Scope and Purpose

P56 maintains an anti-money laundering and countering the financing of terrorism (AML/CFT) program to detect, deter, and report activities that may be illegal. This policy governs all customer interactions, account openings, deposits, withdrawals, transfers, and any ongoing activity across the platform. It establishes the minimum requirements for customer identification, risk assessment, due diligence, monitoring, recordkeeping, and reporting in accordance with applicable AML/CFT laws and regulations.

Legal Basis and Standards

P56 complies with all applicable anti-money laundering and counter-terrorism financing laws and regulations. The program is designed to meet the objectives of preventing money laundering, preventing the financing of terrorism, and maintaining public confidence in the integrity of gaming and payments infrastructure. Where law requires, P56 implements stricter measures in response to risk indicators or regulatory guidance.

Customer Identification and Verification (KYC)

P56 shall identify and verify the identity of every customer prior to establishing a business relationship or conducting a transaction, using reliable, independent source documents, data, and information. Verification procedures shall include, at a minimum:

  • Full legal name, date of birth, and current residential address.
  • Government-issued photo ID and, where applicable, proof of address (dated within the last three months).
  • Non-documentary verification where allowed by law, including corroboration of identity through independent data sources and risk assessment outcomes.
  • Ongoing screening against applicable sanctions, politically exposed persons (PEP) lists, and adverse media indicators.

Verification is proportionate to the risk. For lower-risk profiles, verification may rely on basic identity checks; for higher-risk profiles, enhanced verification measures shall be applied.

Risk-Based Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

P56 applies a risk-based approach to due diligence. Customer risk is assessed at account opening and reviewed periodically. The following categories guide due diligence:

  • Low risk: standard identity verification, basic source of funds assessment, and routine monitoring.
  • Medium risk: enhanced verification of source of funds, verification of beneficial ownership where applicable, and more frequent monitoring.
  • High risk: complex ownership structures, non-resident customers, significant or unusual transaction patterns, or customers from high-risk jurisdictions. For high-risk cases, P56 shall perform enhanced due diligence, obtain additional information on the nature of the business, source of wealth, and purpose of activity, and may require documentary evidence and third-party confirmations.

Enhanced due diligence may include senior management approval, additional corroboration of funds, and ongoing enhanced monitoring of activity and counterparties.

Ongoing Monitoring and Transaction Surveillance

P56 employs continuous monitoring of customer activity to detect unusual or suspicious patterns. Monitoring is designed to identify indicators such as;

  • Unclear source of funds or wealth inconsistent with declared activity.
  • Unusually large, rapid, or structured transactions that obscure beneficial ownership or purpose.
  • Transactions with high‑risk jurisdictions or counterparties without legitimate business rationale.
  • Atypical patterns in deposit, withdrawal, or transfer activity relative to the customer’s profile.

Thresholds and trigger events for enhanced review: any single cash deposit or withdrawal exceeding €2,000 (or equivalent in other currencies) or aggregated activity in a 30-day window exceeding €5,000 shall be subjected to enhanced review, source of funds verification, and, where applicable, additional documentation. All suspicious activity shall be escalated to the AML Compliance Officer for investigation and possible reporting.

Recordkeeping and Data Retention

P56 shall maintain complete records of customer identity, verification documents, transactions, and the results of due diligence for a minimum of eight (8) years from the date of the last interaction or as required by applicable law. Records shall be stored securely with access controls, and shall be available for audit by competent authorities on request.

Suspicious Activity Reporting and Cooperation with Authorities

Any transaction or activity that gives rise to suspicion of money laundering, terrorist financing, or related crimes shall be promptly reviewed by the AML Compliance Officer. If warranted by law, P56 will file a suspicious activity report (SAR) with the competent authority and cooperate fully with law enforcement or regulatory bodies. The reporting process shall comply with statutory timelines and preserve customer confidentiality consistent with legal obligations.

Sanctions Screening and High-Risk Geographies

P56 screens customers and counterparties against applicable sanctions lists and imposes enhanced due diligence or transaction blocking for entities or individuals subject to sanctions. Transactions involving high-risk jurisdictions shall be monitored closely, and may be restricted or require explicit approval from senior compliance personnel.

Internal Controls, Training, and Governance

P56 maintains an AML/CFT compliance program overseen by the designated Compliance Officer. All staff undergo AML/CFT training at onboarding and on an ongoing basis, with refresher sessions at least annually. Training covers identification of red flags, reporting procedures, and the proper handling of customer information and sensitive data.

Privacy, Data Protection, and Rights

In processing personal data for AML/CFT purposes, P56 adheres to applicable data protection laws. Access to and processing of personal data is limited to authorized personnel and is conducted solely for purposes related to identity verification, due diligence, risk management, and regulatory reporting. Customers retain rights to access, rectify, or request deletion of their data as permitted by law, subject to legal and regulatory obligations related to AML/CFT obligations and record retention.

Policy Review and Updates

This AML/CFT policy shall be reviewed at least annually or in response to regulatory developments, changes in the risk environment, or material changes to P56’s business model. Updates shall be approved by the Compliance Committee and communicated to customers and staff as appropriate.