Golden Ape Limited (“Jambo8” or the “Company”) is a company incorporated under British Virgin Islands Law that was established in 2024 and operates the online casino www.Jambo8.com under the licence n.º xxxxxxxxx.As part of its global operations, Jambo8 has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.
2. Company Policy Statement
Jambo8 is not a financial institution within the meaning of applicable law of the British Virgin Islands and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the Anti-Money Laundering Regulations (revised 2020) applicable for the British Virgin Islands,, Jambo8 expressly prohibits and rejects the use of Jambo8 products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering (“AML”) laws, regulations and norms. Jambo8 continues to monitor norm setting parameters promulgated by the Financial Action Task Force (“FATF”) and certain gaming trade groups in addition to Gaming Control Anjouan and will take necessary action as it deems appropriate to reflect changes in law.Jambo8's intention is to follow global best practices in guarding against Jambo8 products being used to facilitate such activities. Those best practices include:
Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;
Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;
Provision of related education and training to relevant personnel;
Independent reviews, monitoring and maintenance of the policy, procedures and controls.
3. Definitions
The following defined terms are widely used in the industry:
Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.
Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.
Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.
Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.
Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.
Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions. For example, they are used to encourage a change in behavior for a target country or regime; to apply pressure on a target country to comply with set objectives; as an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or to prevent and suppress the financing of terrorists or terrorist acts.
4. Governance and Oversight
Jambo8 has appointed a Chief Compliance Officer (“CCO”) that is responsible for coordinating the implementation of the AML Policy and policy program. The Chief Compliance Officer’s duties also include developing AML initiatives, work with other Jambo8holders to revising the AML policy, assessing new regulatory requirements and investigate potentially suspicious or unusual activity. Jambo8 also provides AML training to all of its employees on a regular basis.
5. Know Your Customer
Jambo8 will apply appropriate user due diligence and ongoing monitoring measures required by law. Jambo8 will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity. Jambo8 uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.A. Customer Due Diligence
Jambo8 has adopted a risk-based process to customer due diligence to enable it to understand the nature and purpose of the user relationship to the Jambo8 platform, thereby developing a customer risk profile.
Jambo8 collects documentary and non-documentary information at account opening, commensurate with the nature of the type of account and services offered.
Customer Identification Program (CIP):
Collection of baseline information (e.g., full name, email address, date of birth etc.) through Jambo8’s user profile portal. This information is required to be completed and verified before a customer withdrawal can be made from a player account.
Maintaining records of information used to identify the user.
Determining if a user appears on any list of known or suspected terrorists or terrorist organizations.
Operational Measures:
Identity and Age Verification: Jambo8 verifies the legitimacy of identification and other KYC materials, confirming the user is permissible and not located in comprehensively-sanctioned or prohibited jurisdictions.
Customer Information: Collection of details like name, address, country, date of birth, or postal code to form a reasonable belief about the user's identity, commensurate with their risk profile.
Identity Verification: The verification of identity may be completed through the screening process conducted during customer verification; a customer must successfully pass before they can make a withdrawal from the platform. Checks for politically exposed persons (PEP), sanctions, and adverse media will also be conducted. A customer will not be able to withdraw until they have satisfied the company's verification requirements.Acceptable identity documents for verifying identity are as below:
Passport
national ID card
Armed forces ID card
Full driving licence
B. Enhanced Due Diligence and Ongoing Monitoring
Regular monitoring of users to detect behaviors or indicators related to money laundering and terrorism financing.
Implementation of red flag indicators for assessing customer information.
Suspension of user accounts and pursuit of enhanced due diligence when red flags are triggered.
Third-party service providers may be used for verification.
C. Acceptance Policy
Jambo8 will not accept or will block users who:
Do not provide requested identification information.
Provide fake identification documents.
Attempt to deceive about their location.
Are from restricted or prohibited jurisdictions.
Are subject to sanctions or watch lists.
Are identified with gambling addiction or mental health issues.
Have source of funds originating in restricted jurisdictions.
Jambo8 reserves the right to block and suspend players for other reasons at its discretion.
D. Transaction Monitoring
Commitment to comply with economic and trade sanctions programs.
Establishment of a transaction monitoring program with controls and processes for real-time and ongoing monitoring.
Regular use of rule-based systems to review user history and activity patterns.
Procedures Include:
Identification of unusual activity.
Alert management for investigating and documenting unusual or suspicious activity.
Processes:
Transaction monitoring for sanctioned or prohibited jurisdictions.
Screening for sanctioned parties.
Identification of unusual activity.
Anti-mixing measures.
Chainalysis review.
Withdrawal threshold KYC.
Ban evasion detection.
Time zone monitoring.
Products and services review.
Vendor management.
Compliance innovation.
6. Education and Training
Jambo8, with the assistance of its legal counsel and under the oversight of its CCO, may provide employees AML, anti-terrorist financing, and trade sanctions compliance training on a periodic basis, as deemed appropriate.
7. Reporting
Jambo8 is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity to the regulator.