Beth.bet

Change the way you think about sports betting

Cookies

In order to provide you the best experience with our website, we use cookies. This may entail the processing of your personal data.
Please confirm if you consent to:
The use of cookies by BRC IT Lab in order to remember your settings, such as selected language or currency, between browsing sessions on our websites.
The use by BRC IT Lab of cookies for statistical purposes through analysis of aggregate data on traffic and manner of use of our websites.
The processing by BRC IT Lab also with the use cookies, of your personal data, including data related to your actions on BRC IT Lab websites, viewed content and use of BRC IT Lab products and services, for marketing purposes, also on the basis of automated processing containing profiling elements, in particular, for adaptation of our websites, offers and advertising to your interests.

Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from www.brclab.eu (the “Site”).

1. WHO WE ARE AND HOW YOU CAN CONTACT US

We are BRC IT Lab LP registered in Republic of Ireland. Registration no: LP2547.
Registered Office: OFFICE 29, CLIFTON HOUSE, FITZWILLIAM STREET LOWER, DUBLIN 2,
IRELAND ZIP Code: D02XT91

2. PERSONAL INFORMATION WE COLLECT

We will comply with applicable data protection laws (including, the General Data Protection Regulation (EU) 2016/679, in the UK, the Data Protection Act 2018) in respect of the personal information you supply to us.

2.1. Personal Data

Personal Data means any information that identifies You as an individual or that relates to an identifiable individual.

Whenever it is not possible or feasible for Us to make use of anonymous and/or anonymised data (in a manner that does not identify any Users of the Site or customers of Our services), We are nevertheless committed to protecting Your privacy and the security of Your Personal Data at all times.

2.2. Data obtained from You

We collect from You, through interaction with You or through Your interaction with Us or our Services different kinds of personal data about you which we have grouped together follows:

a) Registration Data provided by you when you register and/or open Your Account including first name, last name, username or similar identifier, date of birth, gender, country.

b) Contact Data includes permanent address, email address and telephone numbers.

c) Identification and Verification Data (Anti-Money Laundering/Due Diligence/KYC data) that include your name, surname, permanent address and proof, age, nationality, KYC documentation (e.g. ID card, Passport).

d) Responsible Gambling Data (RG) including name, surname, Zip Code, email, phone number, country, date of birth, Identification and Verification Data.

e) Payments Data includes bank/payment account details, as well as information pertaining to a transaction such as currency, location, amount/value, client IP, user ID, token.

f) Log in Data includes internet protocol (IP) address, your logins (first log in last login, last failed login), duration of log ins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.

g) Profile Data includes internal notes to your account, interests, preferences, feedback; Any bonus/cash back deals, or bonus preference you have been offered or benefitted from; Whether you have received any giveaways or, and your preferences regarding what type of gifts you would like to receive; Your preferences as to contact channels; information regarding your hobbies and interests;

i) Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out), as well as your Contact and Registration Data.

j) Other Communication Data provided by you in communication with Us (via recorded calls, chats, email, or SMS) which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes.

k) Analytics data include various data provided by your observed with respect to your use of our Website and Services such as your player ID, language, location, browser data, campaigns utilised, channels used, device, payment provider, Transaction and Usage data and in case of online acquisition analytics also pages visited, postcards clicked, scroll depth. Certain information is collected using cookies and/or similar tracking technology – please see section “Cookies”.

2.3. Data from different sources

2.3.1. We collect information for AML/CFT purposes on the background of the player, which we source from third party providers (private companies working mostly with public sources), which includes information whether player is politically exposed person and whether any international and/or financial sanctions have been imposed and/or information on any corporate or property ownership, court judgements and/or insolvency and with respect to players also taxation information for the purpose of establishment of the source of funds and source of wealth during the AML risk monitoring and due diligence process. As for today we use CallValidate (TransUnion) service as outsource company. Please read and understand CallValidate (TransUnion) relevant privacy notice https://www.callcredit.co.uk/legal-information/bureau-privacy-notice.

2.3.2. Profile data (hobbies, interests) are also gathered by search of publicly available sources such as Facebook, LinkedIn, Twitter and Instagram, Google search.

2.3.3. In order to prevent and detect fraud and misuse of our systems (e.g. use of VPN), certain Log In Data, such as; IP address, device model/type, browser information, operating system and other device identification data are sourced and processed by Us utilizing a services of third-party fraud detection software provider.

2.4. Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, from our experience, we may not exclude that You, at your own discretion, send us such data in communication with Us.

