1. Policy Statement
Rosebury Limited (the “Company”), registered in the British Virgin Islands. It is committed to full compliance with all applicable laws to prevent money laundering, terrorist financing, and related financial crimes. We maintain a zero-tolerance approach and implement robust internal procedures accordingly.
2. Objectives
Prevent the use of our platform for money laundering or terrorist financing.
Minimize reputational, legal, and regulatory risk.
Maintain systems in line with current local and international AML standards.
3. Player Verification (KYC)
Players must confirm they are 18+ and legally permitted to play in their jurisdiction.
We may request proof of identity and address at any time.
Mandatory identity verification before any withdrawal over $150,000.
Acceptable documents include a valid passport/national ID and a recent utility bill or bank statement.
Accounts will be closed if players provide false information or refuse verification.
4. Ongoing Monitoring
Automated monitoring of all account activity and transactions.
Transactions of more than $20,000 are flagged for review.
Monitoring includes the origin of funds, frequency, and patterns inconsistent with normal gameplay.
5. Suspicious Activity Reporting
Directors and senior management investigate and, if necessary, files Suspicious Activity Reports with the relevant authorities.
Red flags include:
Use of false or stolen identity
Unusual patterns inconsistent with player profile
Links to sanctioned individuals/entities
Player accounts may be frozen pending investigation.
6. Employee Training
All staff undergo AML training annually, with updates as laws evolve.
Training covers red flag detection, escalation procedures, responsibilities, recordkeeping, and disciplinary measures.
7. Recordkeeping
All verification, transaction, and monitoring data is securely stored in compliance with applicable data protection laws for a minimum of three years.
8. Governance & Review
The directors and senior management oversee the AML Policy.
Policies and procedures are reviewed annually or upon the occurrence of a legal or regulatory change.