Anti-Money Laundering Guidelines
What Is the AML Policy
TeleBet's Anti-Money Laundering Policy establishes the framework under which the operator identifies, assesses, monitors and reports activity that may constitute money laundering or the financing of terrorism. The policy applies to all accounts registered on the platform and is maintained in accordance with the obligations imposed by the Federal Democratic Republic of Ethiopia National Lottery Administration licence number ስ/ው/ብሎ/29/2016 and applicable law.
The purpose of this policy is to ensure that the platform cannot be used — whether knowingly or unknowingly — as a vehicle through which the proceeds of criminal activity are placed, layered or integrated into the legitimate financial system. Compliance with this policy is mandatory for all players; accounts that cannot be verified or that demonstrate indicators of financial crime are subject to restriction or termination without prior notice.
Structure of the AML Guidelines
The AML framework at TeleBet is organised into five core sections, each addressing a distinct area of compliance obligation. These sections form the operational spine of the policy and are applied continuously across all account activity.
- Customer Identification and Verification — establishing and confirming the identity of every account holder before any withdrawal is processed, and at any point the operator deems necessary.
- Risk Assessment — evaluating the money-laundering and terrorist-financing risk profile of individual accounts based on transaction patterns, geographic factors and account behaviour.
- Transaction Monitoring — ongoing automated and manual review of account activity to detect patterns inconsistent with a player's stated profile or normal gambling behaviour.
- Suspicious Activity Reporting — formal procedures for escalating and filing reports with the relevant authority where activity meets the threshold for suspicion.
- Record Keeping — retention of identification documents, transaction records and correspondence for the periods required by applicable law and regulatory obligation.
Possible Actions the Casino May Take
Where a breach of this policy is identified, or where an account presents unacceptable risk, the operator may apply one or more of the following measures:
- Temporary suspension of the account pending investigation.
- Permanent termination of the account.
- Freezing of funds held in the account balance.
- Forfeiture of bonuses, free spins and any associated winnings.
- Requesting additional documentation or a source-of-funds declaration before any withdrawal is released.
- Running credit and identity checks through third-party agencies.
- Filing a Suspicious Activity Report with the competent authority.
- Cooperating fully with law-enforcement or regulatory bodies investigating the account holder.
- Referral of the matter to appropriate legal or prosecutorial authorities.
Due Diligence Levels
TeleBet applies a three-tier due-diligence framework. The level of scrutiny applied to an account is determined by the risk indicators present at registration and during ongoing activity. All three levels may be escalated at the operator's discretion where new information changes the risk assessment of an account.
| Level | Name | When It Applies |
|---|---|---|
| SDD | Simplified Due Diligence | Applied where the account presents a demonstrably low risk of money laundering or terrorist financing — for example, accounts with low transaction volumes and no adverse risk indicators. Basic identity data is collected but full document verification may be deferred. |
| CDD | Customer Due Diligence | The standard level applied to all accounts as a baseline requirement. Includes verification of identity through accepted documents, confirmation of date of birth, and monitoring of transactions against the player's stated activity profile. Required before any withdrawal is released. |
| EDD | Enhanced Due Diligence | Applied where specific risk indicators are present — including, but not limited to, politically exposed persons, accounts with unusually high or irregular transaction volumes, accounts linked to higher-risk jurisdictions, or any account flagged by the automated monitoring system. Requires additional documentation, source-of-funds evidence and may involve a senior compliance review. |
Transaction Monitoring & Compliance
Withdrawal Playthrough Requirement
As an anti-money-laundering control measure, players are required to wager deposited funds at least once before a withdrawal request may be submitted. This requirement exists to prevent the platform from being used as a pass-through mechanism — a technique through which funds are deposited and immediately withdrawn without meaningful participation in the activity the platform is licensed to offer. The playthrough obligation applies to all deposited balances and is assessed at the point a withdrawal request is initiated.
Post-KYC Withdrawal Review
Every withdrawal request at TeleBet is subject to a combined review process that runs both automated algorithmic checks and a manual compliance assessment before funds are released. The automated layer screens for transaction patterns, velocity anomalies and indicators of structuring behaviour. The manual layer involves a compliance officer reviewing flagged cases and exercising judgement where automated rules alone are insufficient. No withdrawal is released until both layers of this process are satisfied.
Player-to-Player Transfers
Direct transfers of funds between player accounts on the TeleBet platform are prohibited under all circumstances. This restriction is an AML control: peer-to-peer transfers within a gambling platform present a recognised mechanism for layering illicit funds, and the prohibition applies regardless of the stated purpose or relationship between the account holders. Any attempt to circumvent this rule — including through sequences of deposits and withdrawals designed to replicate a transfer — will be treated as a compliance breach and may result in account termination and reporting to the relevant authority.