Please note that although ID cards are processed, images contained therein are not specifically technically processed to allow or confirm unique identification. Therefore, such data is not to be considered biometric data (special category of data).

2.5. If You Fail To Provide Personal Data

Where we need to collect personal data under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Our Services).

2.6. Username

Please make sure that your username does not contain any personally identifiable information. Please contact us if your user name contains your personally identifiable data, so we can make proper arrangements to protect your data and guide you as to how to change the username.

HOW DO WE USE YOUR PERSONAL INFORMATION?

3.1. We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

• To allow You to participate in gambling website with the use of our Product (Gambling Bot + Card) to provide ancillary services to You
• To allow You access and use of our website
• For legal and regulatory reasons, to comply with our legal obligations such as Anti-money laundering and responsible gaming.
• For identification and verification proposes
• For purposes that constitute a legitimate interest of BRC IT Lab regarding direct marketing of its own similar goods and services.
• For analytics purposes

3.2. Detailed purposes and legal basis

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data.

• To register you as our customer, to identify you and verify you when you access your Account we use your Registration Data, Contact Data and Log-in-Data.
• To process and manage payment transactions we use your Payment Data and Transaction and Usage Data.
• For AML/CTF and due diligence purposes we will use your Registration Data, Contact Data, Profile Data, Other Communication Data, Transaction and Usage Data, Self-exclusion Data.
• To establish and investigate any suspicious behavior in order to protect our business from any risk and fraud we will use Registration Data, Contact Data, Identification and Verification Data, Log in Data, Payment Data, Other Communication Data.
• For Web Analytics we will use Analytics Data, Transaction and Usage Data
• For Social Media Marketing we will use your Contact Data

3.3. Direct Marketing Of Own Similar Goods And Services

3.3.1. Direct Marketing of Own Similar Products and Services via electronic mail: In accordance with applicable laws and in reliance on Regulation 9(2) of the Processing of Personal Data (Electronic Communication sector) Regulations (S.L. 586.01) and Recital 47 of the GDPR, BRC IT LAB may be informing You, from time to time, via electronic mail (email or SMS) about its own similar products or services (for example any changes on the Website, new products, own new services and promotions, bonuses and offers, loyalty program/VIP experience). You may opt out at any time and free of charge of such service, as applicable, either by:

• Contacting us, or
• Changing your Settings in your profile.

3.3.2. We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

3.3.3. Please note that even if You object to receiving direct marketing material from time to time We may still need to send You certain important communications from which You cannot opt-out.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
You can contact us
+353 1960 9697
or by e-mail support@brclab.eu

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of EU.

DATA RETENTION

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

MINORS

The Site is not intended for individuals under the age of 18.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at support@brclab.eu

Last update 21/01/2020

DISCLAIMER:

All betting in any forms involves risk. Be aware and accept this risk before betting. Never bet with money you cannot afford to lose. No "safe" betting system has ever been invented and no one can guarantee profits or absence of loss. No representation is being made that any account will achieve profits or losses similar to those discussed.

There is no guarantee that, even with the best advice available, you will become a successful better because not everyone has what it takes to be a successful in betting. The betting software discussed may be unsuitable for you depending upon your specific investment objectives and financial position. You must make your own decisions in light of your own objectives, risk profile, and circumstances. Use independent advisors as you believe necessary.

All information on this website or any software purchased from this website is for betting purposes only and is not intended to provide financial advice. Any statements about profits or income, expressed or implied, do not represent a guarantee. Your actual betting may result in losses as no betting system is guaranteed. You accept full responsibilities for your actions, bets, profit or loss, and agree to hold BRC IT Lab Limited and any authorized distributors of this software harmless in any and all ways.

In fact, there are frequently sharp differences between hypothetical performance results and the actual results subsequently achieved by any particular betting program. Hypothetical betting does not involve financial risk, and no hypothetical betting record can completely account for the impact of financial risk in actual betting.

The information provided on this website or any software from this website is not intended for distribution to, or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us to any registration requirement within such jurisdiction or country. We reserve the right to change these terms and conditions without notice. You can check for updates to this disclaimer at any time by visiting this page. The content of this website are copyrighted and may not be copied or reproduced

This is a low cost software tool designed to help only with the mechanics of betting. We do not give or sell information or give advice to help you with gambling. Our software doesn’t influence on the results of the sport event. Every effort is made to ensure that any software sold by us is free of bugs but we will not warrant and cannot warrant that our software is bug free. Any upgrades made by us to existing software that makes the code more reliable will be passed on to the customer free of charge.

