| AllWin UA AML — key provisions | |
|---|---|
| Legal compliance | Compliance with the Law of Ukraine “On Prevention and Counteraction to Legalisation of Proceeds” No. 361-IX and international FATF standards |
| Risk level | Medium — with regular review and updating of the risk assessment |
| KYC procedures | Mandatory identification and verification of all customers |
| Transaction monitoring | Round-the-clock automated monitoring of all financial transactions |
| Transaction limits | Deposit and withdrawal limits set according to the risk level |
General principles of the All Win UA AML policy
AllWin UA adheres to strict standards in preventing the legalisation of criminally obtained proceeds and the financing of terrorism. The AML policy covers every aspect of the AllwinUA platform and applies to all customers without exception. Compliance with the requirements of the Law of Ukraine No. 361-IX and FATF recommendations is ensured through comprehensive procedures for monitoring and controlling financial transactions.
2.1 Customer identification and verification
AllWin UA carries out a mandatory KYC (Know Your Customer) procedure for all registered customers. The process includes multi-level identity verification and validation of the personal data provided, through automated systems and manual document checks by the security team.
KYC stages at AllWin UA
- Basic identification — when registering an account on the Allwin UA platform (full name, date of birth, email, phone number)
- Extended verification — to raise transaction limits above UAH 50,000 per month (uploading a passport, a selfie with the document)
- Periodic review — updating customer information every 12 months for active accounts
- Enhanced due diligence — for higher-risk customers, including checks on sources of income and financial standing
2.2 Customer risk assessment
AllWin UA classifies customers into three risk categories: low, medium and high. The assessment criteria include the user’s geographic location, the amounts and frequency of transactions, sources of funds, gaming activity and the history of financial transactions on the AllwinUA platform.
| Risk level | Criteria | Monitoring measures |
|---|---|---|
| Low | Residents of Ukraine, transactions up to UAH 10,000 per month, transparent gaming history | Standard automated monitoring, periodic checks once a quarter |
| Medium | Non-resident customers, transactions of UAH 10,000-50,000 per month, average gaming activity | Enhanced monitoring with monthly review, additional document requests |
| High | Customers from FATF high-risk countries, transactions above UAH 50,000, complex transaction patterns | Intensive real-time monitoring, continuous oversight by an AML specialist |
2.3 Monitoring of transactions and operations
AllWin UA carries out round-the-clock automated monitoring of all financial transactions through the ComplyAdvantage AML system. Machine learning technology detects suspicious user behaviour patterns and atypical transactions in real time, generating automatic alerts for the security team.
Suspicious behaviour patterns on the AllWin UA platform
- A sudden 3x or greater increase in betting volumes with no visible reason or winnings
- Multiple small deposits (from UAH 100 to UAH 500) within 1-2 hours — a sign of structuring
- Rapid withdrawal of funds after a deposit without significant gaming activity (less than 10% of turnover)
- Simultaneous use of 3 or more different payment methods for deposits and withdrawals
- Frequent changes of personal data (email, phone, address) or payment instruments within a month
- Unusual low-risk betting patterns (bets on opposing outcomes)
2.4 Responsibilities of AllWin UA staff
All AllWin UA employees undergo mandatory anti-money-laundering training when they are hired, plus annual refresher courses. Responsibility for compliance with the AML policy lies with the AllwinUA chief executive and the appointed Chief Compliance Officer (CCO).
Key responsibilities of All win UA staff
- Carrying out customer identification and verification in line with the approved KYC procedures
- Continuous monitoring of transactions for suspicious activity through internal systems
- Immediate reporting of suspicious transactions to the AML specialist within 2 hours of detection
- Strict confidentiality regarding the checks being carried out
- Regularly updating knowledge of Ukrainian AML legislation and international standards
- Participation in quarterly training sessions and seminars on new money laundering methods
2.5 Reporting of suspicious transactions
AllWin UA has formalised internal procedures for reporting suspicious financial transactions. All cases of suspicious activity are documented in a secure database and passed on to the State Financial Monitoring Service of Ukraine in accordance with applicable law.
| Report type | Contents | Filing deadline |
|---|---|---|
| Internal report | Recording of suspicious transactions for internal analysis by the AllWin UA AML department | Immediately after detection (within 2 hours) |
| SFMS report | Information on transactions above UAH 400,000 that are subject to mandatory financial monitoring | No later than 3 business days after the transaction |
| Extraordinary report | Information on transactions linked to terrorist financing or sanctioned persons | Immediately (within 24 hours) |
2.6 Storage of documents and information
AllWin UA stores all documents and information related to anti-money-laundering procedures in encrypted digital archives for the periods established by Ukrainian law. Access to confidential information is granted only to authorised staff of the AllwinUA AML department using two-factor authentication.
