AML/CTF Policy

Essential Details

Approved By: Ecorpp Management N.V. (Director, Horizonix Corp N.V.)

Oversight Team: Compliance Team at Horizonix Corp N.V.

Launch Date: [To be specified]

Upcoming Review: July 4, 2026 (First check after one year; then every three years moving forward)

1. Our Commitment

At Horizonix Corp N.V. (we’ll call it “the Company” from here on), we’re a fully registered entity under Curaçao’s rules (Reg. No. 166811; HQ at Hanchi Snoa 19, TRIAS Building, Curaçao). We hold a solid license from the Curaçao Gaming Authority. We’re dead serious about keeping our games, platforms, and services safe from being used for shady stuff like washing dirty money (ML), funding terrorism (TF), or supporting weapons of mass destruction (FP). We follow Curaçao’s key laws to the letter, such as the rules on ID checks for services (NOIS, N.G. 2017, no. 92), spotting odd deals (NORUT, N.G. 2017, no. 99), chance-based games (NOGC, N.G. 2024, no. 124), cracking down on ML (NOPML), sanctions rules (N.G. 2014, no. 55), and the Kingdom’s sanctions law (N.G. 2016, no. 54). On top of that, we align with global best practices from the FATF and EU rules like 2015/849, 2018/843, and 2018/1673. This applies to everyone involved—our staff, freelancers, partners, and suppliers.

2. Why This Matters

Our goal with these guidelines is to stay on top of Curaçao’s requirements and worldwide norms, including the fresh rules against ML, TF, and FP that kicked in on January 9, 2025, plus FATF standards and those EU directives. Here’s what we’re aiming for:

• Protect our good name and smooth operations from financial crime threats.
• Use a smart, risk-focused way to spot, weigh, and handle dangers from ML, TF, or FP.
• Put in place solid checks on customers (both players and business partners), business vetting, deal watching, and flagging weird activity.
• Set up strong systems to check and keep tabs on our business-to-business (B2B) partners to meet our duties.
• Build a team mindset around doing things right, with ongoing training, deep background digs, and tight internal checks.
• Stop crimes that could lead to ML or TF, like scams, as covered in EU rule 2018/1673 and similar laws.

3. Who This Covers

This touches everyone in our world:

• Our full team, leaders, and board at Horizonix Corp N.V.
• Outside helpers like vendors, reps, and subs working on our projects.
• Everyday players (B2C) and business clients (B2B), from game fans to platform sharers or service users.

4. Key Terms Explained

• Gaming Platform: Our online setup for bets and games run by Horizonix Corp N.V.
• Money Moves: Things like adding funds, cashing out, bank wires, or swaps—but not bets or payouts from games.
• FIU: Curaçao’s Financial Intelligence Unit, where we send tips on sketchy stuff (SARs).
• High-Profile Folks (PEPs): Big-shot public figures, their close family, or buddies, per EU 2015/849 and related rules.
• Fishy Deal: Any move that raises flags under NORUT—like ones over NAf. 5,000 or hints at ML/TF.
• Real Owner (UBO): The person(s) who truly run or own 25%+ of shares/votes in a customer or group, as in EU 2018/843.
• Funds Origin (SoF): Where the cash for a deal comes from, say a paycheck or game win.
• Wealth Roots (SoW): How a player built their overall pot, from jobs to smart investments.
• Base Crime: Bad acts that create cash ripe for laundering, like cheats or bribes, from EU 2018/1673.

5. Putting It Into Action

We take a practical, risk-smart path to handle AML/CTF, as pushed by the Curaçao Gaming Authority (CGA—formerly the Control Board) and FATF. Let’s break down how we do it.

5.1. Signup Basics

When folks sign up (or later), we ask for core info to know who’s joining:

• Full name;
• Birth date;
• ID from passport, card, or license;
• Gender;
• Home country;
• Full address;
• Email and phone;
• Login name and secure pass.

5.2. Agreeing to Rules

Signups include a nod to our site’s full terms—gotta accept to play.