INTRODUCTION

The following services are made available by BRC IT Lab LP registered in Republic of Ireland.
Registration no: LP2547.
Registered Office: OFFICE 29, CLIFTON HOUSE, FITZWILLIAM STREET LOWER, DUBLIN 2,
IRELAND ZIP Code: D02XT91

TERMS AND CONDITIONS:

REGISTRATION, ACCOUNT AND PASSWORD

1. Application

1.1 All applicants must be over 18 years of age and of legal capacity to place a bet/wager or register with betting services. BRC IT Lab reserves the right to ask for proof of age from any customer and suspend their account until satisfactory documentation is provided. BRC IT LAB takes its responsibilities in respect of under age and responsible gambling very seriously.

1.2 All information supplied when registering with the site MUST be your information and be accurate and complete in all respects. Where this is not the case, we reserve the right to suspend the account. Where an account is suspended, the relevant customer should Contact Us.

1.3 By accepting the Terms and/or registering to use the Website you hereby agree that we shall be entitled to conduct any and all such identification, and verification checks from time to time that we may require and/or are required by applicable laws and regulations and/or by the relevant regulatory authorities for use of the Website and our products generally. You agree to provide all such information as we require in connection with such verification checks. We shall be entitled to suspend or restrict your account in any manner that we may deem to be appropriate, until such time as the relevant checks are completed to our satisfaction.

1.4 As part of the registration process, we may supply your information details to authorized reference agencies to confirm your identity and payment card details. You agree that we may process such information in connection with your registration.

1.5 Customers may open only one account. Should we identify any customer with more than one account we reserve the right to treat any such accounts as one joint account.

1.6 Customers must keep their registration and account details up to date. This, and your account information, may be amended in the Personal section of the Website. If you require any assistance, please Contact Us.

2. Account Details

2.1 BRC IT LAB allows all its customers to choose their own Username/Password combination for their account. Customers must keep this information secret and confidential.

2.2 If, at any time, you feel a third party is aware of your Username, Password and/or Passcode you should change it immediately via the Website. Should you forget part or all of your combination, please Contact Us.

3. Personal Details

3.1 We will comply with applicable data protection laws (including, the General Data Protection Regulation (EU) 2016/679, in the UK, the Data Protection Act 2018 and, in Gibraltar, the Data Protection Act 2004) in respect of the personal information you supply to us. Your personal information is processed in accordance with our Privacy Policy.

SOFTWARE

Software downloaded from this website site is provided 'as is' without warranty of any kind, either express or implied, including, but not limited to, the implied warranties of fitness for a purpose, or the warranty of non-infringement. Without limiting the foregoing, BRC IT Lab makes no warranty that:

the software will meet your requirements
the software will be uninterrupted, timely, secure or error-free
the results that may be obtained from the use of the software will be effective, accurate or reliable
with the use of our software you will definitely make profit from sport betting
the quality of the software will meet your expectations
any errors in the BRC IT Lab software will be corrected
software and its documentation made available on this site will not include technical or other mistakes, inaccuracies or typographical errors, and that it will not be out of date, and BRC IT Lab Limited makes no commitment to update such materials. BRC IT Lab may make changes to the software or documentation made available on its web site. BRC IT Lab assume no responsibility for errors or omissions in the software or documentation available from its web site.

In no event shall BRC IT Lab be liable to you or any third parties for any special, punitive, incidental, indirect or consequential damages of any kind, or any damages whatsoever, including, without limitation, those resulting from loss of use, data or profits, whether or not BRC IT Lab has been advised of the possibility of such damages, and on any theory of liability, arising out of or in connection with the use of this software.

The use of the software bought through this web site is done at your own discretion and risk and with agreement that you will be solely responsible for any damage to your computer system or loss of data that results from such activities. No advice or information, whether oral or written, obtained by you from the BRC IT Lab or from this web site shall create any warranty for the software.

You must not share, publish, sell or give your BRC IT Lab software license to any other person. Any license that are publicly published or shared with other people or sold to other people will be permanently deactivated.

We are under no obligation to produce or offer any updates, upgrades or add-ons at all or for any particular product.

The free email support service is for technical and customer support and does not amount to a tipping service or an enhancement of any product.

You must be over 18.

Prices on this website are quoted exclusive of Value Added Tax (VAT) where applicable. VAT is applicable only for United Kingdom, and therefore depends on your billing address, will be calculated at checkout.