Document retention periods at AllWin UA
- Customer identification documents (passports, selfies, proof of address) — 5 years after the account is closed
- Records of financial transactions (deposits, withdrawals, bets) — 5 years after the transaction
- Internal reports on suspicious transactions and investigation results — 5 years
- Staff training materials on AML/CFT procedures — 3 years
- Correspondence with regulatory authorities and responses to enquiries — 7 years
2.7 Technology solutions for AML
All Win UA uses modern AI-based technology solutions for effective monitoring and multi-level analysis of transactions. The system includes machine learning algorithms to detect complex and atypical behaviour patterns typical of money laundering schemes.
Key features of the Allwin UA AML system
- Automatic real-time detection of suspicious transactions with 97.3% accuracy
- Behavioural analysis of user activity using deep learning algorithms
- Integration with international sanctions list databases (OFAC, EU, UN, FATF) with daily updates
- Generation of automated reports for the State Financial Monitoring Service in the prescribed formats
- The option of in-depth manual investigation of suspicious cases by AML specialists
- A customer risk scoring model based on 50+ behavioural parameters
2.8 International cooperation
AllWin actively cooperates with international organisations and regulators in the fight against money laundering and terrorist financing. The AllwinUA platform follows FATF recommendations and Egmont Group standards and takes part in international initiatives for exchanging information about financial crime.
Areas of AllWin UA international cooperation
- Exchange of information with international financial institutions under MOU agreements
- Participation in international training programmes and conferences on AML/CFT
- Cooperation with international law enforcement agencies (Interpol, Europol)
- Compliance with international sanctions lists and restrictions on dealing with high-risk jurisdictions
- Participation in global financial crime databases
2.9 Liability for breaching the AML policy
AllWin UA bears full legal responsibility for complying with anti-money-laundering legislation. A breach of the AML policy may lead to serious legal consequences for the AllwinUA platform, its management and its staff under Articles 209 and 306 of the Criminal Code of Ukraine.
Possible consequences of breaches for AllWin UA
- Administrative fines from UAH 100,000 to UAH 500,000 under the Code of Ukraine on Administrative Offences
- Criminal liability for officials and employees (up to 12 years of imprisonment)
- Suspension or full loss of the Curaçao eGaming licence to operate
- Irreparable reputational damage and loss of customer trust
- Restrictions on business activity and blocking of bank accounts
- Being added to the blacklists of international payment systems
2.10 Review and updating of the AML policy
The AllWin UA AML policy is regularly reviewed and updated in line with changes in Ukrainian legislation, international FATF standards and Curaçao eGaming recommendations. A comprehensive review is carried out at least once a year, or more often if regulatory requirements change significantly.
The Allwin UA AML policy update process
- Continuous monitoring of changes in Ukrainian legislation and international FATF/APG standards
- Quarterly analysis of the effectiveness of current AML procedures through KPI metrics
- Consultations with external experts and auditors in the field of financial monitoring
- Mandatory training of all employees on the updated procedures within 14 days
- Informing customers about changes to the AML policy via email newsletters and notices on the site
- An internal audit of compliance with the updated procedures 30 days after they are introduced
AML FAQ at AllWin UA
Verification is a mandatory requirement of the Law of Ukraine No. 361-IX and international AML/KYC standards. The procedure helps prevent fraud, money laundering and terrorist financing and keeps all AllWin UA customers safe. Without completing KYC, withdrawals above UAH 10,000 are not possible.
AllWin UA accepts a Ukrainian citizen’s passport (internal or biometric), an international passport, a new-format driving licence or a plastic ID card. To confirm your address of residence — utility bills no more than 3 months old, bank statements or official letters from government bodies.
Standard document verification takes from 4 to 24 hours from the moment all the required files are uploaded. If additional checks or extra documents are needed, the period may be extended to 3 business days. Express verification is available for VIP customers (up to 2 hours).
Transactions may be temporarily suspended for additional review under the AllWin UA AML policy. The reasons: exceeding the set limits, suspicious behaviour patterns, inconsistent sources of funds, or the need for additional identity verification. Once the review is complete (24-72 hours), the transaction will be completed or cancelled with a detailed explanation of the reasons.
To appeal a decision to block an account, contact AllWin UA support by email at [email protected] or through the form on the site. You need to provide detailed explanations and documentary proof that your sources of funds are legitimate. Within 5 business days an additional review will be carried out with the involvement of the AML department and the legal team, ending in a final decision.
Unverified accounts on the AllwinUA platform are limited to deposits of up to UAH 10,000 per month and withdrawals of up to UAH 5,000. After completing full KYC verification the limits increase: deposits of up to UAH 500,000 per month and withdrawals of up to UAH 500,000 with 0% commission. VIP customers receive individually raised limits.
Conclusion
The AllWin UA AML policy is aimed at creating the safest and most transparent environment possible for all customers and at effectively preventing financial crime. The AllwinUA platform takes its anti-money-laundering obligations seriously and strictly follows all the requirements of Ukrainian law, FATF recommendations and the standards of its licensor, Curaçao eGaming.
AllWin UA remains open to constructive cooperation with customers, regulators and international partners on financial security, transparency of transactions and countering global financial threats. We continuously improve our AML procedures to meet the highest global standards.