1. Purpose and scope
PlayBatery.com is owned and operated by ARONELIUM LIMITED. This public policy describes the Company’s approach to preventing money laundering, terrorist financing and fraud in connection with its services. The Company applies a risk-based approach and cooperates with competent authorities in accordance with applicable requirements.
Money laundering involves disguising the criminal origin or ownership of funds or property. Terrorist financing involves providing financial support for terrorist activities and may involve funds from either lawful or unlawful sources.
2. Risk-based due diligence
The Company assesses risks relating to customers, countries and geographical areas, products, services, transactions and delivery channels. Due diligence measures are proportionate to the nature and level of the identified risk.
Additional checks may be required where information is incomplete, inconsistent or doubtful, where circumstances change, or where activity raises concerns about money laundering or terrorist financing.
3. Customer identification and verification
The Company requires customers to provide accurate identification information and supporting evidence. Identity must be established and verified before a business relationship is established, and may be checked again where there are doubts about previously supplied information or concerns about money laundering or terrorist financing.
Checks may include verification against reliable and independent sources, verification of a residential address using a bank statement or utility bill, and verification of an email address using a confirmation link. Customers must keep their information current and cooperate with requests for additional information.
The Company may request identity documents such as a passport, national identity card, residence permit or driver’s licence, together with other information needed to establish identity and assess risk.
4. Enhanced checks and politically exposed persons
Higher-risk circumstances may require additional identity checks and information about the source of funds. Politically exposed persons are individuals who hold or have held prominent public functions. Their close associates and family members may also be subject to additional due diligence.
The Company considers relevant geographical risks and unusual or complex activity when deciding what additional information or checks are required.
5. Monitoring and account restrictions
The Company’s policy requires ongoing review of customer activity and payment methods to assess whether transactions are consistent with the customer’s known circumstances, risk profile and source of funds. Complex or unusually large transactions and unusual patterns without an apparent economic or lawful purpose are subject to further examination.
Where required information is missing, insufficient or suspected to be false, or where a customer refuses to cooperate with due diligence, the Company may refuse to establish or continue a relationship, restrict services, decline transactions or terminate the relationship. Suspicious transactions may be suspended in accordance with applicable requirements.
6. Sanctions
The Company does not undertake actions or transactions prohibited by applicable international sanctions. Relationships and transactions may be restricted, suspended or declined where sanctions requirements apply.
7. Reporting and confidentiality
The Company cooperates with competent supervisory authorities and law enforcement agencies. Suspected money laundering or terrorist financing is reviewed and reported to the appropriate competent authority where required by applicable law.
Legal restrictions may prevent the Company from informing a customer about a suspicious activity report, a planned report or a related investigation. Customer information may be disclosed to competent authorities as required by law.
8. Record retention
The Company’s internal procedure provides for retention of customer identity and account documentation, correspondence and relevant relationship records for five years after the relationship ends. Transaction documentation is retained for five years after the transaction. Relevant investigation records and reporting information are also retained for five years.
Retention periods may be extended following a justified request from a competent authority. Records are maintained for compliance purposes and may be made available to competent authorities where required.
9. Contact
For questions about this public AML Policy or a request for verification information, contact ARONELIUM LIMITED at [email protected]. See also the KYC Policy for the customer identification requirements.