KYC-AML-CFT Policy

1. INTRODUCTION

Raw Entertainment B.V. (hereinafter referred to as “Roobet” or the “Company”) is a company duly incorporated under the laws of Curaçao with Company number 157205 and registered office at Korporaalweg 14, Curaçao, Curaçao, operating the website roobet-bonus.com under license OGL/2024/687/0427 issued by the Government of Curaçao.

As a reputable international business and a recognized participant in the gambling industry, Roobet strictly condemns, prohibits and rejects the use of its website and services for any unlawful activity, including money laundering and the financing of terrorism.

Roobet has implemented a set of internal measures, controls and procedures designed to identify, prevent and discourage illegal activity on its website. These procedures are intended to comply with the applicable Curaçao regulations concerning Anti-Money Laundering and Countering the Financing of Terrorism, while also following accepted industry best practices.

2. WHAT IS MONEY LAUNDERING AND TERRORISM FINANCING?

Money Laundering – Money laundering is the process through which proceeds obtained from criminal activity are processed or “washed” through the financial system in order to conceal their illegal origin. Money laundering is generally divided into 3 stages:

a) Placement – This occurs when illegally obtained money is separated from criminal activity and introduced into the legitimate financial system.

b) Layering – Once the funds enter the legitimate financial system, they are moved through a complex network of financial transactions. This is done to make the trail more difficult to follow and to hide the connection between the funds, the criminals and the unlawful activity.

c) Integration – This stage describes the moment when criminals reintroduce illegally obtained funds into the economy through a seemingly legitimate source or transaction, making the illicit money appear lawful.

Terrorism Financing – Terrorism financing is the process of collecting, receiving or providing funds with the intention or knowledge that such funds may be used to finance or carry out an act of terrorism.

3. HOW DO WE FIGHT IT?

Roobet has established a set of internal measures, procedures and policies that help detect and prevent the use of its website and services for unlawful purposes, including money laundering and terrorism financing. The measures and procedures applied by Roobet are divided into several layers:

a) Internal Policies & Procedures;

b) Know Your Customers;

c) Transaction Monitoring;

d) Governance & Training;

e) Reporting.

4. KNOW YOUR CUSTOMER

Roobet applies appropriate due diligence measures to its players during registration and throughout the ongoing relationship with each player. The due diligence process consists of different stages and may be carried out at different points in time depending on the player’s activity on the website. Through this due diligence process, Roobet may:

a) Verify the player’s identity, including name, date of birth, address and other relevant information;

b) Carry out PEP and Sanctions checks; and

c) Understand the source of the player’s funds where required and appropriate.

5. TRANSACTION MONITORING

At Roobet, we understand that preventing money laundering and terrorism financing also requires careful review of player transactions. For this reason, we have implemented a transaction monitoring system that combines internal tools with external software solutions. These tools help detect, prevent and report potentially unlawful activity on the website by analysing players’ gameplay patterns, transaction behaviour and account activity. This information is also used to assess player risk and to support the review and improvement of our control systems.

6. GOVERNANCE & TRAINING

Roobet has appointed an MLRO, who is responsible for coordinating the implementation of the AML Policy and developing AML initiatives that support the improvement of internal procedures. The MLRO is also responsible for working with relevant stakeholders to review the AML Policy, assess new regulatory requirements and investigate potentially suspicious or unusual activity.

In addition, Roobet is committed to developing AML awareness across its organisation by providing annual AML training to all employees, regardless of their role or seniority level.

7. REPORTING & COLLABORATION

As a regulated Curaçao online casino, Roobet has implemented appropriate procedures to detect and report unusual or suspicious transactions to the Curaçao Financial Intelligence Unit (FIU). Roobet is also prepared to cooperate with government authorities conducting investigations into unlawful activity where such investigations may require Roobet’s assistance or collaboration.

8. CONTACTS

If you have any questions about this policy or wish to report suspicious activity, please contact our support team at [email protected].