PURCHASES

You may purchase Betting Agent, and Prepaid Cards (together, the “Products”) through the website as follows:

Our shopping pages will guide you through the steps you need to take to place an order for a Product (“Order”) with us. Our order process allows you to check and amend any errors before submitting your order to us. Please take the time to read and check your Order at each stage of the order process.
When you place an Order this will be deemed an offer by you to buy the Product(s) for the price stated, subject to these terms and conditions.
After you have submitted your Order BRC IT Lab will send you an e-mail to confirm that your order has been accepted and payment received. This email confirmation will be produced automatically so that you have confirmation of your Order details and payment.
The link to download the Betting Agent will be sent you in separate e-mail due to security reasons, after the payment for the program is proceeded.

Where you have incorrectly submitted an Order or you have additional questions, please contact us by phone +353 1960 9697 or by email support@brclab.eu.

If BRC IT Lab are unable to supply you with a Product for any reason we will inform you of this by email or otherwise through the Service, and we will not process your Order. If you have already paid for the Product(s), BRC IT Lab will refund you the full amount, as soon as possible.

PRICE AND PAYMENT

Payment is due from the moment an Order is accepted. Payment may be made as set out on the payment page of the Service, by credit card, debit card or any other such method as BRC IT Lab may introduce in its sole discretion. BRC IT Lab reserves the right to accept or refuse any payment made in any form.
Prices are quoted in UK Pounds.
If you do not hold an account in the relevant currency you should pay by debit or credit card (or any other method that BRC IT Lab may introduce from time to time) and your card company should exchange the amount charged to the currency of your country at the current rate. Please note that you are responsible for paying any currency exchange, or other payment charges.

Your credit card company may also do security checks to confirm it is you making the Order.

LIABILITY

The customer accepts that no liability shall attach to BRC IT Lab LP in respect of any loss to the customer arising from any failure not directly attributable to our product. No liability shall rest with BRC IT Lab LP for situations including, but not limited to, the following, which may result in a failure to place bets or trade out of a position at the best time or at all:
The failure for any period and for whatever reason by the customer to maintain a functioning account with the Betting Agent.
The failure for any period and for whatever reason by the customer to maintain sufficient credit balance in any such account with the Betting Agent to allow completion as instructed to the account
The failure whether in full or part for whatever reason of any internet connection provided by any Internet Service Provider used from time to time by the customer
The failure whether in full or part of any hardware used from time to time by the customer
The failure whether in full or in part for whatever reason of the Betting Agent website to work with full functionality and speed
The failure of the Betting Agent API for any reason including but not limited to technical issues and refusal or inability by the Betting Agent to allow further use of the relevant API for the country in which the customer is located or resident.
Any change in the law of the customer's country of residence or location prohibiting or restricting the use of the software as designed, betting and or online betting of the sort provided by the Betting Agent
We will not be liable in any amount for failure to perform any obligation under this agreement if such failure is caused by the occurrence of any unforeseen contingency beyond our reasonable control including Internet outages, communications outages, fire, flood, war or act of God.

Except as provided above there are no other warranties, conditions or other terms and conditions, express or implied, statutory or otherwise, and all such terms and conditions are hereby excluded to the maximum extent permitted by law.

You agree that in relation to your use of the Service you will not in any way conduct yourself in a manner which is unlawful or which gives rise to civil or criminal liability or which might call us or the Service into disrepute.

You agree that you are and shall remain responsible for maintaining the confidentiality of your password and username and for all activities that occur under your account.

The liquidation or other closure of the BRC IT Lab.

SERVICES DELIVERY POLICY

www.brclab.eu is software provider. Before our software is available for payment and use, customer must accept the Terms and Conditions as presented.

Our services are available via e-commerce only. We don’t need your shipping address.

The customer may select any payment method provided by www.brclab.eu at his convenience.

By payment for the selected package user expresses his explicit consent to the terms and conditions and by payment of services also he indicates that he has read business conditions, has understood their content and its wording is clear and understandable for him/her.

The history of all the payments and packages bought by the customer and the delivery of the services are automatically displayed in the customer’s account cabinet.

Please, pay attention that the packages bought are never subject to automatic renewal. www.brclab.eu doesn’t offer any recurring payments for any of its services.

TERMINATION

Without limiting any other rights that we may have, we may remove, restrict, cancel or suspend access to and/or use of the Betting Agent (Service) and any part of it, if we consider (in our sole discretion) that you have breached any of these terms and conditions.

You may also terminate your agreement with us by ceasing to access the Betting Agent (Service), deleting all copies of the Service or part thereof within your control. Termination shall not affect any rights or remedies which have accrued up to the time of termination.

