AML Policy

1. Introduction and Purpose

   1. Introduction
      Welcome to the Anti-Money Laundering (AML) Policy of www.brazino777.mx, operated by Fiesta Fortunes S.A. de C.V. (“Fiesta Fortunes”). As a leading provider of online gambling services, we are committed to maintaining the highest standards of integrity and regulatory compliance. This policy outlines our commitment to preventing and detecting money laundering and terrorist financing activities within our operations.
   2. Purpose
      The purpose of this AML Policy is to ensure that www.brazino777.mx operates in accordance with all applicable laws and regulations related to anti-money laundering and counter-terrorist financing. The objectives of this policy are to:
      1. Protect the integrity and reputation of Fiesta Fortunes and www.brazino777.mx by implementing robust AML measures.
      2. Establish a comprehensive framework for identifying, assessing, and managing money laundering and terrorist financing risks.
      3. Define the responsibilities and procedures for preventing, detecting, and reporting suspicious activities.
      4. Ensure all employees, partners, and stakeholders understand and adhere to their obligations under this policy.
      5. Foster a culture of compliance and ethical behavior within our organization.
      This policy applies to all employees, agents, and third-party service providers of www.brazino777.mx. Adherence to this policy is mandatory, and any non-compliance will be subject to disciplinary action, up to and including termination of employment or business relationships.
      
      By implementing this AML Policy, Fiesta Fortunes demonstrates its commitment to combating financial crimes and contributing to a safer and more secure gambling environment for everyone.
   3. Definitions
      Money laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds or any other benefit of their criminal activities, thereby avoiding prosecution, conviction, and confiscation of the criminal funds. There are three stages in the process:
      1. Placement: Cash first enters the financial system at the "placement" stage, were the cash generated from criminal activities is converted into monetary instrument
      2. Layering: How the link between the funds and the criminal is concealed
      3. Integration: Investing and/or recovering the funds in a way that looks legitimate.
      As a Company policy we do not to accept cash as means of payment, the Company’s AML Policy is focused to prevent the use of the Company’s activities and resources in the 2nd and in the 3rd stage.

2. Legal and Regulatory Framework

   1. Compliance Requirements
      Fiesta Fortunes, the operator of www.brazino777.mx, is committed to complying with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations. Our AML Policy is designed also to meet the requirements set forth by international and national regulatory bodies.
   2. International Framework
      Our AML practices are aligned with international standards and guidelines, including:
      1. Financial Action Task Force (FATF) Recommendations: We adhere to the 40 Recommendations established by FATF, which provide a comprehensive framework for AML and CTF efforts globally.
      2. European Union Anti-Money Laundering Directives (AMLD): While primarily applicable to EU member states, we consider these directives as best practice guidelines for our operations.
   3. National Framework in Mexico
      In Mexico, our AML efforts are governed by specific laws and regulations, including:
      1. AML Law: The Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita. This law provides the primary legal framework for preventing and identifying money laundering activities in Mexico. It outlines the responsibilities of businesses in various sectors, including gambling, to implement AML measures.
      2. AML Law Regulations: The Reglamento de la de la Ley Federal para la Prevencion e Identificacion de Operaciones con Recursos de Procedencia Ilícita, elaborates on the obligations contained in the AML Law, providing more detailed requirements and instructions to fully comply with the AML Law.
      3. AML General Regulations: the Reglas de Carácter General a que se refiere la Ley Federal para la Prevencion e Identificacion de Operaciones con Recursos de Procedencia Ilícita). It’s a set of additional rules, some of them more technical in nature.
   4. Regulatory Bodies
      Our compliance with AML regulations is overseen by the Unidad de Inteligencia Financiera (UIF), which is the financial intelligence unit in Mexico responsible for monitoring and enforcing AML and CTF laws. The UIF provides guidelines and oversight to ensure that offline and online gaming operators operate in full compliance with national and international standards.
      By adhering to these legal and regulatory frameworks, Fiesta Fortunes ensures that www.brazino777.mx implements effective measures to prevent money laundering and terrorist financing, thereby safeguarding our business and contributing to the global fight against financial crime.

3. Risk Assessment

   1. Risk-Based Approach
      We adopt a risk-based approach to AML and CTF, allowing us to efficiently allocate resources to areas where they are most needed and to implement appropriate measures to mitigate identified risks. Our risk assessment process considers various factors, including the nature of our services, customer behavior, and geographic risk.
   2. Ongoing Risk Assessment
      At www.brazino777.mx our risk assessment procedures are continuously reviewed and updated to ensure their effectiveness. This includes:
      1. Regularly assessing and categorizing risks related to customers, transactions, and geographical regions.
      2. Updating risk profiles based on new information and changes in the regulatory environment.
      3. Conducting periodic audits and reviews of our AML program.

