Anti Money Laundering Policy
On top of complying with all conditions as laid out by “The Gambling Act 2005” in relation to prize competitions, Win Amazing Limited has put in place measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.
Win Amazing Limited is committed to preventing money laundering and combat the financing of terrorism in order to minimise and manage its reputational risk, legal risk and regulatory risk. It is also committed to its wider social responsibility in preventing crime by not allowing its systems to be used to commit crimes.
In order to adhere to Anti Money Laundering regulations and requirements, Win Amazing Limited has appointed a designated Money Laundering Reporting Officer (MLRO) whose responsibility it is to report possible acts of money laundering to the authorities. The MLRO is the General Counsel for The Julius Jones Trust.
WinAmazing is committed to taking steps to establish the identity of any person for whom it is proposed to provide its service and at all times a secure online list of all registered Players.
WinAmazing retains identification and transactional documentation for each Player and provides initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions to the MLRO in accordance with this policy.
WinAmazing ensures that this policy is reviewed and maintained on a quarterly basis to ensure it reflects the latest position in law and examines, as much as is possible, the background and purpose of any complex or large transactions or groups of transactions which are likely, by their nature, to be related to money laundering or the funding of terrorism.
WinAmazing will not accept or open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known and will not register a Player who is under eighteen (18) years of age.
WinAmazing will only register a single account in the name of a particular person and will take all necessary steps to ensure that payments of winnings or refunds are transferred back via the same route from where the funds originated, where possible and will not accept cash from Players.
WinAmazing will terminate a Player’s registration if it becomes aware that a person has provided false information when onboarding or has breached any of the terms of this Policy and the WinAmazing website Terms and Conditions and will report any suspicion or knowledge of money laundering of terrorism financing to the authorities.
WinAmazing Prize Draws
The WinAmazing prize draws are programmed to flag up the details of any Player requesting more than 20 weekly entries in the draw. prize draw staff also look for those that have requested over five entries. In both these cases, the Player will be contacted by a member of staff for verification before their payment is processed. If staff are concerned about a Player’s behaviour in requesting large numbers of entries they will report this to a responsible person. The Player will then be contacted for verification. Should suspicion remain, the responsible person will submit a Suspicious Activity Response to the National Crime Agency. In the event of suspicion of, or proven, criminal activity the Player will be barred from participating in the prize draw and the matter reported to the police.
The risk of financial crime, and WinAmazing’s ability to detect and prevent it, are continuously reviewed in quarterly compliance meetings. A risk assessment matrix is completed, and any policy or processes are updated immediately to ensure due diligence. An additional risk assessment will be completed as required before any significant change, for example the introduction of a new product, technology or entry into a new market. This process is overseen by a responsible person. Each WinAmazing prize draw process is witnessed by an additional member of staff. WinAmazing has conducted DBS checks on key members of staff. Third party agents working on behalf of the charity are not permitted to process cash.
Payment by cheque - Cheques should arrive at all times attached to the application form, or accompanied by a cheque renewal form. Should they arrive separated then they should be matched by the Player name. To verify this, the Player should be contacted to verify the last four digits of the account number. Banking of any cheque should be made daily, recording the date of banking against each cheque, name of payee and the WinAmazing player reference.
All payments will be kept in the bank account relating to the charity WinAmazing draw. This money will only be used for prize draws, any balance being held remains the property of the WinAmazing player until such time it has been used by WinAmazing prize draws or refunded on request.
Payment by Credit/Debit card - Payments are taken using a Worldpay online payments card reader registered to WinAmazing Limited. To protect the Player, payments are only authorised once identity has been verified. They are processed by a person nominated as a responsible staff member. Credit card details are not stored by WinAmazing Limited. The charity is PCI DSS compliant.
Current risk status
The risk of the WinAmazing prize draws being manipulated by an external agent for money laundering, funding terrorism or other financial crime is currently low, as we operate a subscription service, pay-outs are random and processes are closely monitored. The risk of the WinAmazing prize draws being manipulated by an internal agent for money laundering, funding terrorism or other financial crime is currently low, as all processes are closely monitored and witnessed and stringent financial procedures are in place.
Player funds – segregation and disclosure
Payments received in advance of the prize draw are accounted for and reconciled monthly with the bank and the prize draw software. The funds are kept in a bank account in the The Julius Jones Trust, thus separate from WinAmazing and these are shown as a creditor and corresponding debtor on the management accounts. Trustees have deemed this account as separate and the funds are not included in the working capital of the Julius Jones Trust.
