AML Policy

This Anti-Money Laundering (AML) Policy sets out the procedures and controls that 1Win N.V. (registered in Curaçao, company no. 147039), operating under Curaçao eGaming License 8048/JAZ2018-040, implements to prevent money laundering, terrorist financing, and other financial crimes. The policy applies to all players, partners, and transactions conducted through mobilemoney.com.pk. Compliance with this policy is mandatory for all users and is a condition of account access and use of our services.

Legal Framework and Regulatory Scope

1Win operates under the regulatory framework established by the Financial Action Task Force (FATF) Recommendations and international standards for combating money laundering and the financing of terrorism. As a Curaçao-licensed operator, we comply with the requirements of the Curaçao Gaming Control Board and applicable anti-money laundering legislation. Our compliance obligations extend to all jurisdictions in which we offer services, including Pakistan, and we adhere to local regulatory expectations regarding financial crime prevention.

Customer Due Diligence (CDD)

All players must complete Customer Due Diligence verification before depositing funds or placing bets. CDD is a fundamental control that enables us to verify your identity and assess the risk profile of your account.

You must provide a valid government-issued photo identification document (passport, national ID card, or driving licence).
You must provide proof of your residential address, dated within the last three months (utility bill, bank statement, or official letter).
You must disclose your date of birth, nationality, and occupation.
You must confirm that you are not a Politically Exposed Person (PEP) or a relative of a PEP.
You must declare the source of funds used for deposits.
All documents must be clear, legible, and match the information provided during account registration.

Verification is typically completed within 24 hours. If documents are unclear or information is inconsistent, we will request resubmission. Account functionality may be restricted until CDD is fully satisfied.

Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to accounts identified as higher risk. This includes players with cumulative deposits exceeding approximately PKR 500,000 within a calendar year, those from high-risk jurisdictions, PEPs and their family members, players engaged in high-value transactions, or those whose transaction patterns suggest potential money laundering risk.

Detailed source of funds documentation (employment contracts, business registration, investment statements, inheritance documents).
Bank statements covering the previous three months.
Beneficial ownership disclosure if the account is held in a corporate or trust structure.
Enhanced identity verification using third-party data sources.
Ongoing transaction monitoring at increased frequency.

Transaction Monitoring and Suspicious Activity Detection

1Win employs automated transaction monitoring systems to detect patterns consistent with money laundering or terrorist financing. Suspicious transactions are flagged for manual review by our compliance team.

Rapid deposits followed by immediate withdrawal requests without gaming activity.
Multiple deposits from different payment methods within a short timeframe.
Structuring: deposits deliberately kept below reporting thresholds to avoid detection.
Transactions inconsistent with the player's declared source of funds or profile.
Unusual geographic patterns or use of high-risk payment methods.
Unusually large single transactions or cumulative monthly volumes.
Round-sum deposits with no corresponding gaming engagement.

When suspicious activity is detected, the account is placed under enhanced monitoring. We may request additional documentation, freeze the account pending investigation, or file a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit.

Reporting Obligations

1Win is obligated to report suspicious transactions and activities to the Financial Intelligence Unit (FIU) of the relevant jurisdiction. Reports are filed in accordance with applicable legal timelines, typically within 10 business days of detection. We do not disclose to players that a SAR has been filed, as such disclosure is prohibited by law.

Sanctions and PEP Screening

All players are screened against international sanctions lists, including those maintained by the United Nations, the European Union, the United States Office of Foreign Assets Control (OFAC), and other relevant authorities. We also screen against databases of Politically Exposed Persons to identify high-risk individuals.

Screening occurs at account registration and on an ongoing basis.
Matches are reviewed for false positives before action is taken.
Confirmed matches result in account closure and reporting to authorities.
No transactions are processed for sanctioned individuals or entities.

Record Keeping and Data Retention

1Win maintains comprehensive records of all customer verification documents, transaction histories, and compliance decisions. Records are retained for a minimum of five years after the closure of your account or the end of the business relationship, in accordance with regulatory requirements.

Identity verification documents and supporting evidence.
Transaction records, including deposits, withdrawals, and gaming activity.
Correspondence related to compliance inquiries or document requests.
Suspicious Activity Reports and related investigation files.
Sanctions screening results and PEP screening outcomes.

Records are stored securely with restricted access and are made available to regulatory authorities and auditors upon request.

Money Laundering Reporting Officer (MLRO)

1Win has appointed a Money Laundering Reporting Officer responsible for overseeing AML compliance, investigating suspicious activities, and filing reports with the Financial Intelligence Unit. The MLRO has direct access to senior management and the board and operates independently from commercial pressures.

Reviewing and approving all Suspicious Activity Reports.
Conducting internal investigations into flagged transactions.
Ensuring staff training and awareness of AML obligations.
Maintaining AML policies and procedures.
Liaising with regulatory authorities and external compliance advisors.

Staff Training and Awareness

All employees and contractors involved in customer-facing or transaction-processing roles receive mandatory AML training upon hire and annually thereafter. Training covers money laundering typologies, red flags, reporting procedures, and regulatory obligations. Records of training completion are maintained and made available to auditors.

Player Responsibilities

You are responsible for providing accurate, truthful, and complete information during account registration and verification. This includes your identity, residential address, date of birth, occupation, and the source of funds used for deposits.

You must not use false, forged, or misleading documents.
You must not allow another person to use your account or deposit funds on your behalf.
You must promptly notify 1Win of any changes to your personal information.
You must not engage in structuring or other attempts to circumvent AML controls.
You must not use the platform to facilitate money laundering or terrorist financing.

Failure to comply with these obligations may result in account suspension, forfeiture of funds, and reporting to law enforcement authorities. For more information about our services and compliance framework, visit the 1win official site.