We seek to offer the highest security to all of our users and customers on www.sleeva.com; therefore, a three-step account verification is carried out to ensure the identity of our customers and to prove that the registered details are correct and that the deposit methods used are not stolen or being used by someone else, thereby creating the general framework for the fight against money laundering.

We also take into account that, depending on nationality and origin, as well as the method of payment and withdrawal, different safety measures must be applied.

www.sleeva.com also puts reasonable measures in place to control and limit money-laundering risk, including dedicating the appropriate means.

www.sleeva.com is committed to high standards of anti-money laundering in line with EU guidelines and requires management and employees to enforce these standards when preventing the use of its services for money laundering purposes.

The AML program of www.sleeva.com is designed to be compliant with EU Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering, EU Regulation 2015/847 on information accompanying transfers of funds, various EU regulations imposing sanctions or restrictive measures against persons and embargoes on certain goods and technology (including dual-use goods), and the Law of 18 September 2017 on the prevention of money laundering and limitation of the use of cash.

Money laundering is understood as the conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from participation in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person involved in the commission of such activity to evade the legal consequences of that person's or company’s actions.

It also includes the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from participation in such an activity.

Money laundering includes the acquisition, possession or use of property, knowing at the time of receipt that such property was derived from criminal activity or from assisting in such an activity.

It also includes participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to above.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

In accordance with AML legislation, www.sleeva.com has appointed the highest level of management for the prevention of money laundering: the full management of Rublix Dev Ltd is in charge.

An Anti-Money Laundering Compliance Officer (AMLCO) is responsible for enforcing the AML policy and procedures within the system.

The AMLCO reports directly to the general management.

Each major change to the www.sleeva.com AML policy is subject to approval by the general management of Rublix Dev Ltd and the AMLCO.

The formal identification of customers at the start of a business relationship is a vital element for both AML regulations and the KYC policy.

This identification relies on the submission of a copy of a passport, ID card or driving licence, shown alongside a handwritten note containing six randomly generated numbers, as well as a separate picture showing the user’s or customer’s face.

The user or customer may blur out every piece of information except date of birth, nationality, gender, first name, second name and the photo, in order to protect their privacy.

All four corners of the ID must be visible in the same image and all details, except those explicitly permitted to be blurred, must be clearly readable; additional details may be requested if necessary.

Employees may carry out additional checks based on the situation where appropriate.

Proof of address is carried out through two different electronic checks that use two independent databases.

If an electronic test fails, the user or customer has the option to provide proof of address manually.

Acceptable proof of address includes a recent utility bill sent to the registered address, issued within the last three months, or an official document from a government authority that proves the user’s state of residence.

To speed up the approval process, the document must be submitted in a clear resolution, with all four corners visible and all text readable.

Examples include electricity bills, water bills, bank statements or any governmental post addressed to the user.

Employees may perform additional checks where necessary, based on the situation.

If a player deposits over 5,000 EUR, www.sleeva.com must understand and verify the player’s source of wealth.

Examples of sources of wealth include ownership of a business, employment income, inheritance, investments or financial support from family.

It is critical that the origin and legitimacy of that wealth is clearly understood; if this is not possible, employees may request additional documents or evidence.

The account will be frozen if the same user deposits this amount in one go or through multiple transactions that together reach this threshold.

An email will be sent to the user to guide them through the necessary steps, and an information notice will also be displayed on the website.

www.sleeva.com may also request a bank wire or credit card payment to further verify the user’s identity and to obtain additional information about their financial situation.

The basic document is accessible via the settings page on www.sleeva.com.

Every user must fill in the following information: first name, second name, nationality, gender and date of birth.

The document will be created and stored with the assistance of automated systems, and employees may carry out additional checks where necessary based on the situation.

To account for different risk levels and wealth situations across regions, www.sleeva.com categorises each country into three risk regions.

Region one (low risk): for countries in this category, the three-step verification is applied as described in this policy.

Region two (medium risk): for countries in this category, the three-step verification is applied at lower deposit, withdrawal and tipping thresholds; step two is triggered at deposits or withdrawals of 1,000 USD, and step three is triggered at deposits or withdrawals of 2,500 USD.

Users from a low-risk region who convert cryptocurrency into any other currency are treated as users from a medium-risk region.

Region three (high risk): regions considered high risk are banned from using the services, and the list of such regions is reviewed and updated regularly to reflect the changing global environment.