CANCELLATION RETURN/REFUND POLICY AND CLAIMS

www.brclab.eu does not offer refunds for any payments already made.

www.brclab.eu return (refund) payment of customers in following cases:
not authorized payment (without knowledge of account holder)
not verified account
account with invalid debit/credit card
All disputes that may arise in the process of this contract implementation shall be settled by negotiations and agreements between the parties.
In cases foreseen by this Contract the partiers must act in compliance with EU and UK Law.
All disputes that may arise in the process of this Terms and Conditions implementation shall be settled by negotiations and agreements between the parties.
In cases foreseen by this Terms and Conditions the partiers must act in compliance with the Law of Ireland.

IF THERE IS A PROBLEM WITH THE PRODUCT

If you have any questions or complaints about a Product, please contact us. You can telephone our customer service team by phone +353 1960 9697 or write to us at support@brclab.eu.

This document was last updated 21/01/2020

AML policy:

ANTI-MONEY LAUNDERING POLICY AND PROCEDURES

These are the Anti-Money Laundering (ALM) Policy and Procedures adopted by “BRC IT LAB LP” (The Company) in compliance with Criminal Justice Money Laundering and Terrorist Financing Act 2010, as amended by Part 2 of the Criminal Justice Act 2013 (“the Act”), that transposes the EU’s Fourth Money Laundering Directive (2015/849).

OBJECTIVES

The purpose of this policy is to set the high-level principles and standards of management of financial crime risks, including money laundering, and terrorist financing, for the Company.

The Company will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:

• The identities of all new and existing clients will be verified to a reasonable level of certainty
• A risk-based approach will be taken to the monitoring of client tax and accounting affairs
• Any suspicious activity will be reported, and all AML activities recorded
• All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.

DEFINITIONS

For the purpose of this Policy, the act of Money Laundering shall have the same meaning as provided in Article 1(3) of the EU AMLD, which provides that it, when committed intentionally, encompasses:

• the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's 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 an act of participation 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 (a), (b) and (c).

Money laundering shall be regarded as such even where 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.”

For the purpose of this Policy, the act of Terrorist Financing shall have the same meaning as provided in Article 1(5) of the EU AMLD, which provides that it encompasses;  “the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA”.

For the purpose of this Policy the act of Terrorist financing refers to the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out an act of terror, or that the funds will be used to support any terrorist group, persons or association.

CUSTOMER DUE DILIGENCE

The Company has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients are verified to a reasonable level of certainty. This will include all individual clients. Identities will be verified either by email address confirmation or recognized by online identity verification agencies (such as Jumio®). These commercial agencies must have processes that allow the enquirer to capture and store the information they use to check and verify an identity.

The following documentation may be presented by the individual:

• Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.

If the Company fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.

RISK ASSESSMENT AND ONGOING MONITORING

The Company shall take a risk-based approach in monitoring the financial activities of its clients. This will be carried out whilst preparing the accounts, or conducting any other business with the client.

The Company will actively not accept high-risk clients that are identified as follows:

• Clients with large one-off transactions, or a number of transactions carried out by the same customer within a short space of time.
• Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organised crime or drug production/distribution.
• Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
• Money received from areas known to have high levels of criminality or terrorist activity.
• The following are examples of changes in a client’s situation that may be considered suspicious:
• A sudden increase of purchases from an existing customer;
• Uncharacteristic transactions which are not in keeping with the customer’s known activities;
• Peaks of activity at particular locations or at particular times;

Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

No action need to be taken if there is no cause for suspicion.

SUSPICIOUS ACTIVITY REPORTING

A Suspicious Activity Report (SAR) will be made to the Competent authorities as soon as the knowledge or suspicion that criminal proceeds exist arises.

RECORD-KEEPING

Records of all identity checks will be maintained for up to 2 years after the termination of the business relationship or 2 years from the date when the payment has been completed.

Copies of any SAR, together with any supporting documentation filed will be maintained for 5 years from the date of tiling the SAR.

All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.

TRAINING

All affected employees are trained on their responsibilities in relation to money laundering legislation, and are aware of how to identify and deal with transactions that may involve money laundering.

The training and awareness programme is reflected in its usage by:

1. mandatory AML learning training programme in accordance with the latest regulatory evolutions;
2. brief academic AML learning sessions for all new employees.

REVIEW

This Policy must be reviewed by the Comapny at least annually. Any changes to the Policy must be approved by the key stakeholders.