As a gaming company, FOMO7 must comply with certain legal requirements, including measures to prevent money laundering. We use your personal data to ensure that our services are not used to launder the proceeds of crime and to detect and address any such Anti-Money Laundering (AML) activities.
AML Policy Objective
FOMO7 is committed to being vigilant in preventing money laundering and combating the financing of terrorism, aiming to manage and minimize reputational, legal, and regulatory risks. It also recognizes its social responsibility to prevent serious crime and ensure its systems are not misused for illegal activities.
The platform will stay informed about national and international measures to prevent money laundering and terrorist financing, safeguarding its operations, reputation, and stakeholders from related threats. FOMO7’s policies, procedures, and internal controls are designed to comply with all applicable laws, regulations, and directives, and will be regularly reviewed and updated to ensure continued compliance.
User Identification
The Company will take reasonable steps to verify the identity of all users before providing services, as outlined in the registration process in the Terms and Conditions. A secure online list of all registered users will be maintained, and documents will be retained in compliance with data protection regulations.
Minimum identification information will be collected from each user. Anonymous or fictitious accounts are not allowed. Required information includes:
- Full Name
- Date of Birth (must be over 18)
- Place of Residence
- Valid Email Address
- Username and Password
Verification documents (ID, proof of address) will be requested if there is uncertainty about the user’s information or before any payment exceeding EUR 3,000. The Company may use additional methods for verification, such as public databases, financial references, or financial statements. Users will be informed that their identity may be verified. Verification documents may be requested if any significant user information changes.
Employees noticing any discrepancies in user information must report to the AML Compliance Person, who will decide if further verification or reporting to authorities is needed. Users refusing to disclose information or providing misleading details may have accounts blocked or closed, and authorities may be notified. Also, accounts linked to criminal activity will be immediately frozen.
Due Diligence
Account activity of users will be monitored, with special attention to complex or large transactions. Transactions over EUR 1,000 will be automatically monitored daily, with documents requested if deemed necessary by the AML Compliance Person, who will review monitored activity, determine additional steps, document monitoring procedures, and report suspicious activities.
Indicators of possible money laundering or terrorist financing include unusual or unexplained wire transfers, repeated small deposits, or large/unusual transaction patterns. Employees detecting suspicious activity must notify the AML Compliance Person, who will decide whether further investigation, freezing accounts, or reporting to authorities is needed.
Cash or non-electronic payments are not accepted; only approved methods such as credit/debit cards, electronic transfers, or other authorized methods are allowed. Payments of winnings or refunds will be returned via the same route from which funds originated. Third-party payment processors must have monitoring systems in place, and the AML Compliance Person will ensure agreements with such providers meet regulatory requirements. Transaction records will be maintained according to applicable data protection and retention rules.
Suspicious Transactions
The AML Compliance Person will report any suspicious transactions of EUR 1,000 or more where there is reason to suspect:
- The user is associated with terrorism or on a sanctions list.
- The funds are derived from illegal activity or used to disguise illegal proceeds.
- The transaction has no lawful purpose or is unusual for the user.
- The company is being used to facilitate criminal activity.
Training
Employee training will be conducted under the AML Compliance Person and senior management, at least annually, and updated as needed based on company size, user base, and legal developments. Training will cover:
- Identifying money laundering red flags
- Procedures for escalating unusual activity
- Employees’ roles in compliance
- Record retention policies
- Disciplinary consequences for non-compliance