AML Rules

AML Rules,
Fraud Prevention Rules and Guidelines

The following rules must be strictly observed by all casinos operating under the Roqqet Consultants Limited (Anjouan) remote gaming license.

Tucano8.com is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimise and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.
Tucano8.com will endeavour to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organisation and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.
It is your responsibility to understand and abide by these rules. If you have any questions or suggestions, please contact us at [email protected].
1. Player account verification
Each player account must be verified when the player has reached a certain stage of gaming activity:
• Deposits: Cumulative sum of EUR / USD 2,000 or currency equivalent, including cryptocurrencies
• Withdrawals: Cumulative sum of EUR / USD 2,000 or currency equivalent, including cryptocurrencies
• Using 2 and/or more payment systems for deposits and/or withdrawals.
2. Requesting KYC documents
Obligatory documents that should be part of any Know Your Customer (KYC) process:
• Photo of valid ID
• Proof of payment option used for deposit (i.e. screenshot of e-wallet, photo of the card, bank statement). The only exception are deposits made in cryptocurrency.
Optional documents that you can request:
• Proof of address (i.e. utility bill)
• Selfie with ID
• Live verification via mobile or laptop camera
• Source of funds (SOF) and/or Source of wealth (SOW)
Any other forms of KYC documents as may be requested in accordance with Anjouan license requirements.
Tucano8 may supplement the use of documentary evidence by using other means which may include:
• Independently verifying the Player’s identity through the comparison of information provided by the Player with information obtained from any reporting agency, any public database, or any other source;
• Checking references with financial institutions; or
• Obtaining a copy of the financial statements.
• To this extent the Company utilizes external fully certified verification platforms and compliance services to verify the Player’s true identity.
3. SUSPICIOUS TRANSACTION/ACTIVITY REPORTING (STR/SAR)
Suspicious activities and/or transactions must be identified, handled, escalated and reported promptly.
Tucano8.com employees who identify/detect unusual or suspicious activities and/or transactions are obliged to report these incidents to the MLRO immediately. Tucano8.com employees can use different ways to submit internal SAR/STRs and are instructed accordingly.
Once an internal report is received, the MLRO and his assignees will investigate the customer’s account to assess the unusual behaviour and/or suspicion described within the internal report. Based on the outcome of the investigation, the MLRO will decide whether to report the suspicion externally to the Anjouan FIU or to close the internal report with documented reasons.
The suspected/involved customer or any other third party is not to be alerted of any investigations or reports regarding ML/FT, as under no circumstances a “Tipping-off” is accepted or tolerated, given the fact that this would be a serious criminal offence.
The MLRO is obliged to report any suspicious activity or transaction to the respective authorities where the MLRO knows, suspects, or has reasonable grounds to suspect ML/FT promptly. The internal or external reporting of a suspicious activity cannot be suppressed.
4. AML/CFT TRAINING PROGRAM
Adequately AML/ CFT trained staff is a cornerstone of every effective AML/CFT program to protect the company of related risks. It creates also the level of awareness that is key to report any suspicious activity without undue delay. New employees shall receive anti-money laundering training as part of the mandatory new joiners training program (as applicable in their respective company).
All employees are required to complete a web-based AML/CFT training annually. Employees with operational or other substantial AML responsibilities shall receive additional AML/CFT trainings as applicable, especially if they are responsible for the maintenance of customer relationships or for processing transactions.
5. Politically Exposed Persons
The requirements relating to PEPs are of a preventive and not criminal nature by law. Tucano8.com has an appropriate risk management system in place, including risk-based procedures, to determine
• whether a customer or the management or the beneficial owner of a business partner is a politically exposed person,
• whether this person can be accepted as a customer and
• which mitigating measures need to be applied.
Generally, a person is politically exposed if he/she holds or has held a prominent public function in the past 12 months. Such prominent public functions shall include, but are not limited to:
• Heads of State,
• Heads of Government,
• Ministers and Deputy and Assistant Ministers and Parliamentary Secretaries;
• Members of Parliament;
• Members of the governing bodies of political parties;
• Members of the Courts or of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances;
• Members of courts of auditors, Audit Committees or of the boards of central banks;
• Ambassadors, charge d’affaires/diplomats and other high-ranking officers in the armed forces;
• Members of the administration, management or boards of state-owned corporations; and
• anyone exercising a function equivalent to those set out in the paragraphs above within an institution of the European Union or any other international body.
Close family members, such as
• the spouse or any person considered to be the equivalent to a spouse,