5.3. Age Gate

Our setup blocks anyone under 18 (or local legal age) from signing up. We double-check birth dates against IDs during deeper reviews.

5.4. Overall Business Check (BRA)

Goal: Spot and tackle ML/TF/FP threats in our daily work. How:

• Our Compliance crew runs a yearly deep dive, refreshing it for big shifts like new games, spots, or laws.
• We look at:
  
  • Player dangers: Big betters, PEPs, or odd earners.
  • Location hazards: Ties to trouble spots (check FATF’s watchlist at https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html or EU 2018/843’s Annex II).
  • Game/service pitfalls: Anon-friendly options like crypto or big-stakes spins.
  • Channel risks: Online-only or middleman setups.
• We pull from FATF alerts, CFATF notes, Transparency International’s graft rankings, EU/U.S. sanction rolls, and more.
• It’s all written up, board-signed, and ready for CGA eyes.
• This shapes our risk limits and defenses, matching FATF’s core advice on smart risk handling.

5.5. Player/Business Risk Check (CRA)

Goal: Gauge threats from players (B2C) and partners (B2B).

For Players:

• Done at start and ongoing.
• We weigh (via FATF Rec. 10 & EU 2015/849): status (PEP? Bad press? Lists?), home turf (risky nations—see Appendix 1), play habits (huge adds, tiny bets, wild spends), pay ways (risky like vouchers/crypto—see chart), scam signs (VPNs, fake multis).

• Scores (low 0-20: light checks; med 21-40: standard plus SoF; high 41+: full EDD with docs and watches) use points like:

For B2B:

• Before teaming up, we vet their anti-crime setup, Curaçao fit, real owners/directors (25%+ per EU 2018/843), ops spots, and service types (shared tech, labels).
• Check against UN/EU/Curaçao rolls (N.G. 2015 nos. 27-30, 65) and PEP tools.
• Scores drive watches and deal terms.

5.6. Who We Welcome (CAP)

Goal: Clear rules on okay-ing players and partners. How:

• Flags big risks: PEPs, listed groups, watchlist homes (Appendix 1), bad press.
• Watch for multis, risky pays, scam vibes.
• Checks scale: Easy for safe, full for dicey.
• No-gos:
  
  • Kids under 18.
  • Listed/PEP auto-no (EU 2015/849; UN lists, Curaçao decrees on Al-Qaida/Taliban/ISIL (N.G. 2015 no. 29), Libya (28), Iran (27), N. Korea (30), Yemen (65)).
  • Missing docs after 2 weeks.
  • Cheats, bonus grabs, rule breaks.
  • Prior bans.
  • Scam signals.
  • Weak B2B crime plans.
  • PEP-owned outfits.
• Block players sans docs or on lists; partners if off Curaçao track.
• Geo-locks bar forbidden zones (Appendix 1).

5.7. Player Vetting (CDD)

Goal: Confirm who’s who and block ML/TF/FP risks, per FATF 10 & EU 2015/849.

For Players—When:

• Deals over NAf. 4k/EUR 2k (solo or chained, EU 2018/843).
• Whiff of crime (scams via 2018/1673).
• ID doubts.
• Signup or bets.

Steps:

• Gather: Name, home, birth, nation, ID num. (Basics for safe folks.)
• Confirm: Fresh photo ID, address proof (bills <3mo, leases, mail). Maybe biometrics or location pings.
• Owner Check: Players solo? Terms say yes; syndicates need UBOs.
• Why Here: Guess activity from chats or stats.
• List/PEP Scan: Hit UN/EU/Curaçao rolls and PEP sites (like knowyourcountry.com) at join and bi-yearly.

Deeper Dive (EDD): For risks (PEPs, big rollers, €2k+): Source proofs (pays, banks, sales), boss okay, extra eyes on odd deals. Light Touch (SDD): Basics for low-risk. Freeze Mode: Sanction hits or crime whiff? Lock funds, SAR to FIU in 7 days. Block after 14-day doc lag; refund source unless hold needed. Keep Watching: Update IDs on expires/changes; scan deals for weird (big ins, splits); full check every 6mo.

