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AML / CFT Policy

Effective from: 01 January, 2026

1. Policy

1.1 General Policy

 

Money laundering and the financing of terrorism pose persistent and material risks to national and international financial systems. Online gaming platforms are exposed to these risks due to the speed, volume, and cross border nature of transactions.

 

Wager.com is committed to preventing the misuse of its services for money laundering, terrorist financing, fraud, or any other criminal activity. Appropriate internal controls, procedures, and monitoring mechanisms are maintained to ensure that the services offered to Account Holders are not exploited for illicit purposes.

 

Wager.com is owned and operated by Scivias Ltd, a company incorporated in the Autonomous Island of Anjouan, Union of Comoros, under registration number 15923, with its registered address at Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros. Scivias Ltd is licensed to conduct online gaming operations by the Government of Comoros under license number ALSI-2025 01037-FI2.

1.2 Objective

 

This policy is established in accordance with the applicable anti money laundering and counter terrorism financing laws and regulations of the Union of Comoros, as well as internationally recognized standards, including those issued by the Financial Action Task Force (FATF).

 

The objective of this policy is to define the principles, controls, and procedures implemented by Wager.com to:

  • • Identify and verify Account Holders
  • • Monitor Player activity and transactions
  • • Detect and prevent suspicious or unusual activity
  • • Report reportable transactions to the competent authorities
  • • Maintain appropriate records
  • • Ensure staff integrity and awareness

 

These measures are designed to deter, detect, and mitigate risks associated with money laundering, terrorist financing, and related predicate offenses.

1.3 Scope

 

This policy applies to:

  • • All services provided by Wager.com
  • • All Account Holders and Players
  • • All directors, officers, employees, and relevant contractors

 

Compliance with this policy is mandatory. Failure to adhere to its provisions may result in disciplinary action, termination of employment or contractual relationship, and reporting to relevant authorities where required.

2. Regulatory Framework

 

2.1 National Regulations

 

Wager.com operates under the legal framework of the Union of Comoros and the Autonomous Island of Anjouan. Money laundering and terrorist financing are criminal offenses under applicable Comorian law.

 

This policy is informed by, and aligned with, national legislation and regulatory instruments addressing:

  • • Anti money laundering
  • • Counter terrorism financing
  • • Predicate criminal offenses
  • • Sanctions compliance
  • • Reporting obligations for unusual or suspicious transactions

 

Where national regulations impose specific or additional obligations, Wager.com implements supplementary procedures to ensure full compliance.

 

 

2.2 International Standards

 

In addition to local legal requirements, Wager.com adheres to internationally accepted AML and CFT standards, including those promulgated by the Financial Action Task Force. These standards inform a risk based approach to customer due diligence, transaction monitoring, recordkeeping, and reporting. Where relevant and appropriate, guidance derived from other internationally recognized regulatory frameworks may also be considered to ensure robust controls and best practice.

3. Procedures

 

Wager.com maintains a comprehensive AML and CFT framework covering the following areas:

  • • Risk management
  • • Know Your Customer procedures
  • • Ongoing monitoring of Account Holder activity
  • • Reporting of unusual or suspicious transactions
  • • Recordkeeping
  • • Staff due diligence

3.1 Risk Management

 

Risk Based Approach

Wager.com applies a risk based approach to identify, assess, and manage risks related to money laundering, terrorist financing, fraud, and other prohibited activities.

Account Holders are classified into risk categories based on behavior, transactional patterns, geographic indicators, and other relevant factors.

 

Risk Classification

The following risk categories are maintained:

  • • Low Risk
  • • High Risk

 

Low Risk

By default, Players are classified as Low Risk and are subject to Standard Due Diligence. This includes identity verification, ongoing monitoring, and periodic review of account activity.

 

High Risk

A Player may be classified as High Risk where indicators suggest elevated risk. This includes, but is not limited to:

  • • Automated system alerts
  • • Irregular or suspicious activity
  • • High risk jurisdictions
  • • Attempts to circumvent controls

 

High Risk Players are subject to Enhanced Due Diligence.

3.2 Know Your Customer (KYC)

 

3.2.1 Identification and Verification

 

No individual may participate in games for money without registering and holding a verified Player Account.

Only one Player Account is permitted per person, per family, and per shared environment.

 

During registration, Players must provide:

  • • Full legal name
  • • Date of birth and confirmation of legal age
  • • Residential address
  • • Valid email address
  • • Payment method details
  • • Username and password
  • • Valid identification documentation
  • • Proof of address

 

Acceptable identification includes a valid passport or government issued identification.

 

Proof of address may include a recent utility bill or bank statement.

 

Geolocation checks are conducted at registration to ensure the Player is located in a permitted jurisdiction. Accounts may be suspended or terminated if false, misleading, or unverifiable information is provided.

3.2.2 Due Diligence

 

Standard Due Diligence

Standard Due Diligence is conducted:

  • • During onboarding
  • • Upon withdrawal requests
  • • When cumulative withdrawals reach EUR 2,000 or equivalent
  • • At the discretion of Wager.com

 

Verification may include document checks and phone verification.

 

Failure to satisfactorily complete verification may result in account suspension, closure, and forfeiture of winnings where permitted by law.

 

Enhanced Due Diligence

Enhanced Due Diligence may include:

  • • Selfie verification with ID
  • • Additional bank statements
  • • Source of funds or source of wealth information
  • • Confirmation of withdrawal destination

 

EDD is applied where elevated risk is identified, including suspected fraud, collusion, multiple accounts, PEP status, or other suspicious behavior.

3.2.3 Money Laundering Reporting Officer (MLRO)

 

Wager.com appoints a Money Laundering Reporting Officer responsible for:

  • • Oversight of KYC and due diligence
  • • Monitoring Player activity
  • • Training staff
  • • Liaison with competent authorities
  • • Ensuring policy compliance and review

3.3 Monitoring of Account Holder Activity

 

Account activity is continuously monitored using automated systems and manual review.

Indicators reviewed include:

  • • False or misleading information
  • • Multiple accounts
  • • Syndicate behavior
  • • Zero risk or abusive betting
  • • Unusual transaction patterns
  • • Use of prohibited software or automation
  • • Access from high risk jurisdictions

3.3.1 Cryptocurrency Transactions

 

Cryptocurrency transactions are permitted only where the initial deposit is made using cryptocurrency. All subsequent transactions must use the same cryptocurrency.

 

Wager.com does not exchange cryptocurrency to fiat currency or vice versa.

 

Additional controls include:

  • • Identity and age verification
  • • Hardware and IP monitoring
  • • Segregation of Player funds
  • • Proof of solvency
  • • Disclosure of cryptocurrency volatility

 

Deposits are permitted solely for gaming purposes. Non gaming deposits and withdrawals are prohibited and may result in account suspension.

3.3.2 Security Reviews

 

Wager.com reserves the right to conduct security and compliance reviews at any time.

 

Third party verification services may be used. During reviews, withdrawals or access to services may be temporarily restricted.

3.4 Reporting of Unusual Transactions

 

Transactions suspected to involve criminal proceeds, concealment, or facilitation of illegal activity may be reported to the relevant financial intelligence authority.

 

The MLRO is responsible for determining reportability and maintaining appropriate documentation.

3.5 Recordkeeping

 

All relevant records are retained for a minimum of five years following the end of the business relationship. Records are maintained to ensure a complete audit trail.

3.6 Staff Due Diligence

 

All employees and relevant contractors are subject to integrity checks, including:

  • • Verification of identity
  • • Review of qualifications
  • • Reference checks

 

Staff receive initial and ongoing AML and CFT training appropriate to their role.