• parents and children and their spouses or any person considered to be the equivalent to a spouse are to be classified as PEPs as well.
This also applies to persons who are considered “known to be close associates”. This definition applies to every natural person who has joint profits from assets or established business relationship or any other close business relations with a politically exposed person and natural persons who have sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a politically exposed person.
6. Sanctions
Tucano8.com is required to screen customers and on a risk-based level also business partners against sanctions lists issued, among others, by the United Nations, European Union and US Office of Foreign Assets Control (OFAC) at a minimum in all jurisdictions in which tucano8.com operates, unless to do so would conflict with local legislation.
Whereas tucano8.com can decide whether to accept PEPs as customers, under no circumstances can business be carried out with any sanctioned natural person or corporate entity.
7. Measures in case of PEP and sanction matches
Relevant operational teams have procedures in place, which describe how to deal with PEP/sanction alerts, identify alerts as false positives or true matches and escalate true matches to the MLRO and Deputy. The MLRO has a separate procedure in place, which defines the steps that need to be taken if the designated teams escalate a PEP or sanction match. According to the escalation procedure,
• senior management approval for the establishment or continuation of a business relationship with a PEP has to be obtained;
• EDD measures, including establishment of the source of wealth and if applicable the source of funds that are involved in such business relationships, need to be applied
• enhanced, ongoing monitoring of those business relationships needs to be applied. If a customer is identified as a sanctioned person, the following actions are mandatory:
• immediately freeze all assets held on behalf of the sanctioned person and
• inform the Sanctions Monitoring Board (SMB) to receive further instructions.
8. RECORD KEEPING
All identification documentation and service records shall be kept for a minimum period of no less than five years after the termination of the contractual relationship with the customer notwithstanding retention periods of other laws as e.g. tax or data protection laws.
AML/CFT relevant data in relation to internal investigations, KYC measures or STRs/SARs shall be obtained for five years and - if no further need is identified - deleted after.
All data and documentation shall be made available to authorized persons promptly on request and without undue delays. Authorized persons are e.g. competent authorities or public prosecutors, the FIAU/FIU, etc.
9. Use of Gifts and manual Balance Corrections
‘Gifts’ and positive Balance Corrections must be created for rewarding players only, and cannot be used for Operator’s personal needs. We prohibit the use of ‘Gifts’ for any purpose other than rewarding players for certain activity (i.e. a forum contest, etc).
In case you absolutely need to make a prepayment to an affiliate, or make any other form of payment using ‘Gifts’ or positive Balance Corrections, you must contact your Account Manager in advance and get a written approval.
We reserve the right to cancel your Gifts or positive Balance Corrections in the event that you do not have approval for issuing a Gift or making a positive Balance Correction. Furthermore, we reserve the right to restrict your access to the Admin Area until written explanation of Gifts or positive Balance Corrections are received by your Account Manager.
10. Processing withdrawals
As an Operator you should always attempt to process withdrawals via the same payment method used to make a deposit. It is crucial for Anti-Money Laundering (AML) protection to follow this rule in full measure. We, however, understand that in some cases it may not be possible (e.g. a Mastercard card used for deposit cannot be used for withdrawal etc.) and do not intend this measure to limit your operations in any way.
All cryptocurrency deposits can be withdrawn back only to cryptocurrency wallets. All fiat money deposits can be withdrawn only via fiat payment options. In case of an urgent necessity to make fiat-crypto withdrawal, all such payments must be approved by [email protected].
11. Third-party payment accounts
Use of 3rd party payment accounts is strictly prohibited. Please note that each customer can only use their own payment accounts or wallets. Any player who uses a 3rd party payment source must have their account closed and their funds confiscated. Only in exceptional cases can the customer initiate a refund.
If you found a player who uses 3rd party payment accounts, you should report such a player to [email protected].
12. Handling funds confiscation
In case a player’s funds are confiscated due to breach of the Terms and Conditions and/or Bonus Terms and Conditions, you must specify the exact reason for such action including the exact clause from the Terms and Conditions. Both the rule and the reason must be posted in the ‘Change balance’ section.
13. Other cases
1. If a player attempts to manipulate casino games, casino systems, or you have a strong reason to believe that the customer is attempting to cheat, please report this customer to [email protected].
2. If a player openly states in live chat or by email about possible chargebacks, please report such a player to [email protected].
3. If a player provided forged or false documents, please report such a player to [email protected].
4. All suspicious players, potential collusion attempts or fraud should be reported to [email protected] immediately.