An AI system overseen by the AML Compliance Officer monitors for unusual behaviour and immediately flags it to an employee of www.sleeva.com.

Based on a risk-based approach and general experience, human employees review and may repeat or supplement any checks performed by the AI or by other employees.

A data scientist, supported by modern electronic analytic systems, looks for unusual behaviour such as depositing and withdrawing without extended betting sessions, attempts to use different bank accounts for deposits and withdrawals, changes in nationality, currency changes, behavioural or activity changes and indications that an account is not being used by its original owner.

Users must use the same method for withdrawals as they used for deposits, for at least the amount of the initial deposit, in order to prevent money laundering.

As part of its risk-based approach, www.sleeva.com conducts an AML enterprise-wide risk assessment (EWRA) to identify and understand risks specific to the website and its business lines.

The AML risk policy is determined after identifying and documenting the risks inherent in its business lines, such as the services offered, the users to whom services are provided, transactions carried out by these users, the delivery channels used, the geographic locations of operations, customers and transactions, and other qualitative and emerging risks.

The identification of AML risk categories is based on www.sleeva.com's understanding of regulatory requirements, regulatory expectations and industry guidance, as well as additional safety measures addressing the specific risks of operating via the worldwide web.

The EWRA is reassessed annually.

AML Compliance ensures that ongoing transaction monitoring is conducted to detect transactions that are unusual or suspicious compared to the customer’s profile.

This transaction monitoring is conducted on two levels.

First line of control: www.sleeva.com works solely with trusted payment service providers that have effective AML policies in place to prevent the majority of suspicious deposits from reaching www.sleeva.com without proper execution of KYC procedures.

Second line of control: www.sleeva.com makes its network aware that any contact with the customer, player or authorised representative must trigger due diligence on the transactions on the relevant account.

Such contacts include, in particular, requests for the execution of financial transactions on the account and requests related to means of payment or services linked to the account.

The three-step verification process, combined with adjusted risk management, is designed to ensure that all necessary information about customers of www.sleeva.com is available at all times.

All transactions must be overseen by employees supervised by the AML Compliance Officer, who in turn is supervised by the general management.

Specific transactions submitted to the customer support manager, potentially via their Compliance Manager, are also subject to due diligence.

Determining whether one or more transactions are unusual depends largely on a subjective assessment in relation to knowledge of the customer, their financial behaviour and the counterparty to the transaction.

An automated system performs these checks, with employees cross-checking the results for additional security.

Transactions on customer accounts for which it is difficult to understand the lawful nature of the activities and origin of funds are rapidly considered atypical, as they are not directly justifiable.

Any www.sleeva.com staff member must inform the AML division of any atypical transactions they observe that cannot be attributed to a lawful activity or known source of income.

In its internal procedures, www.sleeva.com describes in precise terms, for the attention of its staff members, when it is necessary to submit a report of suspicious activity and how such reporting must be carried out.

Reports of atypical transactions are analysed within the AML team in accordance with a precise methodology fully described in the internal procedures.

Depending on the result of this examination and the information gathered, the AML team decides whether it is necessary to send a report to the Financial Intelligence Unit (FIU), in accordance with the legal obligations provided in the Law of 18 September 2017, and whether it is necessary to terminate the business relationship with the customer.

The AML rules, including minimum KYC standards, are translated into operational guidance and procedures that are available internally for www.sleeva.com staff.

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the execution of the transactions or the end of the business relationship.

These data are stored securely, both online and offline, with appropriate encryption.

Human employees of www.sleeva.com carry out manual controls on a risk-based approach for which they receive specific training.

The training and awareness programme is reflected in its usage, including mandatory AML training in accordance with the latest regulatory developments for all staff involved in financial activities.

Academic AML learning sessions are provided for all new employees.

The content of the training programme is tailored to the nature of the business and the positions held by the trainees.

These sessions are delivered by an AML specialist working in the Rublix Dev Ltd AML team.

Internal audit regularly conducts missions and produces reports on AML activities.

All data provided by any user or customer will be kept secure and will not be sold or disclosed to third parties, except when required by law or where necessary to prevent money laundering.

Data may be shared with the AML authority of the relevant state when legally required.

www.sleeva.com follows all applicable rules and guidelines of the data protection directive.

If you have any questions about our AML and KYC Policy, please contact us by email at support@sleeva.com.

If you have any complaints about our AML and KYC Policy or about the checks carried out on your account or your person, please contact us by email at support@sleeva.com.