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

What is Money Laundering?

Money laundering is the process of making illegally obtained funds appear legitimate. It typically involves three stages: placement, layering, and integration. These activities are often linked to criminal enterprises and pose serious risks to financial systems and individual users.

Combating Money Laundering at Pin Up

Pin Up combats money laundering through strict compliance with international regulations and local laws in India. Our AML program includes rigorous customer verification, transaction monitoring, and ongoing risk assessments. By proactively identifying suspicious activities, we ensure a secure environment for all users.

• Rigorous customer identity verification
• Real-time transaction monitoring
• Regular compliance audits

Regulatory Compliance and Reporting Obligations

All Pin Up employees are required to report any suspicious activities or transactions that may indicate money laundering. This includes unusual transaction patterns, customer behavior, or incomplete documentation. Reports must be submitted promptly to the designated AML compliance team. Employees are trained to recognize red flags and follow established procedures for escalation.

• Unusual or high-value transactions
• Incomplete or inconsistent documentation
• Activities linked to high-risk jurisdictions

Pin Up ensures all legal checks are conducted to maintain compliance with Indian regulations and international standards. This commitment protects both the company and its users from potential financial crimes.

Crime Prevention and AML Policy

Pin Up's AML practices are designed to prevent criminal activities by ensuring transparency and accountability in all financial transactions. This includes continuous monitoring and adherence to legal frameworks.

• Transparency in all financial operations
• Accountability for employee actions
• Integrity in user interactions
• Compliance with local and international laws
• Customer due diligence verification

Risk Management Strategies

While Pin Up operates in India, we align with UK regulatory standards to ensure robust risk management. This includes regular audits, staff training, and updated compliance protocols. These measures help mitigate financial risks and maintain trust with our users.

• Conducting regular internal audits
• Providing mandatory staff training
• Updating compliance protocols annually
• Implementing multi-layered customer verification

Suspicious Activity Detection

Pin Up verifies user identities through multiple documents and biometric checks to prevent fraud. This process includes cross-referencing information with official databases and ensuring all details match. Identity verification is a critical step in our AML strategy to deter illegal activities.

Senior Management Accountability

Senior management at Pin Up is directly responsible for overseeing and ensuring the effectiveness of our AML policies and procedures.

High Risk Jurisdictions and Enhanced Checks

Pin Up conducts enhanced due diligence for users from high-risk jurisdictions to mitigate potential financial risks. This includes additional verification steps and ongoing monitoring of transactions.

• 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.

Maintaining accurate financial records is essential for transparent accounting practices.

Audit logs track all financial transactions and system changes to ensure traceability. They provide a clear history for internal and external reviews.

• Segregation of duties to prevent conflicts of interest
• Monthly reconciliation of accounts
• Use of certified accounting software
• Documentation of all financial decisions
• Annual external audits by independent firms

Verifying new clients to prevent fraudulent activities and ensure compliance

All staff undergo rigorous background checks, including criminal record screenings and verification of professional credentials. Ongoing training programs ensure awareness of AML regulations and red flags. Regular monitoring of employee behavior and transaction patterns helps identify potential risks early.

Securing physical and digital assets against unauthorized access

All sensitive data is encrypted using industry-standard protocols to protect against breaches. Access to critical systems is restricted to authorized personnel with multi-factor authentication. Regular security audits and penetration testing identify vulnerabilities proactively.

Establishing a dedicated compliance oversight team

The Compliance Committee will be formed with members from legal, finance, and operations departments to ensure cross-functional oversight. Regular meetings will be scheduled to review AML policies and address emerging risks.

Evaluating third-party vendors for compliance adherence

All suppliers must adhere to strict transparency standards and cooperate fully with audits. Contracts will include clauses requiring compliance with AML regulations and data protection laws. Regular performance reviews ensure ongoing adherence to agreed-upon principles.

• Valid business licenses and certifications
• Proven compliance with local and international regulations
• Transparent financial reporting practices
• History of no legal or regulatory violations
• Commitment to ongoing AML training

All supplier agreements require formal approval from the Compliance Committee before execution.

Complying with legal frameworks to prevent illicit financial flows

Pin Up strictly adheres to the Proceeds of Crime Act and related regulations to combat financial crime.

Ensuring transparent and tamper-proof financial recordkeeping

All financial records must be retained for a minimum of seven years to facilitate audits and investigations. Digital records are stored in secure, encrypted servers with regular backups.

• Transaction history for 7 years
• Customer identification documents for 7 years
• Audit logs for 7 years
• Correspondence related to compliance for 7 years
• Suspicious activity reports for 7 years

Implementing measures to detect and prevent collusive activities

Advanced algorithms monitor for unusual patterns in player behavior that may indicate collusion. All staff are trained to report suspicious activities immediately. Regular reviews of high-risk accounts ensure timely intervention.

Overview of the verification process for new users

All new users must provide valid identification documents to verify their identity and address. Verification is authorized by our compliance team to ensure authenticity and prevent identity fraud. Users are required to submit documents in accordance with Indian regulatory standards. Failure to complete verification may result in account restrictions.

• Suspicious activity detected in the account
• Incomplete or invalid verification documents

Purpose of this policy to prevent money laundering

Verification is triggered when suspicious activity, inconsistent information, or high-risk transactions are identified.

• Large or frequent deposits without clear source of funds
• Multiple accounts linked to the same individual
• Transactions involving high-risk jurisdictions
• Unusual betting patterns or behavior

Users must provide requested documents within 7 business days to avoid account suspension.

• Full name and date of birth
• Physical address and contact information
• Government-issued ID (e.g., passport, Aadhaar card)
• Proof of address (e.g., utility bill, bank statement)
• Occupation and income details
• Passport or national ID card
• Aadhaar card or PAN card
• Bank statement or utility bill
• Employment letter or tax documents
• Official government-issued identification

Income proof must be verifiable through official sources and match the user's declared financial status.

Users are obligated to provide accurate and up-to-date information at all times.

• Verify identity and source of funds
• Update personal information promptly
• Report suspicious activities immediately
• Cooperate fully with compliance checks

Pin Up reserves the right to terminate accounts and report suspicious activities to authorities if AML obligations are not met.