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For Deposits and Withdrawals.
(AML Anti-Money-Laundering policy of oldcaptainbet.com)
oldcaptainbet.com is operated by Cosmogames N.V. having its office at ABRAHAM DE VEERSTRAAT 9, WILLEMSTAD, CURAÇAO. Company Registration number 155512.
We seek to offer the highest security to all of our users and customers on oldcaptainbet.com for that a three step account verification is done in order to insure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.
oldcaptainbet.com also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.
oldcaptainbet.com is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
The AML program of oldcaptainbet.com is designed to be compliant with:
Money Laundering is understood as:
Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
In accordance with the AML legislation, oldcaptainbet.com has appointed the "highest level" for the prevention of ML: The full management of Cosmogames N.V. are in charge.
Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.
The AMLCO is placed under the direct responsibility of the general Management.
Each major change of oldcaptainbet.com AML policy is subject to be approval by the general management of Cosmogames N.V. and the Anti money laundering compliance officer.
Step one verification must be done by every user and customer to withdraw. Regarding of the choice of payment, the amount of payment, the amount of withdraw, the choice of withdraw and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. Following information's must be filled in: first name, second name, date of birth, country of usual residence, gender (optional) and full address.
Step two verification must be done by every user which deposit over 2000 EUR (two thousand Euro) or withdraws any amount. Until step two verification is done the withdraw, tip or deposit will be hold. At Step two verification the user or customer to be instructed how to submit his/her ID for verification. Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different. There may also be an electronic check if the filled in Data from the step one verification is correct. The electronic check may be conducted in various available database to insure the given information`s matches between the filled document and the details from the ID. If an electronic test fails or is not available, the user/customer has the option to provide a proof manually.
Step three verification must be done by every user which deposit over 5000 EUR (five thousand euro) or withdraws over 5000 EUR (five thousand euro). Until step three verification is done the withdraw, tip or deposit will be hold. For step 3 a user/customer to be asked for a source of wealth.
The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles:
Proof of address to be done via different electronic checks, which use various available database. If an electronic check fails or is not available, the user/customer has the option to make a manually proof.
A document must be issued within the last 3 months and proof your state of residence.
For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.
To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible, and all text is readable.
An employee may conduct additional checks and request an additional information if necessary, based on the situation.
If a player deposits over a five thousand euro there is a process of understanding the source of wealth (SOW)
Examples of SOW are: Ownership of business, Employment, Inheritance, Investment, Family
It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or prove.
The account will be frozen if the same user/customer deposits either this amount in one or multiple transactions. An email will be sent to them manually to lead the user/customer through the above and an information on the website itself.
oldcaptainbet.com may also ask for a bank wire/credit card to further insure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
The basic document will be accessible via the setting page on oldcaptainbet.com. Every user has to fill out the following information's: First name, Second name, Nationality, Gender (optional), Date of Birth The document will be created and saved automatically, an employee may do additional checks if necessary based on the situation.
In order to deal with the different risks and different states of wealth in different regions in the world oldcaptainbet.com will categorize every nation in three different regions of risk.
For every nation from the region one the three-step verification is done as described earlier.
For every nation from the region two the three-step verification will be done at lower deposit, withdraw and tip amounts. Step one will be done as usually. Step two will be done after depositing 1000 EUR (one thousand euro), withdrawing 1000 EUR (one thousand euro). Step three will be done after depositing 2500 EUR (two thousand five hundred euro), withdrawing 2500 EUR (two thousand five hundred euro).
Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.
In addition, an algorithmic automated system which is overseen by the AML compliance officer will look for any unusual behaviour and once such case is detected will report it insantly to an employee of oldcaptainbet.com.
Based on a risk level and general experience the employees of oldcaptainbet.com will review and double-checked all such cases detected by the algorithmic automated system or reported by other persons and may redo or do additional checks according to the situation.
In addition, a company team supported by modern, electronic, analytic systems will look for unusual behaviour like: Depositing and withdrawing without long enough sessions. Attempts to use a different means of payment for Deposit and Withdraw, nationality changes, currency changes, behaviour and activity changes as well as checks, if an account is used by it ́s original holder.
Also a User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.
As part of its risk-based approach, oldcaptainbet.com has conducted an AML "Enterprise-wide risk assessment" (EWRA) to identify and understand risks specific to oldcaptainbet.com and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank's operations, customers and transactions and other qualitative and emerging risks.
The identification of AML risk categories is based on oldcaptainbet.com understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.
The EWRA is yearly reassessed.
AML-Compliance ensures that an "ongoing transaction monitoring" is conducted to detect transactions which are unusual or suspicious compared to the customer profile.
This transaction monitoring is conducted on two levels:
oldcaptainbet.com works solely with trusted Payment Service Providers that all have effective AML policies in place in order to prevent the large majority of suspicious deposits to oldcaptainbet.com without proper execution of KYC procedures on the potential customer.
oldcaptainbet.com makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:
Also, the three-step verification with adjusted risk management should provide all necessary information's about all costumers of oldcaptainbet.com at all time.
Also, all transaction must be overseen by employees supervised by the AML compliance officer who is over watched by the general management.
The specific transactions submitted to the customer support manager, possibly through their Compliance Manager may also be subject to due diligence.
Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.
These checks will be done by an automated System, while an Employee crosschecks them for additional security.
The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).
Any oldcaptainbet.com staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.
As a last line of defence against AML oldcaptainbet.com will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.
If fraud or Money Laundering is detected the authorities will be informed.
In its internal procedures, oldcaptainbet.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.
Depending on the result of this examination and on the basis of the information gathered, the AML team:
The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the internal system of oldcaptainbet.com.
Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.
Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.
These data will be safely, encrypted stored offline and online (as appropriate).
oldcaptainbet.com employees will make manual controls on a risk based approve for which they get special training.
The training and awareness program is reflected by its usage:
The content of this training program has to be established in accordance with the kind of business the trainees are working for and the positions they hold. These sessions might be conducted by an experienced AML-specialist either external or employed by the company.
Internal audit regularly establishes missions and reports about AML activities.
All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
oldcaptainbet.com will follow all guidelines and rules of the data protection directive Directive 95/46/EC
If you have any questions about our AML and KYC Policy, please contact us:
If you have any complains about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us: