Terms & Conditions

Terms & Conditions
Site rules
Esportsbet faq

1. General

These general terms and conditions defined in this text as "Terms and Conditions" regulate the usage of games and play provided through SITE.com (“SITE”) , which is managed by Eastern Way Tech B.V. (the "Websites").
Eastern Way Tech B.V. (“Eastern Way”) is incorporated in Curacao with registration number 162441a with its registered address at 4 Fransche, Bloemweg, Willemstad, Curaçao, according to the laws of Curacao and by Apollo MKT Ltd, a company registered in Cyprus and having its registered address at Apollo MKT Ltd Strovolou 47, Nicosia, Cyprus.
Eastern Way is regulated under the Sub-License of Gaming Service Provider Master License No 365/JAZ.
We call Eastern Way "SITE ", "Our Company", "We", "Us", "The Company", and we shall refer to the player as "You" or "the player".
The current version of this agreement is valid until a new version is published on the Websites.
These Terms and Conditions also apply to all platforms and devices that enable game play of games provided by SITE . ‘Games’ are defined as Casino and other games available on the Websites.
"Games", "the Games" or "Game" refers to any of the gaming products offered at the Websites.
SITE has the right to revise these Terms and Conditions, and they shall be effective from the time they become available on this website. If the Terms and Conditions change, both you and us shall abide to the changes. If you do not agree to the change(s) of these Terms and Conditions, you will not be unable to log in to your account and if there is a positive balance on your account, you will be able to withdraw it. For details please contact us at cs@esportsbet.io. Chat is available if necessary.
You must fully read and understand these Terms and Conditions before registering. If you do not agree to any part of these Terms and Conditions, you shall not continue the registration or usage of this website.
These Terms and Conditions can be applied when confirming and registering necessary information in the registration process of this website. By registering your account at SITE , you agree to read, understand, and accept these Terms and Conditions. By using this website, you agree to accept the current Terms and Conditions.
You understand and agree to be bound by these Terms and Conditions which will be revised from time to time.
Although these Terms and Conditions are published in multiple languages, they are all based on the same principle and are translated for the purpose of giving information to our players. Here, only those versions written in English shall establish a legal relationship between you and SITE . If there are differences between the English version and the non-English version of these Terms and Conditions, the English version shall prevail.

2. Your obligations

You may only open one account on each of the Websites provided by us, SITE has the right to terminate any duplicate accounts.
You are over 18 years of age or comply with a higher minimum legal age, stipulated in the jurisdiction of your residence under the laws applicable to you. It is your sole responsibility to know the age at which gambling is legal in your country of residence.
You are solely responsible for the account details such as username and password or any other means to access your account at the Websites. In the case there is suspicion that such information should have been compromised you must inform SITE and take proper action to prohibit or prevent any unauthorised access to any part of your account or funds.
You may use the Games on your own behalf and not on the behalf of any other person or company.
You may participate in the Games strictly in your personal non-professional capacity for recreational and entertainment reasons only.
You must be residing in a jurisdiction where gambling is legal. You are not allowed to access the Website and/or register an account from a jurisdiction that prohibits online gambling and/or any other jurisdiction that the Central Government of Curacao deems online gambling illegal.. SITE also prohibits persons located in (including temporary visitors) or residents of Australia, Aruba, Bonaire, Curacao, France and its territories, Netherlands and its territories, Saba, Spain, Statia, St Martin, United Kingdom, the USA and its territories. For the avoidance of doubt, registration from countries that do not feature on the dropdown options available at registration stage, is strictly prohibited.
You cannot transfer, sell, or pledge your balance or your Account to another person. This prohibition includes the transfer of any assets of value of any kind, including but not limited to ownership of accounts, winnings, deposits, bets, rights and/or claims in connection with these assets, legal, commercial or otherwise. The prohibition on said transfers also includes however is not limited to the encumbrance, pledging, assigning, usufruct, trading, brokering, hypothecation and/or gifting in cooperation with a fiduciary or any other third party, company, natural or legal individual, foundation and/or association in any way shape or form.
You agree that all information that you give us, such as but not limited to, address and email, during the term of validity of this agreement is complete, true, correct, and that you will immediately notify SITE of changes of such information or change such details by yourself on the Websites.
You may only participate in any Game if you have enough funds on your account for such participation.
You may not use funds that are tainted or associated with any illegality or originate from any illegal activity or source.
You are solely responsible for reporting and accounting for any taxes or other fees applicable to you under the relevant laws for any winnings that you receive from SITE.
In relation to deposits and withdrawals of funds into and from your Account, you shall only use such credit cards and other financial instruments that are valid and lawfully belong to you.
You understand that by playing Games provided by us, you take the risk of losing money deposited into your account.
You shall not be involved in any fraudulent, collusive, fixing or other unlawful activity in relation to your or third parties’ participation in any of the Games and shall not use any software-assisted methods or techniques or hardware devices for your participation in any of the Games. We hereby reserve the right to invalidate any betting in the event of such behaviour.
You may only use the software for your own personal, recreational use in accordance with rules and terms and conditions we have established and in accordance with all applicable laws, rules and regulations.
You shall be courteous to other players using the Websites as well as to support personnel employed by SITE and avoid rude or obscene comments.
Should you, any family member or close associate be a Politically Exposed Person (PEP) you are not permitted to open or continue to use your account and must inform us immediately

3. Your account

For you to be able to deposit money and place bets, you must first register personally with us and open an account ("Account").
You are permitted to open only one account and register it personally. We reserve the right to close any multiple Accounts opened in the same name or in any way referable to the same person.
You must enter all mandatory information requested into your registration form all of which must be true and correct. It is your sole responsibility to ensure that the information you provide is true, complete and correct. You are hereby notified that we carry out verification procedures and that your Account may be blocked for access or closed if you are found to supply false or misleading information. You are required to update and keep up to date the mandatory information provided in the registration form in the event such information changes.
If you notice that you have more than one registered Account, you must notify us immediately. Failure to do so may lead to your Account being blocked for access.
As part of the registration process, you will have to choose your username and password for your login into the Website. It is your sole and exclusive responsibility to ensure that your login details are kept securely. You must not disclose your login details to anyone. We are not responsible for any abuse or misuse of your Account by third parties due to your disclosure, whether intentional or accidental, whether active or passive, of your login details to any third party.
You are not allowed to transfer funds from your Account to other players or to receive money from other players into your Account, or to transfer, sell and/or acquire, user accounts.
SITE reserves the right to refuse or close an Account at its sole discretion, but any contractual obligations already made by SITE shall, without prejudice to any rights available at law to SITE , be honoured accordingly.
SITE prohibits player collusion and does not allow any kind of robots and programmed devices to participate in game play.
If you wish to close your account, you may do so at any time, by contacting customer support in written form. The effective closure of the Account will correspond to the termination of the Terms and Conditions. In case the reason behind the closure of the Account is related to concerns about possible gambling addiction the player shall indicate it.
In the case a player account is closed, related information about the account is saved for a minimum of six (6) years from the time the account is closed. Related information includes player name, address, phone, email and account transaction details.

4. Deposits into your account

You may be charged assigned fees for processing deposits. If such fees occur, they’ll be visible during the deposit process. Deposits can be made with E-wallet, Credit Card, Cash, and Crypto.
The Company shall assign minimum deposit amounts and maximum deposit amounts as specified on the website.
Depositing funds into your account is made by using any of the methods specified on the Websites, as may be amended from time to time. Details in respect to the timings for withdrawals in respect to the method utilized are available on the relevant pages of the Websites, as may be amended from time to time.
Deposited amounts are available on the Account within a reasonable amount of time after the confirmation of the deposit on all available deposit options unless extra verification procedures are needed as stated in.
The Company reserves the right to use additional procedures and means to verify the identity of the customer in order to validate the payment to your account (Know Your Client).
If SITE mistakenly credits Your Account with winnings that do not belong to you, whether due to a technical or human error or otherwise, the amount will remain property of SITE and the amount will be transferred from Your Account. If prior to SITE becoming aware of the error You have withdrawn funds that do not belong to You, without prejudice to other remedies and actions that may be available at law, the mistakenly paid amount will constitute a debt owed by You to SITE . In the event of an incorrect crediting, you are obliged to notify SITE immediately by email.
You shall only use valid credit cards or other financial means legally belonging to you.
It is prohibited by law to deposit funds obtained from fraudulent means.
SITE will perform security checks on random occasions and at our sole discretion. You accept that we may demand additional information in the event of a security check and that we may suspend and/or terminate your Account, registration or withhold your payment until we receive the appropriate information that we have requested.
SITE will only accept colour copies of identification documents.
Deposits made to your SITE account should commensurate with game play. Therefore, if in Eastern Way’s discretion, there is suspicion of abuse (for instance, where a deposited amount has not been used for an appropriate level of game play and the user then makes a withdrawal request in relation to that deposited amount or where Eastern Way suspects that you are abusing exchange rate fluctuations), we reserve the right in its absolute discretion to cancel the respective deposit(s) in part or in full, to retract any costs that may have resulted in conjunction therewith and to close the gaming account indefinitely. Eastern Way further reserves the right to request and obtain satisfactory proof of deposit and additional copies of personal identification in such instances prior to processing any withdrawal request, the processing of such request to be entirely at Eastern Way’s discretion.
SITE reserves the right to terminate an account, ban a player and retain all funds where that player is reasonably suspected of engaging in fraudulent activities which include, but are not limited to, use of stolen or falsified credit cards or account numbers, forgery, and submission of data or documents which are forged, stolen or otherwise misappropriated.

5. Withdrawals

Available withdrawal options are to be clearly stated on the Websites and may differ depending on the market from which the player originates.
Withdrawals will be made to your bank account or other withdrawal methods available to choose from ‘the Website’ and/or chosen by SITE . SITE shall credit you back using the same method as you have previously deposited with, if the method allows this to be made.
Funds marked as "Bonus money" or stuck in an aborted game will not be possible to withdraw.
All transactions shall be checked in order to prevent money laundering. If the player becomes aware of any suspicious activity relating to any of the Games of the Website, the player must report this to the Company immediately. SITE may suspend, block or close an Account and withhold funds if requested to do so in compliance with the Prevention of Money Laundering Regulations.
The time for the withdrawal to be finalized may vary due to circumstances but a withdrawal attempt should be approved or denied within maximum three (3) days. The player shall be informed about reasons for any delay if the time for the money to arrive at the player's account exceeds ten (10) days.
Be advised that our products are consumed instantly during gameplay. Thus, we cannot provide refunds, returns of goods, or cancellation of your service when playing. If you play a game with real money, the money will be drawn from your player account instantly.
Customers shall not treat SITE as a banking institution nor expect any interest.
We may impose a fee on the processing of the withdrawal, which will be stated when you request a withdrawal.
SITE reserves the right to charge a fee should you request a withdrawal without turning over an amount that is equal or more than the amount deposited.

6. Bonuses & Rewards Scheme Conditions

The bonus and rewards conditions defined are valid until a new version is made available on the websites.
SITE reserves the right to withhold and remove any bonus money awarded to you if it has not been used within 90 days from the date awarded. Individual campaigns may have a shorter expiration time and are, if so, stated to the player related to the time when receiving the campaign offer.
If you are eligible for a bonus, free spins, or a free bet, wagering requirements will apply before you are eligible to make any cash-outs of the winnings by bets using real money. If you would like to request a withdrawal before the wagering requirements are fulfilled, SITE will deduct the whole bonus amount as well as any winnings made from bonus money before approving any withdrawal. SITE has the right to choose which games and how much a game contributes to the wagering requirements.
Winnings from Free Spins (rounds) have a wagering requirement of thirty-five (35) times the winning sum if nothing else is stated alongside the Free Spin campaign to contradict this. Only bets with real money count towards the wagering requirements.
If no specific information is given regarding wagering requirements when receiving a bonus, the wagering requirement is set to thirty-five (35) times the sum of the received bonus amount.
Any player found to be abusing bonuses/promotions on ANY games with a progression mechanic, opposite betting or any other bonus seeking mechanic are liable to have any winnings confiscated and may have their accounts closed.
Local wagering requirements may be applied and if so, is to be stated together with the offer.
Bonuses/Free Spins/Free Bets at SITE can only be received once per household, IP address and/or credit card number. Risk-free bets on any games do not qualify for SITE ’s wagering requirements. We reserve the right to close your account and confiscate any existing funds if evidence of bonus abuse/fraud is found.
Individually, bonus campaigns can have specific details and terms, in this case such information shall be made available to the user.
Game rounds and game features triggered with bonus funds must be played through whilst a bonus is active. Players are not permitted to delay completion of game rounds or game features until after the wagering requirement for that bonus has been met, and/or they have deposited new funds. If such activity is identified, the player agrees that their bonus and/or any associated winnings may be voided at the discretion of Casino Management.
Upon depositing to receive bonus funds, Free Spins, or Free Bets, you must wager your deposit at least once. Failure to do this could result in no further bonuses being awarded or even account closure at the discretion of Casino Management.
Esportsbet reserves the right to close your account and forfeit your winnings generated on the account, should we suspect bonus abuse has occurred. Abuse includes but is not limited to, cash stashing, bonus stashing, or else by depositing only to receive free spins and withdrawing your real money before wagering the amount deposited at least once.
During gameplay, real money is used first. Real money bets give real money winnings and mixed bets or bonus money only bets give bonus money winnings.
The free spins (bonus rounds) or free bets are valid for 30 days from the date you make a deposit.
The wagering requirement may be deemed void if your account balance is, or reaches 0.00EUR/USD.
Some games are excluded from bonus play and the Player is not allowed to wager bonus funds on any of the excluded games. Games that have been excluded from bonus wagering have been technically blocked and wagering with bonus funds in these games won't be calculated as valid wagering.

Special Games that is excluded from Bonus play:

Roulette

Black Jack

7. Paused and Inactive accounts

A paused account is an account that has not been accessed for 12 months, that has a real money balance.
An inactive account is an account that has not been accessed for 30 months, that has a real money balance.

8. Exceptional Circumstances & Aborted Games

Unexpected technical problems or circumstances outside the control of SITE such as technical problems with third party providers, allow SITE to cancel bets and give refunds to players.
SITE has the right to limit, cancel and refuse bets in the case they are too large or if we see that the betting pattern of the player takes place in such a way that the system is being abused.
If a refund is decided upon, the amount of the refund shall be returned to the player’s account, the player shall be informed, and the procedure finalized within 48 hours after the decision has been made.
In the case that a game is "stuck" in a state where it is not being finished, for example a connection loss while playing an active blackjack hand, SITE has the right to "clean up" such bets on a regular basis and refund the bet/wager to the player’s account. This is performed on a monthly basis. If the game has been aborted or miscarried on the server, the player should be refunded.
If a bonus campaign has in any way been misconfigured, SITE has the right to alter player's balances and account details to correct the mistake.
If a game contains a bug or misconfiguration that causes incorrect behaviour or pay out, SITE has the right to remove the game and alter player's balances and account details to correct the mistake.
The Company is not liable for any downtime, server disruptions, lagging, or any technical or political disturbance to the game play. Refunds may be given solely at the discretion of the management.
The Company shall accept no liability for any damages or losses which are deemed or alleged to, have arisen out of, or in connection with website or its content; including without limitation, delays or interruptions in operation or transmission, loss or corruption of data, communication or lines failure, any person’s misuse of the site or its content or any errors or omissions in content.
SITE may remove any game from the Websites at any time we see fit.
If a player leaves a bet open for more than the configured threshold (90 days), the sweeper job in Microgaming’s slots cancels the bet and returns the wager for that incomplete game round. The wager will be configured to return the money back to the player.

