Compliance Policies

1. Introduction

Here4YouWins is committed to preventing money laundering and ensuring compliance with all applicable UK anti-money laundering legislation, including the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, and related guidance from the Gambling Commission.

2. Policy Statement

We maintain robust systems and controls to detect, prevent, and report any suspicious activity that may be related to money laundering. All employees are trained to recognise and report potential money laundering activities.

3. Customer Due Diligence (CDD)

We implement the following measures:

• Verification of customer identity before allowing significant transactions
• Enhanced due diligence for high-value prize claims
• Ongoing monitoring of customer activity and transactions
• Record keeping of all verification documents for a minimum of 5 years
• Risk-based approach to customer assessment

4. Identity Verification

All customers must be verified as being 18 years or older and resident in the UK. For prize claims above £2,000, we require:

• Valid photo identification (passport, driving licence)
• Proof of address dated within the last 3 months
• Source of funds verification where appropriate

5. Transaction Monitoring

We actively monitor for:

• Unusual patterns of ticket purchases
• Multiple accounts linked to the same payment method
• Transactions inconsistent with customer profile
• Use of multiple payment methods by a single customer
• Rapid or unusual changes in account activity

6. Suspicious Activity Reporting

Where we identify suspicious activity, we will submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA). We will not inform the customer of any such report in accordance with tipping-off regulations.

7. Staff Training

All staff members receive comprehensive AML training upon joining and annual refresher training. This includes recognition of suspicious activity, reporting procedures, and understanding their legal obligations.

8. Record Keeping

We maintain records of all customer due diligence and transactions for a minimum of 5 years following the end of the customer relationship or completion of the transaction, whichever is later.