CoinPoker AML Policy: Customer Verification, Risk Checks and Compliance

The CoinPoker AML framework covers customer identification, risk assessment, ongoing monitoring and suspicious transaction reporting. The policy applies to fiat transactions within the customer relationship, and due diligence continues after an account has been established. This page explains what verification and compliance checks may apply when using fiat deposits or withdrawals.
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How CoinPoker Verifies Customer Identity 

During CoinPoker’s verification process, customer identity is established remotely. Fiat deposits and proposed withdrawals trigger requests for identity and address evidence. Any submitted scans or photographs must be clear enough for review. 

  1. Enter personal details: provide your legal name, date of birth, address, phone number and email.
  2. Add identity evidence: upload a national ID card, passport or driving licence.
  3. Provide address evidence: submit a utility bill or bank statement issued within 6 months.
  4. Check consistency: make sure document details match the information entered during sign up.

Missing or unsuitable evidence can lead to another document request. Conflicting application and document details can result in account closure. Customers below the lawful gambling age or restricted from gambling are not accepted.

CoinPoker Customer Risk Categories and Enhanced Checks

As part of CoinPoker’s customer risk assessment, information is reviewed against defined risk factors. These include adverse media, politically exposed person status, sanctions listings and higher-risk geographical factors. Reliable public and independent sources may also be used during the assessment. 

Risk categoryCriteriaPolicy result
Lowno listed factor appliesrelationship may be established
Mediumno more than 1 factor appliesEnhanced Due Diligence may apply
Highat least 2 factors applyrelationship is not established

Enhanced Due Diligence may involve additional explanations and supporting documents, as well as senior management review. Customers may also be asked to provide evidence relating to their source of funds or source of wealth. If the identified risk cannot be sufficiently reduced, CoinPoker may decline to establish the business relationship. 

Ongoing Monitoring of CoinPoker Accounts Worldwide

Within CoinPoker ongoing due diligence, transactions and customer behaviour remain under review. Monitoring can identify concerns linked to deposits, promotion abuse, duplicate accounts, unfair external influences, fraud or criminal activity. Customer records are reviewed for relevance.

Standard information is updated at least once every 24 months. Where Enhanced Due Diligence applied during onboarding, updates occur at least once every 12 months. Failure to provide requested updates within a reasonable time may lead to termination.

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Unusual Transactions, Reporting and Record Retention

Under the CoinPoker AML process, unusual activity includes transactions inconsistent with normal customer behaviour. Recorded concerns are escalated internally to a senior manager without undue delay. An authorised case can then be reported to the supervisory authority.

Special attention applies to:

  • complex transactions with unusual characteristics;
  • unusually large transactions;
  • patterns lacking an apparent economic or visible lawful purpose.

Suspicious transaction findings are retained for at least 5 years. Customer information and documents are stored electronically for 5 years after the relationship ends. Data may be shared with an AML authority when required by law or to prevent money laundering.

FAQ

Does CoinPoker separately identify the beneficial owner after remote verification?

Once the customer is identified remotely, the beneficial owner is deemed identified as well. This follows the policy’s identification procedure. Later due diligence can still apply.

Can CoinPoker request another proof document for an individual case?

Yes. Another proof document may be requested for a particular case. It must support the verification being carried out.

Who signs the AML risk report before CoinPoker files it?

The Executive Director prepares the report for the Money Laundering Reporting Officer. Both the Executive Director and Non Executive Director sign it before filing. The reporting officer submits it to authorities.

What happens if CoinPoker does not authorise external reporting of an unusual transaction?

Relevant documents are kept internally. The reason for non authorisation is documented and signed by the senior manager. Those records remain subject to retention rules.

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