Anti-Money Laundering (AML) Policy – Organization

1. Purpose

This policy aims to prevent the use of the organization and its operations for money laundering or terrorist financing. It ensures compliance with applicable laws and regulations.

2. Scope

Applies to all staff, agents, sponsors, partners, and third parties involved with:

• Player transfers

• Sponsorship agreements

• Ticketing and merchandising

• Betting and gambling partnerships

• Payments and financial transactions

3. Legal Framework

This policy aligns with:

• The EU 5th/6th AML Directives (if in Europe)

• The USA PATRIOT Act and Bank Secrecy Act (if in the U.S.)

• FATF Recommendations

• Relevant local AML laws

4. Key Principles

• Risk-Based Approach: Identify and assess risks in all transactions and partnerships.

• Know Your Customer (KYC): Verify identities of players, sponsors, and significant partners.

• Ongoing Monitoring: Continuously monitor high-risk transactions.

• Record Keeping: Maintain records of due diligence and transactions for a minimum of 5 years.

• Reporting Obligations: Report suspicious activity to the relevant Financial Intelligence Unit (FIU) or authority.

5. Roles and Responsibilities

• AML Compliance Officer: Oversees implementation, training, monitoring, and reporting.

• Staff: Must report suspicious activity and follow KYC processes.

• Board/Executive Team: Approves and reviews the AML framework annually.

6. Red Flags

Examples of suspicious activity include:

• Irregular player transfer fees

• Anonymous donations or sponsorships

• Cash-heavy transactions

• Use of offshore accounts or tax havens

• Resistance to KYC checks

7. Training

Annual mandatory AML training for all relevant personnel.

8. Sanctions and Enforcement

Violations of this policy can lead to disciplinary action, including termination and legal reporting.