No credit is granted to individual Players. If a Player has not paid they are not entered into the draw.
Any person wishing to play the WinAmazing prize draw on-line or by paying by cheque or debit card must be located in Great Britain. Players and Direct Debit Players agree that playing the Games after registration whilst located in any jurisdiction other than Great Britain is strictly prohibited. WinAmazing has the right to terminate a Player's Account and withhold any Prize to any Player in respect of any Games played whilst located in any jurisdiction other than Great Britain.
Any person wishing to play the WinAmazing prize draws must be aged 18 years or older;
Any person wishing to play the WinAmazing prize draw On-line must supply their debit card details which must be linked to a bank account (or building society) that is based in Great Britain (GB) for which they are an authorised user and must also be linked to a GB address. Players who supply details of a jointly owned bank accept that Prizes won may be paid into that account.
When registering, the bank card referred to above must not have been reported as lost or stolen and cannot be used to open any more than one Account;
WinAmazing Limited reserves the right to exclude persons who do not meet the eligibility criteria set out above. Excluded Persons may also include persons (or category of persons) as the Gambling Commission may specify from time to time. Any person who enters the WinAmazing prize draw but who does not comply with the Terms and Conditions on this website shall be considered an Excluded Person.
WinAmazing reserves the right to refuse a Registration at its absolute discretion.
No Prizes will be paid to a Player if the criteria set out in this policy is not met, or if they are ineligible to play for any reason.
In carrying out these checks, personal information provided will be disclosed to a credit reference agency to perform an identity check, this is a verification footprint rather than a credit footprint which cannot, under any circumstances be used in the credit decision process or affect the person’s credit rating.
The check looks only at the existence of the Name, Address and Date of Birth with lenders rather than any current or previous credit information. This will leave a soft footprint on the Player’s credit file for 12 months. These checks will also be conducted when a postal claim is made and, in the event our electronic checks cannot verify player details, we may request physical documentation such as driving licence or passport to prove eligibility to claim prize.
In order for WinAmazing to decide whether the Player is eligible to play, the player will need to provide their name, home address details, date of birth, debit card detail and e-mail address.
Proceeds of Crime Act 2022
Under the 2002 Proceeds of Crime Act (POCA), we need to report the gambling activities of individuals if we know or suspect that their lifestyle is supported by the proceeds of criminal activity. In other words, those people we know or suspect are using the proceeds of crime money to take part in our prize draw activities.
Further information on POCA can be accessed via this link: Proceeds of Crime Act 2002
Money Laundering Definitionery campaigns will be operated specifically in accordance with the Gambling Commission’s Licence Conditions and Codes of Practice.
Money laundering is a process by which the proceeds of crime are converted into assets which appear to have a legitimate origin, so that they can be retained permanently or recycled into further criminal enterprises or spent as a lifestyle. This definition of money laundering means that potentially anyone could contravene the Regulations if they were to become aware of or suspect the existence of criminal property and continue to be involved in a matter which relates to that property without reporting their concerns.
WinAmazing is committed to ensuring that all necessary safeguards are in place with regard to the receipt of money in order to avoid it being used to launder money that may originate from the proceeds of crime.
The General Counsel of The Julius Jones Trust is Designated Anti Money Laundering Officer (AMLO). All relevant staff are trained on the requirements of the Regulations and told of the need to report any suspicious cash transactions to the AMLO for the purpose of informing the relevant authorities.
Although the likelihood of any suspicious activity related to money laundering is considered to be an extremely low risk, WinAmazing is aware of the appropriate course of action to follow should such a suspicious activity be identified – the course of action is described below.
Where it is suspected by a member of staff that money laundering activity is taking/has taken place, a disclosure must be made to the AMLO as soon as possible. Because of the importance attached to the process, notification should normally take place immediately by telephone or, where that is not possible, by any other expedient means. No discussion will take place with colleagues as confidentiality is paramount.
The AMLO will determine whether or not to submit - online or otherwise - a suspicious activity report (SAR) to the National Crime Agency (NCA) and will maintain records of all suspicious activity notifications received and the decision making process to address them. The AMLO may consider seeking advice from an appropriate authority (example: Gambling Commission) before deciding if SAR should be submitted.