeds.
These scenarios are collectively considered as triggers for suspicion or knowledge. Authorities expect companies to demonstrate, through supporting documentation, that a risk assessment has been conducted before establishing any business relationship. Furthermore, Customer Due Diligence (CDD) must be carried out to ensure that transaction behavior aligns with the risk profile of the customer.
This policy outlines the measures the Company follows to monitor risk, including circumstances that warrant a Declaration of Source of Funds from customers who present a higher risk of money laundering.
3. AML POLICY PRINCIPLES
The AML policy is guided by the following core principles:
Tailored systems and controls are developed to suit the nature of the business while adhering to applicable legal and regulatory obligations;
Annual risk assessments are conducted to identify inherent AML risks, followed by the adoption of a flexible, proportionate, and cost-effective risk-based approach;
Full support and accountability for AML measures are maintained at the senior management level;
Ongoing evaluation of the adequacy and effectiveness of internal systems and controls is performed;
Transaction records are maintained in accordance with law enforcement requirements to aid investigations into financial crimes;
Comprehensive AML training is provided to all relevant employees at onboarding and on a regular basis thereafter.
Here's a polished and slightly reworded version of Sections 4 and 5 of your AML/KYC policy. The structure has been improved for clarity, while all original information has been preserved or refined for professionalism and readability.
4. RISK MANAGEMENT
Magix.bet has established a structured risk assessment and management policy, as required by the relevant Money Laundering Regulations. This risk-based approach ensures that we apply proportionate measures to manage and mitigate potential money laundering and terrorist financing risks. The core steps of our risk strategy include:
Identifying and assessing the money laundering and terrorist financing risks relevant to our operations;
Developing and implementing controls and procedures to address these identified risks;
Continuously monitoring the effectiveness of these measures and enhancing them where necessary;
Keeping thorough records of actions taken, alongside justifications.
5. SUSPICIOUS ACTIVITY MONITORING
“Suspicious Activity” refers to transactions or behaviors that are inconsistent with a player’s known profile, such as unusual deposit patterns, significant discrepancies in player activity, or behaviors indicative of account misuse. Examples include:
High deposit frequency not aligned with typical player behavior;
Limited or no gaming activity following deposits;
Attempts to process large withdrawals without gameplay.
Enhanced Due Diligence (EDD)
Where suspicion is raised, the Company may conduct Enhanced Due Diligence. This may include requests for:
Valid government-issued ID (e.g., passport or national ID card);
Recent utility bills;
Bank account statements;
Other credible documents proving the identity and financial standing of the user.
EDD measures are triggered based on a player’s risk profile and overall transactional behavior. Investigations may also include inquiries into:
The customer’s employment;
Ownership of assets, including real estate;
Residence and whether it corresponds logically with the user’s financial activity.
5.1 Suspicious Activity Reports (SARs)
When an employee identifies grounds for suspicion or knowledge of possible money laundering or terrorist financing, they are required to report it immediately to the Risk Team. Key principles include:
SARs must be submitted confidentially, in writing, and never via email to protect anonymity;
Employees are strictly prohibited from discussing such matters with the person under suspicion or any third party—this includes avoiding any account notations that may imply suspicion;
Breaches of confidentiality or “tipping off” are considered criminal offenses and may lead to serious legal consequences.
5.2 Monitoring & Withdrawal Procedure
To maintain security, all player activity, including deposits, gameplay, and withdrawal requests, is subject to review. Prior to processing a withdrawal, the following checks are performed:
a. Deposit Review:
Analyze the deposit history for abnormal or suspicious transactions;
Assess the consistency of deposit amounts and frequency with user behavior across the platform.
b. Gameplay Review:
Verify that the user has engaged in genuine gameplay and is not using the platform solely as a financial transfer method.
c. Refund to Original Source:
Where possible, funds are returned via the same payment method used for deposits (see Terms & Conditions).
d. Withdrawal Checklist:
Has the player placed bets or wagers?
Does the withdrawal method belong to the account holder and match previous deposits?
Are the user’s transactions aligned with typical customer activity?
5.3 Withdrawal and Refund Policies
5.3.1 Withdrawals
During withdrawal processing, the Company reserves the right to request additional documentation to verify the identity and account ownership of the user. This may include:
A photo of the user holding their passport or ID (clearly readable);
A photo of the front side of the bank card (showing only the first 5 and last 4 digits, cardholder name, and expiry date).
Timelines:
Users must provide the requested documentation within 72 hours. Failure to do so will result in the withdrawal request being declined.
First-time withdrawals may take up to 72 hours for full verification.
Verified users may expect processing within 24 hours, unless further checks are triggered.
In case of bonus abuse or suspicious activity, withdrawal periods may be extended up to 30 days, pending investigation.
The Company may restrict available withdrawal methods to those previously used for deposits, based on user profile (including currency, location, and payment type). If multiple currencies or virtual assets were used to deposit, the Company may select the withdrawal method at its discretion.
5.3.2 Refunds
Refunds can be requested from the moment funds are credited to a user’s account. The request must be emailed to legal@magix.bet with the following documentation:
A photo of the user holding their passport/ID;
A photo of the bank card (front only, with required digits visible);
Alternatively, bank details certified by a financial institution.
If all documents are not submitted within 72 hours, the refund request will not be processed.
Verification may take up to 72 hours, or longer if required by AML laws or additional risk checks.
The Company may also request proof of the source of funds before issuing refunds. Acceptable evidence includes:
Payslips, dividend statements, or pension documentation;
Bank statements showing regular income from an identifiable source;
Trust deeds detailing entitlement to funds;
Dated documents confirming legal awards or payments made to the user.
Refunds will only be executed upon completion of all verification procedures.
6. EMPLOYEES
6.1 Senior Management
Senior management holds ultimate responsibility for the implementation and effectiveness of this AML policy. They are aware of their personal legal liability for any compliance failures due to consent, neglect, or complicity.
6.2 Money Laundering Reporting Officer (MLRO)
A designated MLRO is responsible for overseeing AML and CTF activities, receiving internal disclosures, making reports to senior management, and submitting external SARs where necessary. The MLRO operates independently and has adequate resources to fulfill their duties.
6.3 Staff Training
All staff receive AML/CTF training, including how to recognize and escalate suspicious activity to the MLRO. Training includes procedures for CDD, EDD, identifying PEPs, and reporting obligations. Employees are reminded of the criminal implications of non-compliance.
7. HIGH-RISK JURISDICTIONS
High-risk jurisdictions are identified through FATF and Gambling Commission guidance. Customers from such countries are subject to Enhanced Due Diligence (EDD), and players from jurisdictions on the FATF blacklist will be refused service.
8. RECORD KEEPING
We maintain a clear audit trail for customer activity and internal investigations to support law enforcement, in line with license requirements.
9. OFFENCES
Employees may face criminal prosecution for:
Failing to report suspicious activity;
Tipping off customers about an investigation or SAR;
Tampering with documents relevant to ongoing investigations.
10. EMPLOYEE VETTING
New employees undergo ID verification to ensure they are of legal working age and provide accurate personal information.
11. INTERNAL ASSET PROTECTION
Key business assets are protected via strict processes and security controls. Our server infrastructure is secured in Curaçao with onsite protections, and similar safeguards are in place in our offices.
12. SUPPLIER DUE DILIGENCE
Suppliers are evaluated on financial stability, compliance history, ethics, and service quality. All must pass a verification and risk assessment process to ensure they meet regulatory and operational standards.
13. INTERNAL RECORDS
We uphold principles of “Know Your Customer” and maintain:
Transaction records for the license-defined retention period;
Customer records post-termination for the license-defined retention period;
AML and SAR-related records for the full legal retention period.
KYC POLICY
Introduction
By using our services, users consent to identity verification checks as required by law and company policy. Access to funds may be restricted during the verification process. Accounts with false or incomplete data may be closed immediately.
Underage gambling is strictly prohibited—any such accounts will be closed, transactions voided, deposits returned, and winnings forfeited.
1. OBJECTIVE
Verification may be triggered by:
Suspicious activity (e.g., fraud, money laundering);
Document inconsistencies or compliance concerns.
Minimum KYC Requirements:
Full name, date of birth, nationality, permanent address, and ID number.
Valid government-issued ID and proof of address.
Additional Requests May Include:
Secondary ID (e.g., driver’s license);
Selfie with ID;
Front of payment card (masked);
Source of funds documentation.
Users must submit requested documents within 72 hours. Verification takes up to 72 hours post-submission unless extended by legal or risk-based requirements.
Documents may be rejected for:
Mismatched or unreadable details;
Unacceptable formats;
Any other reasonable cause.
Phone or video verification may also be required.
2. COMPLIANCE OBLIGATIONS
Due Diligence:
All users are subject to due diligence procedures and ongoing risk monitoring.
Duplicate Accounts:
Multiple accounts may be linked, monitored, or closed if abuse is detected.
Politically Exposed Persons (PEPs):
Enhanced scrutiny is applied to PEPs and their close associates. A risk-based approach is taken depending on activity and geography.
The Company reserves the right to decline or terminate any account if the KYC procedure is not satisfied.