4. Customer Due Diligence (CDD)

   1. Identification and Verification
      We implement stringent procedures for verifying the identity of our customers, particularly for Identifiable Transactions (transactions equal to or greater than 325 times the minimum wage, MXN $35,285.25). The information required includes:
      1. Full name, date of birth, country of birth, nationality, occupation, phone number, email, CURP (if available), and tax ID number.
      2. Details of the identification document, including the document’s name, number, and issuing authority.
      3. Copies of valid ID with a photograph, CURP document (if available), and proof of address if needed.
   2. Ongoing Risk Assessment
      At Brazino  777 casino our risk assessment procedures are continuously reviewed and updated to ensure their effectiveness. This includes:
      1. Regularly assessing and categorizing risks related to customers, transactions, and geographical regions.
      2. Updating risk profiles based on new information and changes in the regulatory environment.
      3. Conducting periodic audits and reviews of our AML program.
   3. We maintain records of all subsequent Identifiable Transactions for a six-month Accumulation Period. If the total of these transactions exceeds 645 times the minimum wage (MXN 70,027.75), an AML Report must be filed with the Unidad de Inteligencia Financiera (UIF).
   4. Enhanced Due Diligence (EDD)
      For high-risk customers, including those from high-risk jurisdictions, we conduct enhanced due diligence (EDD). This involves additional verification steps and closer scrutiny of transactions to ensure compliance with AML regulations.
   5. Customer Risk Profiling
      We categorize customers based on their risk profile, considering factors such as transaction size, frequency, and customer background. This allows us to apply appropriate levels of monitoring and due diligence.

5. Account Monitoring and Transaction Reporting

   1. Monitoring Transactions
      Our system continuously monitors transactions to identify any that meet or exceed the threshold for Identifiable Transactions. While the regulation requires monitoring deposits, we also consider the industry standard and best practices to monitor all types of transactions, including withdrawals and winnings, to ensure comprehensive compliance.
   2. Suspicious Activity Reporting (SAR)
      We have procedures in place for identifying and reporting suspicious transactions to the UIF. This includes submitting an AML Report for transactions that exceed 645 times the minimum wage (MXN 70,027.75) within the Accumulation Period.
   3. Record Keeping
      We maintain comprehensive records of customer identification, transactions, and AML reports for a minimum of five years, in compliance with legal requirements.
   4. Risk Factors and Mitigation Measures
      1. Identifying Risk Factors
         We identify and evaluate risk factors based on the following criteria:
         1. Transaction Size and Frequency: High-value transactions or a high frequency of transactions within a short period.
         2. Customer Profile: Customers from high-risk jurisdictions or those with inconsistent information.
         3. Transaction Patterns: Unusual or suspicious transaction patterns, such as rapid deposits and withdrawals.
      2. Mitigation Measures
         To mitigate these risks, we implement the following measures:
         1. Enhanced Due Diligence (EDD): For high-risk customers and transactions, we conduct more stringent checks and maintain enhanced monitoring.
         2. Transaction Limits and Alerts: Setting thresholds and alerts to flag suspicious activities for further investigation.
         3. Employee Training: Regular training programs for our staff to recognize and report suspicious activities.
         4. Periodic Reviews: Regular audits and updates of our risk assessment process to ensure its effectiveness and relevance.

6. Internal Controls and Procedures

   1. Internal Policies
      We implement robust internal controls to detect and prevent money laundering activities. These controls include transaction monitoring systems, customer due diligence procedures, and regular compliance audits.
   2. Employee Training
      All employees receive regular training on AML regulations, recognizing suspicious activities, and proper reporting procedures. This ensures that our staff are well-equipped to detect and respond to potential money laundering activities.
   3. Audit and Review
      Our AML program undergoes regular audits and reviews to ensure its effectiveness and compliance with regulations. This includes both internal and external audits to identify and address any weaknesses in our AML controls.

7. Responsibilities and Governance

   1. AML Compliance Officer
      We appoint a designated AML Compliance Officer responsible for overseeing the implementation and maintenance of our AML program. The AML Compliance Officer reports directly to senior management and the board.
   2. Board and Management Oversight
      Senior management and the board of directors play a critical role in the governance and oversight of our AML policy. They are responsible for ensuring that adequate resources are allocated to the AML program and that it remains effective and compliant with regulations.

8. Reporting and Record Keeping

   1. Report Submission
      We have established procedures for the timely submission of AML reports to the UIF. Reports are prepared and submitted to the provider of the license under which www.brazino777.mx operates (UNOCAPALI LA PAZ OPERADORA S.A. DE C.V.), in accordance with the deadlines and requirements specified by the UIF. UNOAPALI LA PAZ OPERADORA S.A. DE C.V., as the provider of the gaming license for the www.brazino777.mx, is required to submit the AML reports to the UIF, but it is Fiesta Fortunes’ obligation, as operator of the site, to keep a record of the transactions, monitor player activity, collect player data and documentation, and in general to comply with all the AML regulations, even if the entity that by law must submit the reports, is UNOCAPALI LA PAZ OPERADORA S.A. DE C.V.
      We also have procedures and protocols in place to verify that the license holder submits, in a timely basis, the reports that we prepare for them in compliance with AML regulations.
   2. Documentation
      We ensure that all documents related to customer identification, transaction records, and AML reports are retained for the required period of five years. This documentation is securely stored and readily accessible for regulatory review.
      By implementing this comprehensive AML Policy, www.brazino777.mx and Fiesta Fortunes are committed to maintaining the highest standards of integrity and regulatory compliance, and to contributing to the global effort against money laundering and terrorist financing.