9. Complaints

You may contact our customer service according to the instructions located on the Websites to give us any complaints regarding our services. Should you want to send us a complaint through email you may do so addressing cs@esportsbet.io.
Complaints are handled in the support department and escalated in the organization of SITE in the case that support personnel do not solve the case immediately. The player shall be informed about the state of the complaint to a reasonable level.
If, for some reason, you are not satisfied with the resolution of your complaint by Eastern Way Tech B.V., you may bring unresolved disputes to Gaming Services Provider N.V via complaints@gaming-curacao.com.

10. Limitation of Liability

You enter the Website and participate in the Games at your own risk. The Websites and the Games are provided without any warranty whatsoever, whether express or implied.
Without prejudice to the generality of the preceding provision, we, our directors, employees, partners, service providers.

do not warrant that the software, Games and the Websites are fit for their purpose;
do not warrant that the software, Games and the Websites are free from errors;
do not warrant that the software, Games and the Websites will be accessible without interruptions;
shall not be liable for any loss, costs, expenses or damages, whether direct, indirect, special, consequential, incidental or otherwise, arising in relation to your use of the Websites or your participation in the Games.

You understand and acknowledge that, if there is a malfunction in a Game or its interoperability, any bets made during such malfunctioning shall be void. Funds obtained from a malfunctioning Game shall be considered void, as well as any subsequent game rounds with said funds, regardless of what Games are played using such funds.
You hereby agree to fully indemnify and hold harmless us, our directors, employees, partners, and service providers for any cost, expense, loss, damages, claims and liabilities howsoever caused that may arise in relation to your use of the Website or participation in the Games.

11. Breaches, Penalties and Termination

If you breach any provision of these Terms and Conditions or we have a reasonable ground to suspect that you have breached them, we reserve the right to not open, to suspend, or to close your Account, or withhold payment of your winnings and apply such funds on account of any damages due by you.
If SITE suspects that you are engaged in illegal and/or fraudulent activities when using any of the Websites; or in breach of this Agreement; or that you are having problems with creditors or otherwise detrimental to our business, we may freeze or terminate your account or cancel any stakes at our absolute discretion.
You acknowledge that SITE shall be the final decision-maker of whether you have violated SITE 's rules, terms or conditions in a manner that results in suspension or permanent barring from participation in our site(s).

12. Severability

If any provision of these Terms and Conditions is held to be illegal or unenforceable, such provision shall be severed from these Terms and Conditions and all other provisions shall remain in force unaffected by such severance.

13. Assignment

We reserve the right to assign or otherwise lawfully transfer this agreement. You shall not assign or otherwise transfer this agreement.

14. Entire Agreement

These Terms and Conditions jointly with our Privacy Policy constitute the entire agreement between you and us with respect to the Websites and, save in the case of fraud, supersede all prior or contemporaneous communications and proposals, whether electronic, oral or written, between you and us with respect to the Websites.
Applicable law and jurisdiction
These Terms and Conditions shall be governed by the laws of Curacao.
The parties agree that any dispute, controversy or claim arising out of or in connection with these Terms and Conditions, or the breach, termination or invalidity thereof, shall be submitted to the exclusive jurisdiction of the Courts of Curacao.

15. Anti-Money Laundering, Anti-Terrorist Financing statement

Company Business Model

Eastern Way Tech B.V (“Esportsbet” or the “ Company ”) is a company incorporated under Curaçao Law that was established in 2021 and operates the online casino https://esportsbet.io under the licence 365/JAZ issued by Gaming Service Provider. Esportsbet presently supports users in more than 230 countries globally.

