1. Introduction
This Anti-Money Laundering Policy (the "Policy") sets out the principles and procedures adopted by RakeBet ("RakeBet", "we", "us", "our"), operator of rakebet.io, to prevent the use of our services for money laundering (ML), terrorism financing (TF), or any other form of financial crime.
RakeBet operates under its gaming license and complies with applicable AML/CTF laws, regulations and guidance, including FATF (Financial Action Task Force) recommendations applicable to virtual asset service providers and online gaming operators.
This Policy applies to all customers, employees, contractors, and partners of RakeBet, across all products including casino, live casino, and sportsbook, and across all supported payment methods, including cryptocurrencies and local fiat methods.
2. Definitions
- Money Laundering (ML): the process of concealing the origin of funds obtained from criminal activity so they appear legitimate, typically through placement, layering, and integration.
- Terrorism Financing (TF): the provision or collection of funds with the intention or knowledge that they will be used to carry out terrorist acts.
- KYC (Know Your Customer): the process of identifying and verifying the identity of customers. See our KYC Policy.
- CDD / EDD: Customer Due Diligence and Enhanced Due Diligence — graduated levels of identity and source-of-funds verification.
- PEP: Politically Exposed Person — an individual who holds or has held a prominent public function, including their family members and close associates.
- SAR/STR: Suspicious Activity Report / Suspicious Transaction Report filed with the relevant financial intelligence unit.
3. Risk-Based Approach
RakeBet applies a risk-based approach (RBA), allocating compliance resources in proportion to the ML/TF risk presented by each customer, product, geography, and payment channel. Each customer is assigned a risk rating (low, medium, high) at onboarding, which is reviewed continuously based on behavior and transaction patterns.
Risk factors we consider
- Customer risk: PEP status, adverse media, inconsistent identity data, use of anonymizing tools.
- Geographic risk: connection to high-risk or sanctioned jurisdictions as defined by FATF and applicable sanctions lists.
- Product risk: products or features that could facilitate value transfer between users.
- Payment risk: deposits from high-risk crypto sources (mixers, darknet markets, sanctioned addresses) or mismatched fiat payment ownership.
4. Customer Due Diligence
All customers must register a personal account and may only hold one account. Identity verification is performed in accordance with our KYC Policy, applying tiered verification thresholds based on deposit, withdrawal, and lifetime turnover volumes.
Enhanced Due Diligence (EDD)
EDD is applied where higher risk is identified, including but not limited to:
- Customers identified as PEPs or with adverse media findings;
- Cumulative deposits or withdrawals exceeding internal thresholds;
- Deposits originating from high-risk blockchain sources flagged by our chain-analysis tooling;
- Unusual gameplay consistent with value transfer rather than genuine play (e.g., minimal-risk betting, chip dumping).
EDD may include requests for source of funds (SOF) and source of wealth (SOW) documentation, such as payslips, bank statements, tax returns, or evidence of crypto asset acquisition. Accounts may be restricted until EDD is satisfactorily completed.
5. Transaction Monitoring
RakeBet operates automated and manual transaction monitoring designed to detect patterns indicative of ML/TF, including:
- Deposits followed by withdrawal with little or no gameplay (pass-through activity);
- Structuring of deposits or withdrawals to stay below verification thresholds;
- Rapid movement of funds between payment methods or currencies;
- Use of multiple accounts, shared devices, or shared payment instruments;
- Activity inconsistent with the customer's known profile and declared income.
Alerts generated by monitoring systems are reviewed by the compliance team, and accounts may be suspended pending investigation. Withdrawals are processed only to payment methods or wallet addresses controlled by the verified account holder, and, where required, returned via the original deposit method.
6. Crypto-Specific Controls
As a platform that accepts virtual assets, RakeBet applies additional controls to cryptocurrency deposits and withdrawals:
- Blockchain analytics: incoming deposits are screened against chain-analysis providers to identify exposure to mixers, sanctioned addresses, stolen funds, darknet markets, and other illicit sources.
- Risk scoring: deposits exceeding risk thresholds are held for review and may be rejected or returned, and the account subjected to EDD.
- Withdrawal address checks: withdrawal addresses are screened prior to processing; withdrawals to sanctioned or high-risk addresses are blocked.
- No third-party funding: customers must use wallets and payment methods held in their own name or under their own control. Third-party deposits are prohibited.
7. Reporting Obligations
Where the compliance team knows, suspects, or has reasonable grounds to suspect that funds are the proceeds of crime or are linked to TF, a suspicious activity report will be filed with the competent financial intelligence unit without delay, in accordance with applicable law.
RakeBet will not inform the customer that a report has been or may be filed ("tipping off" is strictly prohibited). We cooperate fully with law enforcement and regulatory authorities, subject to applicable legal process.
8. Record Keeping
We retain customer identification documents, account data, transaction records, and compliance investigation files for a minimum of five (5) years after the end of the business relationship, or longer where required by law. Records are stored securely and made available to competent authorities upon lawful request.
9. Sanctions Screening
Customers are screened at onboarding and on an ongoing basis against applicable sanctions lists, including the UN, EU, OFAC, and other relevant lists, as well as PEP and adverse media databases. Residents of restricted or sanctioned jurisdictions are not permitted to open or operate accounts, and matches result in immediate account suspension and escalation to the compliance team.
10. Staff Training
All relevant staff receive AML/CTF training at onboarding and at least annually thereafter, covering red flags, escalation procedures, and legal obligations. The Money Laundering Reporting Officer (MLRO) is responsible for overseeing this Policy, reviewing it at least annually, and reporting to senior management.
11. Contact
Questions about this Policy or compliance-related matters may be directed to our compliance team at compliance@rakebet.io, or through our Contact Us page.