Ruby Fortune (“we”, “our”, “us”) is committed to the highest standards of anti-money laundering (AML) compliance and counter-terrorist financing. This AML Policy outlines the measures we take to prevent the use of our platform for illicit financial activities.
1. Purpose
The purpose of this policy is to:
- Prevent and detect money laundering and terrorist financing activities.
- Comply with all applicable AML laws and regulations, particularly those enforced in New Zealand and internationally.
- Safeguard our operations, reputation, and customers.
- Promote transparency and accountability in all financial transactions.
2. Definition of Money Laundering
Money laundering involves disguising the origins of illegally obtained money so it appears to be from a legitimate source. This typically involves three stages:
- Placement: Introducing illegal funds into the financial system.
- Layering: Concealing the source through complex layers of financial transactions.
- Integration: Returning the funds to the offender in a seemingly legitimate form.
Terrorist financing, although sometimes involving smaller amounts, follows similar concealment tactics.
3. Legal Framework
Ruby Fortune complies with all applicable AML laws and regulations including:
- The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (NZ)
- Financial Action Task Force (FATF) guidelines
- Industry standards applicable to remote gambling operators
4. Know Your Customer (KYC)
We conduct thorough KYC procedures to verify the identity and age of our users before they can engage in gambling or financial transactions.
KYC Requirements:
- Full legal name
- Date of birth (must be 18+)
- Residential address
- Valid government-issued photo identification
- Proof of address (e.g., utility bill, bank statement)
- Source of funds (in high-risk cases)
Verification is mandatory upon registration, prior to making deposits or withdrawals, and when suspicious behavior is detected.
5. Ongoing Monitoring
We continuously monitor user activity to detect suspicious or unusual behavior. This includes:
- Frequent large deposits or withdrawals
- Multiple accounts under one identity or IP address
- Use of anonymous payment methods
- Transactions inconsistent with known user behavior
- Reluctance to provide KYC documents
Any such activity may trigger a formal review, temporary suspension, or reporting to authorities.
6. Risk-Based Approach
We adopt a risk-based approach to AML compliance, allowing us to apply greater scrutiny to high-risk customers or jurisdictions.
Risk Factors Include:
- High-volume players
- Politically Exposed Persons (PEPs)
- Users from high-risk countries
- Unusual deposit/withdrawal patterns
Higher-risk users may be subject to enhanced due diligence (EDD), which could include requesting more detailed source-of-funds documentation and more frequent monitoring.
7. Reporting Suspicious Activity
All suspicious activities are reported to the appropriate authority, such as New Zealand’s Financial Intelligence Unit (FIU).
Suspicious Activity Reports (SARs) will be filed when:
- We suspect money laundering or terrorist financing
- There is unusual user behavior without clear economic justification
- A customer refuses to provide requested documents or information
Employees are required to report suspicions internally before escalating them to the designated AML Compliance Officer (AMLCO).
8. Record Keeping
We maintain records of:
- KYC documents
- Customer transactions
- Suspicious Activity Reports (SARs)
- Communication with law enforcement agencies
These records are securely stored and retained for a minimum of 7 years in compliance with legal requirements.
9. Staff Training
All relevant employees receive regular training on:
- AML legislation and regulations
- Identifying and reporting suspicious activity
- KYC procedures
- Data handling and privacy
Training is updated annually or as needed based on regulatory changes or internal reviews.
10. AML Compliance Officer
Ruby Fortune has appointed an AML Compliance Officer (AMLCO) responsible for:
- Developing and implementing AML procedures
- Ensuring staff training and awareness
- Monitoring compliance
- Filing Suspicious Activity Reports (SARs)
- Acting as liaison with regulatory authorities
11. Cooperation with Authorities
We fully cooperate with law enforcement and regulatory agencies during AML investigations, and we reserve the right to freeze or close accounts pending investigation or upon request by competent authorities.
12. Policy Review
This AML Policy is reviewed at least annually and updated to reflect changes in regulations, technology, or business operations.
Contact Information
Ruby Fortune
📍 586 Victoria Street, Hamilton Central, Hamilton 3204, New Zealand
📧 [email protected]
🌐 www.wendycainphotography.com
