Pin Up's Anti-Money Laundering Policy for Responsible Gambling in India

What is Money Laundering?

Money laundering is the process of disguising illegally obtained funds as legitimate through complex financial transactions. It often involves converting illicit cash into assets like real estate or luxury goods. This practice undermines financial systems and enables criminal activities.

Combating Money Laundering at Pin Up

Pin Up actively combats money laundering through a robust compliance framework, rigorous customer due diligence, and continuous transaction monitoring. Our systems detect unusual patterns and flag suspicious activities for further investigation. We also collaborate with regulatory authorities to ensure transparency and accountability.

• Customer due diligence (CDD) for all users
• Real-time transaction monitoring
• Suspicious activity reporting (SAR) mechanisms

Regulatory Compliance Obligations

All Pin Up employees are required to report any suspicious activity immediately, adhering to Curaçao licensing requirements and Indian AML regulations. This includes verifying customer identities, reviewing transaction histories, and documenting compliance actions. Failure to report may result in legal consequences for both the employee and the company.

• Unusual transaction patterns (e.g., large deposits/withdrawals)
• Identity discrepancies or forged documents
• Transactions linked to high-risk jurisdictions

Pin Up ensures all legal checks align with international standards and local Indian laws. Our policies are regularly reviewed to maintain compliance with evolving regulations. This commitment protects both our users and the integrity of our platform.

Crime and AML Policy

Pin Up's AML practices are designed to prevent criminal exploitation of our platform. We prioritize transparency and traceability in all financial interactions, ensuring alignment with international anti-crime frameworks.

• Transparency in all financial dealings
• Mandatory customer due diligence
• Continuous transaction monitoring
• Prompt reporting of suspicious activities
• Regular employee training on AML protocols

Risk Management Strategies

Under UK regulations, Pin Up must implement risk-based approaches to AML compliance. This includes assessing customer risk profiles, applying enhanced due diligence for high-risk users, and maintaining detailed records. Proactive risk management minimizes exposure to financial crimes.

• Conduct regular customer risk assessments
• Apply enhanced due diligence for high-risk users
• Maintain detailed transaction records
• Implement automated monitoring tools

Suspicious Activity Reporting

Pin Up verifies user identities through document checks, biometric authentication, and cross-referencing with global databases to prevent fraud. All verification steps are encrypted and compliant with Indian data protection laws.

Senior Management Accountability

Pin Up's senior management is ultimately accountable for ensuring AML policies are effectively implemented and maintained.

High Risk Jurisdictions

Pin Up applies enhanced due diligence for users from high-risk jurisdictions, including stricter identity verification and transaction monitoring. This ensures compliance with global AML standards and reduces exposure to illicit financial flows.

• Afghanistan; 
• Algeria; 
• Angola; 
• Bosnia and Herzegovina; 
• Ecuador; 
• Guyana; 
• Iraq; 
• Lao People’s Democratic Republic; 
• Myanmar; 
• Panama; 
• Papua New Guinea; 
• Syria; 
• Uganda; 
• Yemen; 
• Iran; 
• Democratic People’s Republic of Korea.

Robust Accounting Practices for Transparency

Our audit logs meticulously track all financial transactions and user activities to ensure compliance with regulatory standards. These logs are regularly reviewed to detect anomalies and maintain operational integrity.

• Regular internal audits of financial records
• Segregation of duties among accounting staff
• Use of certified accounting software
• Documentation of all financial processes
• Monitoring of discrepancies and irregularities

Thorough Verification of New Clients

All staff undergo rigorous background checks, including criminal record screening and verification of professional credentials. Ongoing training programs ensure compliance with AML regulations and company policies. Regular audits of staff activities help identify and mitigate potential risks.

Securing Financial Assets and Equipment

Physical and digital assets are protected through advanced encryption, secure storage facilities, and access controls. Regular security assessments and audits ensure vulnerabilities are addressed promptly. Employee access to sensitive equipment is restricted to authorized personnel only.

Establishing an Independent Compliance Committee

The Compliance Committee is composed of cross-functional experts who meet quarterly to review AML policies and risk assessments. Members are selected based on their expertise in legal, financial, and operational domains.

Rigorous Supplier Vetting Procedures

We collaborate only with suppliers who adhere to strict ethical and legal standards. All partners must demonstrate compliance with AML regulations and provide transparent financial records. Regular audits ensure ongoing adherence to our cooperation principles.

• Legal compliance with AML regulations
• Financial stability and transparency
• Reputable industry standing
• Robust internal controls
• Adherence to data protection laws

All supplier partnerships require formal approval from the Compliance Committee before implementation.

Adherence to Proceeds of Crime Act

Pin Up strictly complies with the Proceeds of Crime Act to prevent illicit funds from entering our platform.

Maintaining Accurate Internal Accounting

We maintain detailed records of all financial transactions to ensure transparency and accountability. These records are stored securely and are subject to regular audits to verify their accuracy.

• Transaction records for 5 years
• Customer account information for 7 years
• Audit logs for 10 years
• Correspondence with regulators for 10 years
• Financial statements for 15 years

Preventing Collusion and Fraud

Advanced monitoring systems detect suspicious patterns in user behavior and transactions. Transaction limits and account restrictions are applied to high-risk accounts. Employees are required to report any suspected collusion or fraud immediately.

Introduction to AML Compliance

Pin Up implements strict KYC procedures to verify the identity and financial legitimacy of all users. Verification is conducted through document checks, biometric authentication, and cross-referencing with official databases. Users must provide valid identification and proof of address during account setup. Account restrictions may be applied if verification is incomplete or suspicious activity is detected.

• Suspended accounts for incomplete verification
• Closed accounts for fraudulent activity

Purpose of This Policy

This policy ensures all users are verified to prevent money laundering and other financial crimes.

• Unusual transaction patterns
• Multiple accounts linked to a single individual
• Large deposits without clear source of funds
• Frequent account withdrawals

Users are required to provide requested documents promptly to complete verification.

• Full name and date of birth
• Government-issued ID (e.g., passport, PAN card)
• Physical address and contact information
• Employment or income details
• Bank account information
• Passport or national ID card
• Driver's license
• PAN card
• Bank statement (≤3 months old)
• Utility bill (≤3 months old)

Users must provide proof of income or assets to verify the legitimacy of funds deposited.

Users are obligated to cooperate fully with verification and compliance processes.

• Provide accurate personal and financial information
• Update details promptly when changes occur
• Report suspicious activities immediately
• Comply with account restrictions if requested

Pin Up reserves the right to terminate accounts that fail to comply with verification or AML requirements.