Purpose and Scope

This Anti Money Laundering and Countering Financing of Terrorism policy establishes Caca88 obligations for identifying customers, verifying their identities, assessing risk, and monitoring activity in accordance with applicable AML/CFT laws. It applies to all product offerings and all customer interactions conducted through the Caca88 platform.

Regulatory Framework and Applicability

Caca88 implements an AML program based on risk assessment and commensurate controls to detect and deter money laundering, the financing of terrorism, and related illicit activity. The program includes customer due diligence, ongoing monitoring, reporting of suspicious activity, and cooperation with competent authorities as required by law.

Definitions

  • Customer due diligenceCDD and enhanced due diligenceEDD: processes applied according to risk level.
  • Beneficial owner or account holder: the natural person ultimately controlling the account or funds.
  • Source of funds and source of wealth: origin of deposited funds and overall financial resources used in relation to the account.
  • Politically Exposed Person PEP: a person in a prominent public function or closely related individuals and associates, subject to enhanced scrutiny.
  • Ongoing monitoring: continuous review of customer activity and data updates to identify unusual or high risk transactions.
  • KYC: Know Your Customer procedures used to verify identity and assess risk before and during business relationships.

Minimum Identification Data

To establish customer identity, Caca88 requires a minimum data set at account opening as well as updates thereafter. The minimum data set includes:

  • Full name
  • Date of birth
  • Nationality
  • Permanent residential address
  • Government issued identifier number

Required Documentation

For verification, customers may be asked to provide:

  • Government issued photo identity document (passport, national ID card, or national driver license) that is valid and not expired within the next three months
  • Proof of residential address issued within the last three months (for example a utility bill or bank statement) showing the same name as the identity document
  • Selfie or live image holding the identity document to confirm authenticity
  • If applicable, additional documents for the payment method used (for example front side of a payment card with sensitive data masked in accordance with policy)

Source of Funds and Wealth Verification

Customers may be required to provide evidence that funds used for deposits originate from lawful sources. Acceptable evidence includes payslips, pension statements, bank statements indicating funds differentially received, investment income statements, or other documentation demonstrating a credible and lawful source of funds and wealth. Caca88 may request supporting documentation to corroborate the declared source of funds.

Risk Based Due Diligence and Ongoing Monitoring

The company applies a risk based approach to due diligence. Customer risk is assessed at onboarding and reviewed periodically thereafter. Monitoring includes screening against adverse lists, reviewing unusual or high risk transactions, and updating customer information as needed. Significant changes to risk status prompt a re-assessment and, where required, additional verification or restrictions.

Enhanced Due Diligence and PEPs

Customers identified as high risk, including Politically Exposed Persons or their close associates and family, are subject to enhanced due diligence. Procedures include extended verification of identity and sources of funds, increased monitoring, and potential limitations on activity or mandatory verification before transactions are processed.

Prohibitions on Anonymity and Multiple Accounts

Anonymous or nominal accounts are not permitted. If identity cannot be established or remains inconsistent, the account may be suspended or closed, applicable funds may be returned or retained under lawful process, and earnings may be cancelled as permitted by policy and law. The company may identify and link related or connected accounts and may require consolidation, restrict activity, or suspend or terminate privileges across all linked accounts.

Source of Funds and Sanctions Screening

Transactions and accounts are screened for sanctions, money laundering indicators, and other financial crime risks. Any match or risk indicator triggers escalation to the Compliance team and potential temporary restriction of activity pending further investigation.

KYC Processing and Statuses

On account opening, customers undergo a KYC review. The process may result in one of the following statuses:

  • Approved: customer verified and cleared for standard activity.
  • Temporary Approved: initial screening completed; further information may be required. While temporarily approved, there are transaction limits and restrictions on withdrawals.
  • Rejected: verification failed or risks identified; services may be refused and accounts closed.

During temporary approval, a customer may be subject to a deposit limit and no withdrawal rights until verification is complete. The standard verification window is defined by internal controls and in any event will be completed promptly with notification of the outcome.

Transaction Limits and Withdrawal Controls

Per transaction limits and withdrawal controls apply based on KYC status. Typical controls may include:

  • Temporary approval: aggregate deposits restricted to a defined threshold (for example 500 in the reporting currency) and no withdrawals permitted.
  • Post verification: deposits may be subject to per transaction limits (for example up to 2000 in the reporting currency) and withdrawals subject to verification of funds, activity review, and balance checks.

Data Privacy, Security and Retention

Caca88 acts in accordance with applicable data protection laws. Personal data collected for AML purposes is stored only as long as required by law and for the duration of the business relationship. Access to data is restricted to authorized personnel and contractors performing AML functions. Data subjects may request access, correction, or deletion in accordance with applicable laws and operational policies.

Suspension, Termination and User Rights

Failure to meet AML and KYC requirements may lead to suspension of account access, restriction of deposits or withdrawals, forfeiture of earnings, or termination of the customer relationship. In such cases, funds in the customer account will be handled in accordance with law and internal policy. Customers have the right to request a review of decisions in accordance with the internal escalation process and will be informed of the outcome within a reasonable period.

Governance, Training and Record Keeping

Caca88 maintains governance structures to oversee AML/CFT compliance, including periodic training for staff and record retention for all customer due diligence, risk assessments, and transaction monitoring activities in accordance with legal requirements.

Reporting and Cooperation

The company reports suspicious activities and transactions in accordance with applicable reporting requirements and cooperates with competent authorities in investigations, including providing timely information and access as required by law.