For Partners (KYB):

• Get: Biz name, reg, spot, owners (25%+).
• Confirm: Reg docs, articles, director rolls (<3mo), license, plan. Maybe stamped extras.
• Crime Fit: Eye their policies.
• Scans: Owners/directors vs. lists/PEPs.
• Deals: Contracts lock Curaçao rules, quarterly checks.

5.8. Staying Alert

Goal: Match actions to risks, catch odd vibes.

Players:

• ID Refresh: On changes/expires.
• Deal Watch: Probe mismatches (big in/low play, card flips); source-check outliers.
• Habit Scan: Spot ML hints (safe repeats, splits) or gambling woes.
• Risk Tweaks: Re-score on shifts (new PEP?).
• Dicey Ones: Frequent source digs.

Partners:

• Track deals and rule-stick.
• Quarterly control audits.
• Re-check on renews or law tweaks.

5.9. Teaming with Outsiders for Vetting

Goal: Safe handoffs for checks, FATF 17 & EU 2015/849 style. How:

• Okay for regulated partners (pays, etc.) if Curaçao-level standards, data access pact, regular tests.
• We own risk scores, PEP hunts, watches.
• B2B: Only if their land matches standards.
• Agents: Our rules apply, with audits.

5.10. Flagging Weird Deals

Goal: Spot and report ML/TF/FP hints, FATF 20 & EU 2015/849. How:

• Spot: Training covers big deals (NAf.5k/EUR2k cash/chips/pulls), authority tips, listed/PEP ties, flags (big in/low play, small bursts, third-party outs).
• Inside Tip: Staff to Compliance lead with deets, notes, proofs.
• Outside: Lead sends to FIU via goAML in 7 days, English/full docs.
• Lockdown: Block on suspicion (no tip-off, EU 2015/849 Art. 41); freeze on sanctions.
• No Leaks: Can’t clue customers on probes.
• Keep Files: 5+ years for deals/SARs/CDDs, FATF 11.

5.11. Our Full Anti-Crime Setup

Goal: Strong shield against ML/TF/FP. How:

• Rules & Guards: Boss buy-in docs; step-by-steps for checks/reports/watches; auto alerts for slips.
• Lead Role: Top neutral pro runs it—risk digs, rule crafts, trains, SARs, FIU chats; full power for checks/orders.
• Team Prep: Newbies get crime-spot basics (2018/1673 crimes); frontliners on tricks/flags/reports; yearly updates on trends; logs with who/what/when/tests.
• Hire Scrubs: ID/CV/honesty pre-hire; yearly for all, randoms for key spots.
• Outside Eyes: Yearly by pro (2+yr AML, CAMS); tests rules/files/deals/training; report to bosses with fix dates.
• Block Steps: 14-day doc no? Crime whiff? Lists? Lock; refund unless freeze/SAR.

6. Sticking to It & What Happens If Not

Do It: Everyone follows; lead tracks, reports up. If Not: Staff: Warnings to boot. Partners: Cut ties. Legal: Fines/jail via NOIS/NORUT/etc. Biz Hits: Name tarnish, license yank by CGA.

7. Extra Reads

• Local Laws: NOIS (2017/92), NORUT (2017/99), NOGC (2024/124), NOPML, Sanctions (2014/55), Kingdom Act (2016/54).
• Global: FATF, EU 2015/849/2018/843/2018/1673.
• Tips: CGA’s Jan 2025 anti-ML guide.
• Tools: UN/EU lists, FATF watches, Transparency graft index.

8. Reach Out

Questions? Hit Compliance at Horizonix Corp N.V. Email: [email protected]

9. Update Log

10. Where to Find It

Check it out at: https://vashbet.com/page/aml-and-kyc-policy and https://graviracasinoplay.com/page/aml-and-kyc-policy