Anti Money Laundering Policy


Sections


  1. Introduction
  2. Scope and Obligations
  3. The Money Laundering Officer
  4. Prevention and Deterrence
  5. Disclosure and Reporting

Introduction


The following policy exists to protect Hosts, Entrants, Us and our Partners from crime and terrorism. It sets out the rules and expectations of all involved in this exciting concept, so make sure to read them. We would suggest a comfy seat and a cup of something comforting.

  1. The fight against crime and terrorist activities is becoming ever more globalised. The significant contribution that can be made by depriving potential criminals and terrorists of the funds they need is recognised, as is the relatively low level of funds required for significant acts to be carried out.
  2. Joxle Limited (Trading as Raffique) is committed to preventing the Raffique competition platform being exposed to money laundering; identifying the risks where it may occur; and complying with legal and regulatory requirements, especially with regard to reporting suspected cases.
  3. The Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering Regulations 2007 place obligations on Joxle Limited and its employees to establish internal procedures to prevent the use of their services for the purposes of money laundering.
  4. Money laundering is the process where criminals attempt to hide and change the true identity of the proceeds of their crime so that they appear legitimate. The various stages are termed placement, layering and integration:
    1. Placement: “dirty money” is placed directly into the financial system
    2. Layering: the proceeds are moved through a series of financial transactions, making it harder to establish their origin
    3. Integration: the money launderer creates a legitimate explanation for the source of the funds allowing them to be retained, invested into the legitimate economy or to acquire assets.
  5. The following constitute the act of money laundering:
    1. Concealing, disguising, converting, transferring criminal property or removing it from the UK (section 327 of the 2002 Act); or
    2. Entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (section 328); or
    3. Acquiring, using or possessing criminal property (section 329);
    4. Becoming concerned in an arrangement facilitating concealment, removal from the jurisdiction, transfer to nominees or any other retention or control of terrorist property (section 18 of the Terrorist Act 2000)
  6. These are the primary money laundering offences and thus prohibited acts under the legislation. There are also two secondary offences: failure to disclose any of the primary offences; and tipping-off. Tipping-off is where someone informs a person or people who are, or are suspected of, being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.
  7. Potentially any employee could be caught by the money laundering provisions if they suspect money laundering and do nothing about it or become involved with it in some way. This Policy sets out how any concerns should be raised. The key requirement for Raffique employees and partners is to promptly report (Section 337 Disclosure) any suspected money laundering activity to the Money Laundering Reporting Officer (MLRO).
  8. The Money Laundering Officer is Jodie Paget, Company Director who’s email is hello@raffique.co.uk.

Scope and Obligations


  1. This Policy applies to all employees of Joxle Limited and its partners. It sets out the required procedures which should be followed for reporting suspicions of money laundering activity to enable Joxle Limited to comply with its legal obligations which include but are not limited to:
    1. appointing a MLRO to receive disclosures from employees of money laundering activity (their own or anyone else’s);
    2. implement a procedure to enable the reporting of suspicions of money laundering;
    3. maintain client identification procedures in certain circumstances; and
    4. maintain record keeping procedures.
  2. Failure by a Joxle Limited employee to comply with the procedures set out in this Policy may lead to disciplinary action being taken against them.
  3. The Money Laundering Officer (MLRO) is: Jodie Paget, Company Director. 72a Windsor Street, Beeston, Nottingham. NG2 9BW. e: hello@raffique.co.uk
  4. In the absence of the MLRO disclosures will be received by Leah Marley, Company Director. 72a Windsor Street, Beeston, Nottingham. NG2 9BW. e: hello@raffique.co.uk

Prevention and Deterrence


Prevention and deterrence of money laundering refers to the procedures intended to prevent (and deter) criminals from disguising illegally obtained funds as legitimate income. By actively deterring acts of money laundering we protect Raffique, its’ Users and Hosts from criminals and ensure the future of a market-leading platform that is safe for all. All are to be aware of the following processes that are in place for their protection.

Our deterrence strategy includes but is not limited to:

  1. Anyone who wishes to participate in a pay to enter game of skill on the Raffique competition platform must register an account. Guest checkout is not permitted. No ticket transactions are made outside of the Raffique competition platform.
  2. The Raffique competition platform limits the number of tickets per user, per competition to 100 entries. Any requests for additional entries or orders placed over £1,001 in value will require a customer interaction. Should more than £1,001 worth of tickets be released, a full record will be maintained including but not limited to full name, total value and their numbers.
  3. Undertake the necessary checks for Hosts listing competitions on the Raffique platform including but not limited to;
    1. ID Checks, KYC and AML checks.
    2. Proof of ownership of the intended prize.
    3. Failure to provide such documents will result in a failed application.
  4. The following individuals may not enter a competition: (see point 6.2 of the Raffique Terms and Conditions).
    1. employees or shareholders of Raffique or its holding or subsidiary companies;
    2. employees of agents or suppliers of Raffique or its holding or subsidiary companies, who are professionally connected with the competition or its administration; or
    3. members of the immediate families or households of (a) and (b) above.
    4. Such entries are disqualified.
  5. Robust approval system including but not limited to;
    1. Restrictions of prizes that can be offered on the Raffique competition platform (see point 18 of the Raffique/Joxle Limited Terms and Conditions).
    2. Approval required for the aforementioned listings by an employee to ensure compliance with the Raffique/Joxle Limited Terms and Conditions.
  6. Measures within our platform prohibit manipulation of our technology however; Joxle Limited will freeze any account that appears to be suspicious, whether User or Host and any other transaction(s) made by the same user. Alerts include;
      1. Unusual patterns of transactions and; or
      2. Very high account turnover.

    Frozen accounts are promptly evaluated by the MLRO to determine whether it should be reported to the National Crime Agency (NCA).

  1. Operating a cashless organisation. All financial transaction(s) whether received or awarded are passed through reputable partners (banks/merchants or financial/legal institutions). Our organisation accepts no physical money.
  2. Work closely with our payment provider(s) that have experienced risk and fraud teams who scan and validate and monitor payment card transactions for potentially suspicious transactions.

Disclosure and Reporting


  1. If a member of staff has reasonable grounds to suspect money laundering activities or proceeds of crime, or is simply suspicious, the matter should still be reported to the MLRO.
  2. The MLRO or deputy must promptly evaluate any disclosure to determine whether it should be reported to the National Crime Agency (NCA).
  3. The MLRO or deputy must, if they so determine, promptly report the matter to the NCA on their standard report form and in the prescribed manner. Details can be found on the NCA website at: http://www.nationalcrimeagency.gov.uk/
  4. All disclosure reports referred to the MLRO or deputy and reports made to the NCA must be retained by the MLRO in a confidential file kept for that purpose, for a minimum of five years.
  5. The MLRO or deputy will commit a criminal offence if they know or suspect, or have reasonable grounds to do so, through a disclosure being made to them, that another person is engaged in money laundering and they do not disclose this as soon as practicable to the NCA.
  6. All information and records will be retained in-line with Joxle Limited’s legal and regulatory requirements. The MLRO will keep a record of all referrals made to them and of any action taken / not taken. The precise nature of these records is not set down in law but should be capable of providing an audit trail during any subsequent investigation.

Joxle Limited will regularly conduct an in-depth assessment of the money laundering risks to our business both off and online.

The Money Laundering Officer (MLRO) is: Jodie Paget, Company Director.