AML Policy of KEKW Gaming B.V.

Policy for processing Financial Deposits and Withdrawals.

(AML - Anti-Money-Laundering policy of https://www.csgoluck.com)

Introduction: https://www.csgoluck.com is operated by KEKW Gaming B.V. having its office at Abraham Mendez Chumaceiro Blvd. 50, Willemstad, Curacao. Company Registration number 155.997

Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on https://www.csgoluck.com. To achieve this, a three step account verification is done in order to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.

https://www.csgoluck.com also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

https://www.csgoluck.com is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of https://www.csgoluck.com is designed to be compliant with:

  • EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
  • EU: “Regulation 2015/847 on information accompanying transfers of funds”
  • EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
  • BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash

Definition of money laundering

Money Laundering is understood as:

  • The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
  • The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
  • The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
  • Participation in, association to commit, attempts to commit and aiding, abetting, facilitating, and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for https://www.csgoluck.com

In accordance with the AML legislation, https://www.csgoluck.com has appointed senior directors for the prevention of ML. The full management team of KEKW Gaming B.V. are in charge of this process.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general management.

AML policy changes and implementation requirements

Each major change of https://www.csgoluck.com AML policy is subject to be approval by the general management of KEKW Gaming B.V. and the Anti money laundering compliance officer.

Three step Verification

Step one verification

Step one verification must be done by every user and customer to withdraw funds/skins. When approving documents, we take into consideration the original method of payment, the amount of payment, the value of the withdrawal request and nationality of the user/customer. Step one verification is a process that must be completed by the user/customer themselves on the website. In order to process ANY withdrawal, we must hold the following information on each user, and this information where noted must match that of the Card Holder: first name, second name, date of birth, country of usual residence, gender, full home address and email address.

In any instance where this information differs between the CSGOLuck user account and the information held by our payment processors, we reserve the right to block any attempts to withdraw. Any funds that have been lost shall not be refunded where KYC is rejected.

Step two verification

Step two verification must be completed by every user that deposits over $2000 (two thousand Dollars), withdraws over $2000 (two thousand Dollars), or sends another user over $100 (one hundred Dollars) in tips. Until step two verification has been completed, any withdrawal, tip or deposit will be placed on hold. Step two verification will lead the user or customer to a subpage where you must send ID. Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different. There will also be an electronic check to ensure the information supplied in step one is accurate, and matches that of the ID. The electronic check will check two different databanks to ensure the information given matches the information held. If the electronic test fails or is not possible, the user/customer is required to send in a conformation of his current residence.

Step three verification

Step three verification must be completed by every user that deposits over $50,000 (fifty thousand Dollars), withdraws over $50,000 (fifty thousand Dollars), or sends another user over $3,000 (three thousand Dollars). Until step three verification is completed, any withdrawal or tip will be held. For step 3, a user/customer will be asked to prove their source of funds/wealth.

Customer identification and verification (KYC)

The formal identification of customers is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card or driving license and a second picture with the face of the user/customer is required. The user/customer may blur out any information, besides date of birth, nationality, gender, first name, second name and any private or personal detail from the picture to secure their privacy.

Please note that all four corners of the ID have to be visible in the same image and all details have to be clearly readable. We may ask for additional details if necessary.

An employee may do additional checks if necessary, based on the situation, and is entirely at the discretion of KEKW Gaming B.V.

Proof of Address

Proof of address will be done via to different electronic checks, which use two different databases. If an electronic test fails, the user/customer will be required to supply evidence of their current residence.

A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proves your state of residence. Please note that a mobile phone bill is not acceptable.

To make the approval process as speedy as possible, please make sure that the document is sent in a respectable resolution, where all four corners of the document are visible, and all text is readable.

Examples of accepted documents are: An electricity bill, water bill, bank statement, GP letter, hospital letter or any governmental post addressed to you.

An employee may do additional checks if necessary, based on the situation. These additional checks are entirely at our discretion, as with ID.

Source of funds

To protect ourselves against fraud, money laundering and from allowing users to benefit from the proceeds of crime, we may ask you to prove your source of funds.

Examples of how you can do this are:

  • Ownership of business and related accounts
  • Employment income
  • Inheritance
  • Investments
  • Family wealth

It is critical that the origin and legitimacy of wealth is clearly understood. If this is not possible we may terminate our relationship with you.

You will be informed by email and allowed up to 28 days to supply the relevant evidence.

https://www.csgoluck.com also asks for a bank wire/credit card to further ensure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

Risk management

In order to deal with the different risks and different states of wealth in various regions on the earth, https://www.csgoluck.com will categorize every nation in three different regions of risk. We will periodically review these, but players should be aware that we may request KYC with no prior warning, solely based on your geo location.

Enterprise-wide risk assessment

As part of its risk-based approach, https://www.csgoluck.com has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to https://www.csgoluck.com and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.

The identification of AML risk categories is based on https://www.csgoluck.com understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.

The EWRA is reassessed on an annual basis.

Ongoing transaction monitoring

AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

  1. The first Line of Controlhttps://www.csgoluck.com works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto https://www.csgoluck.com from taking place, without execution of KYC procedures onto the potential customer.
  2. The second Line of Control:Our standard KYC process.If fraud or Money Laundering is suspected, we reserve the right to withhold your funds indefinitely and inform the relevant authorities

Record keeping

Records of data obtained for the purpose of identification must be kept for at least six years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

This data will be held safely and securely encrypted, and stored both offline and online.

Data Security

All data supplied by any user/customer will be held securely and will never be sold or given to any 3rd party, without prior express permission. Only under request by a federal or legal authority, or to prevent money laundering, can data be shared without the users prior consent.

https://www.csgoluck.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

Contact us

If you have any questions about our AML and KYC Policy, please contact us:

If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us: