Anti-Money Laundering (AML) Policy for Opduel.com

Operating under OPDuel

Effective Date: September 30, 2025

Version: 1.0

Approved by: OPDuel Compliance Officer

1. Introduction and Purpose

This Anti-Money Laundering (AML) Policy (“Policy”) sets out the mandatory procedures and controls for Opduel.com (“We,” “the Company,” or “the Platform”), operated by OPDuel, to prevent money laundering, terrorist financing, and other illicit financial activities while ensuring full compliance with applicable laws and regulations.

The primary objectives of this Policy are to:

Detect and deter money laundering and terrorist financing in accordance with Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) requirements.
Implement a risk-based framework for transaction monitoring, reporting, and internal controls.
Protect the integrity of the Company's operations as a provider of cryptocurrency-based online gaming and related financial services.
Promote transparency, accountability, and collaboration with regulatory authorities.

This Policy is aligned with the AML/CFT Laws of Nevis, international standards including the Financial Action Task Force (FATF) Recommendations, and industry best practices for crypto-based platforms. It supplements our separate Know Your Customer (KYC) Policy and is an integral part of our main Terms & Conditions. By using our services, customers agree to be bound by its provisions.

2. Scope

This Policy applies to all aspects of Opduel.com operations, including:

All employees, contractors, and third-party service providers involved in financial transactions, compliance, and risk management.
All customers engaging in deposits, wagers, withdrawals, or other transactions involving cryptocurrencies or fiat equivalents.
Global operations, with adaptations for local regulatory requirements where necessary.

Exclusions: This Policy does not apply to non-financial internal operations unless they impact AML/CFT risks.

3. Core Principles

3.1 Risk-Based Approach

We apply AML/CFT measures proportionate to the risks identified in customer profiles, transactions, products, and jurisdictions. Periodic risk assessments inform the level of due diligence, monitoring, and controls required.

3.2 Transparency

All transactions must be traceable, with prohibitions on anonymous or obfuscated fund flows beyond verified cryptocurrency addresses. Customer identities (verified per our KYC Policy) enable full auditability.

3.3 Accountability

Defined roles ensure enforcement, with the Compliance Officer overseeing implementation, reporting, and liaison with authorities.

3.4 Collaboration

We provide full cooperation with Nevis Licensing Services Inc., financial intelligence units (FIUs), and international bodies, responding promptly to inquiries and investigations.

4. Risk Assessment

4.1 Risk Identification

Comprehensive assessments evaluate:

Customer Profiles: Geographic origins, transaction history, gaming patterns, and associations with high-risk entities.
Products and Services: High-risk games, privacy coins, or large-volume crypto transfers.
Delivery Channels: Online platforms, e-wallets, and direct transfers.
Jurisdictional Risks: Exposure to FATF high-risk or monitored jurisdictions, sanctioned entities, or adverse media.

4.2 Risk Mitigation

Assessment outcomes drive:

Tailored controls to address vulnerabilities.
Enhanced Due Diligence (EDD) for high-risk cases, such as Politically Exposed Persons (PEPs), unusual transaction patterns, or complex structures.
Annual reviews or updates following regulatory changes, operational shifts, or incident triggers.

5. Customer Due Diligence (CDD)

CDD is integrated with our KYC Policy for initial identification but extends to ongoing AML scrutiny. We perform CDD before processing withdrawals or upon cumulative deposits reaching USD $10,000 (or crypto equivalent), whichever occurs first.

5.1 Standard CDD

Review customer profile against risk factors.
Verify source of funds for transactions exceeding thresholds.
Screen against sanctions lists, PEPs, and adverse media databases.

5.2 Enhanced Due Diligence (EDD)

Mandatory for high-risk indicators, including:

PEP status, family, or associates.
Transactions from high-risk jurisdictions.
Patterns lacking economic rationale or inconsistent with profile (e.g., rapid deposits/withdrawals with minimal activity).

EDD requires:

Source of Funds (SOF) or Source of Wealth (SOW) documentation (e.g., bank statements, tax records).
Senior approval and third-party verification if needed.
Continuous monitoring with adjusted thresholds.

6. Record Keeping

6.1 Retention Period

We retain AML/CFT records for at least five (5) years post-transaction or account closure, including:

Transaction logs (deposits, wagers, withdrawals).
Risk assessments, CDD/EDD files, and screening results.
Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), and compliance correspondence.

6.2 Secure Storage & Accessibility

Records are stored in encrypted systems with role-based access. They are available upon legal request from authorities, ensuring audit readiness.

AI-driven systems provide real-time analysis for red flags, such as:

Structuring (e.g., transactions near reporting thresholds).
Use of mixers/tumblers or obfuscation tools.
Links to high-risk jurisdictions, sanctioned addresses, or unusual patterns (e.g., high-volume deposits followed by quick withdrawals).

Alerts trigger immediate review; thresholds include single transactions >$10,000 or aggregated weekly volumes >$50,000.

7.2 Suspicious Activity Reports (SARs)

Suspected activities are investigated by the Compliance Officer. Confirmed suspicions result in SAR filing with Nevis Licensing Services Inc. and relevant FIUs within 24 hours. No "tipping off" of customers is permitted.

7.3 Currency Transaction Reports (CTRs)

Transactions exceeding $10,000 USD (or equivalent) in 24 hours are reported automatically, regardless of suspicion.

8. Internal Controls

8.1 Policies and Procedures

Written AML procedures cover risk assessment, monitoring, reporting, and training, reviewed annually.

8.2 Compliance Officer

The designated officer oversees the AML program, ensures reporting, and serves as the regulatory liaison.

8.3 Employee Training

Mandatory training covers red flag identification, escalation, and procedures—delivered at onboarding, annually, and post-changes.

9. Cybersecurity and Data Protection

9.1 Data Integrity

AML data is maintained accurately and protected against tampering.

9.2 System Security

Measures include encryption (SSL/TLS), firewalls, intrusion detection, and regular penetration testing.

9.3 Breach Reporting

Significant breaches affecting AML data are reported to Nevis Licensing Services Inc. within 24 hours.

10. Independent Audits

10.1 Annual AML Audit

Third-party audits evaluate program effectiveness, compliance, and controls annually.

10.2 Regulatory Oversight

Authorities may conduct unannounced inspections.

11. Penalties for Non-Compliance

Customer violations (e.g., suspicious transactions) may lead to account suspension, fund forfeiture, and law enforcement referral. Company non-compliance risks fines, license revocation, or prosecution.

12. Continuous Improvement

We monitor regulatory developments, adopt technologies like blockchain analytics and AI monitoring, and engage in industry forums to enhance our framework.

Acknowledgment

This AML Policy supplements the Terms & Conditions and KYC Policy of Opduel.com. By using our services, you acknowledge reading, understanding, and agreeing to comply.

For questions or to report suspicions, contact [email protected]