AML Policy

AML Policy

For RSD Events Ltd, trading as Balgriffin Inn Online Zoom Bingo
Formal Legal Version

1. Purpose and Legal Framework

1.1
This Anti‑Money Laundering and Counter‑Terrorist Financing Policy (“Policy”) sets out the measures adopted by RSD Events Ltd, trading as Balgriffin Inn Online Zoom Bingo (“the Company”), to prevent its services from being used for the purposes of money laundering, terrorist financing, or any other financial crime.

1.2
This Policy is implemented in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021 (“the Acts”), all applicable Irish and EU AML/CTF legislation, and relevant guidance issued by the Department of Justice, the Central Bank of Ireland, and FIU Ireland.

1.3
The Company adopts a risk‑based approach to AML/CTF compliance, ensuring that controls are proportionate to the risks inherent in remote bingo operations and online payment processing.

2. Scope

2.1
This Policy applies to:

• All customers of balgriffinbingo.ie
• All online bingo transactions
• All staff, contractors, and persons engaged in payment processing, customer verification, or prize distribution
• All systems and processes used to facilitate customer registration, payments, and prize payouts

3. Definitions

For the purposes of this Policy:

• “Acts” means the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021.
• “MLRO” means the Money Laundering Reporting Officer appointed by the Company.
• “CDD” means Customer Due Diligence.
• “EDD” means Enhanced Due Diligence.
• “STR” means Suspicious Transaction Report.
• “FIU Ireland” means the Financial Intelligence Unit of An Garda Síochána.

4. Governance and Responsibilities

4.1
The Company shall appoint a Money Laundering Reporting Officer (MLRO) with responsibility for:

• Receiving internal reports of suspicious activity
• Assessing whether an STR is required
• Filing STRs with FIU Ireland and Revenue Commissioners
• Maintaining AML records
• Overseeing staff training
• Ensuring ongoing compliance with the Acts

4.2
All staff must:

• Comply with this Policy
• Report suspicious activity to the MLRO without delay
• Complete AML training as required
• Maintain confidentiality and avoid “tipping off”

5. Customer Due Diligence (CDD)

5.1
The Company shall conduct CDD where required under the Acts, including:

• Verification of customer identity
• Confirmation of age (18+)
• Verification of address where necessary
• Verification prior to prize payouts

5.2
CDD shall be applied in the following circumstances:

• Large or unusual cumulative transactions
• Irregular purchasing patterns
• Suspicious or unusual behaviour
• Where required by law or regulation

5.3
Acceptable verification documents include:

• Passport
• Driving licence
• National identity card
• Recent utility bill or bank statement (for address verification)

5.4
Failure to provide satisfactory documentation may result in:

• Suspension of participation
• Withholding of prizes
• Account closure

6. Enhanced Due Diligence (EDD)

6.1
EDD shall be applied where:

• The customer presents a higher risk
• Transactions are unusually large or complex
• Multiple payment methods or accounts are used
• Documents appear forged or tampered with
• The customer is identified as a Politically Exposed Person (PEP)

6.2
EDD measures may include:

• Obtaining additional identity documentation
• Verifying source of funds
• Increased monitoring of transactions

7. Ongoing Monitoring

7.1
The Company shall monitor customer activity to identify:

• Unusually large purchases
• Rapid or repeated purchases inconsistent with normal play
• Purchases without participation in games
• Attempts to use multiple cards or mismatched names
• Refund‑seeking behaviour
• Structuring designed to avoid detection

7.2
The Company strictly prohibits:

• Transfer of funds between player accounts
• Payouts to accounts not in the name of the registered player

8. Suspicious Activity Reporting

8.1
Where staff have reasonable grounds to suspect that funds are the proceeds of criminal conduct, they must report the matter internally to the MLRO.

8.2
The MLRO shall determine whether an STR must be filed with:

• FIU Ireland, and
• Revenue Commissioners, where applicable

8.3
The Company is legally prohibited from informing the customer that an STR has been filed (“tipping off”).

9. Record Keeping

9.1
The Company shall retain AML‑related records for a minimum of five (5) years after the end of the customer relationship, including:

• Identification documents
• Transaction histories
• Internal AML reports
• STR assessments
• Staff training records

9.2
Records shall be stored securely and accessed only by authorised personnel.

10. Staff Training

10.1
All relevant staff shall receive AML/CTF training covering:

• Legal obligations under the Acts
• Identification of suspicious activity
• CDD and EDD procedures
• Reporting obligations
• Data protection and confidentiality

10.2
Training shall be refreshed regularly and documented.

11. Payment Processing Controls

11.1
All payments are processed through secure, reputable third‑party payment providers.

11.2
The Company does not store or process card details directly.

11.3
Payouts shall only be made to accounts held in the name of the verified customer.

12. Risk Assessment

12.1
The Company shall conduct periodic AML risk assessments to evaluate:

• Customer behaviour
• Transaction patterns
• Payment methods
• Operational vulnerabilities

12.2
Controls shall be updated as necessary to ensure ongoing compliance.

13. Sanctions for Non‑Compliance

13.1
Any staff member who breaches this Policy may face:

• Disciplinary action
• Suspension or termination of employment
• Reporting to relevant authorities

14. Policy Review

14.1
This Policy shall be reviewed annually, or sooner where required by changes in law, regulation, or operational risk.

15. Contact Information

For AML‑related queries, contact the MLRO at:

bingo@thebalgriffin.ie