As part of its global operations, Esportsbet has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

Company Policy Statement

Esportsbet is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (“ AML/CFT ”) applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, Esportsbet expressly prohibits and rejects the use of Esportsbet products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering (“ AML ”) laws, regulations and norms. Esportsbet continues to monitor norm setting parameters promulgated by the Financial Action Task Force (“ FATF ”) and certain gaming trade groups in addition to the Curaçao Gaming Control Board and will take necessary action as it deems appropriate to reflect changes in law.

Esportsbet’s intention is to follow global best practices in guarding against Esportsbet products being used to facilitate such activities. Those best practices include:

Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;

Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;

Provision of related education and training to relevant personnel; and

Independent reviews, monitoring and maintenance of the policy, procedures and controls.

Definitions

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appears legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.

Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions.For example, they are used:

To encourage a change in behaviour for a target country or regime;

To apply pressure on a target country to comply with set objectives;

As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or

To prevent and suppress the financing of terrorists or terrorist acts.

Governance and Oversight

Esportsbet has appointed a Chief Compliance Officer (“ CCO ”) that is responsible for coordinating the implementation of the AML Policy and policy program. The Chief Compliance Officer’s duties also include developing AML initiatives, work with other Esportsbet holders to revise the AML policy, assessing new regulatory requirements and investigating potentially suspicious or unusual activity. Esportsbet also provides AML training to all of its employees on a regular basis.

Know Your Customer and Transaction Monitoring

Esportsbet will apply appropriate user due diligence and ongoing monitoring measures required by law. Esportsbet will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity. Esportsbet uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.

16. Know Your Customer

Customer Due Diligence

Esportsbet has adopted a risk based CDD to enable Esportsbet to understand the nature and purpose of the user relationship to the Esportsbet platform in order to develop a customer risk profile. In order to do so, Esportsbet collects certain documentary and non-documentary information at account-opening commensurate with the nature of the type account and services that Esportsbet offers. Esportsbet maintains different CDD for different accounts and services.

For instance, the CDD requires users to go through Esportsbet’s customer identification program (“ CIP ”). The CIP consists of procedures for:

Collecting baseline (e.g., wallet address, email address, first name and surname, d.o.b) information at account creation through Esportsbet’s user onboarding portal;

Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user’s account;

Maintaining records of the information used to identify the user; and

Determining if a user appears on any list of known or suspected terrorists or terrorist organisations provided to the financial institutions based on the above information.

The above steps are operationalised using the following measures:

Identity and Age Verification . A third-party service provider will support EsportsBet,s ability to determine the legitimacy of the identification information other KYC materials or information provided and will confirm that the user is permissible. The service provider also will confirm that the user does not appear to be located in a comprehensively-sanctioned or otherwise prohibited jurisdiction and will search global sanctions lists to confirm that the user does not appear thereon using onboarding information such as wallet addresses.

Customer Information . Esportsbet will collect details on each user to form a reasonable belief that Esportsbet knows the identity of its users commensurate with the user’s risk profile. For instance, Esportsbet may collect such details as the wallet address, name, address, country, date of birth, or postal code (collectively, “ KYC Information ”). Esportsbet will collect any of the above KYC Information prior to issuing an Esportsbet funding address (e.g., QR code) to users. Esportsbet does not presently allow users who are non-natural persons. Esportsbet may, at its own description, rely on the performance by another institution of some or all of the elements of our CIP.

Geo-blocking for Prohibited Jurisdictions . Esportsbet will require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.

Contractual Prohibitions on Users Onboarding from Prohibited Jurisdictions . Users are notified at onboarding that Esportsbet does not offer services in restricted jurisdictions. Esportsbet’s policy on restricting user activity stems from a combination of its risk, fraud prevention, and AML standards, as well as any assessments associated with the permissibility of its services in certain jurisdictions.

ESPORTSBET WILL ALSO REQUEST SUPPORTING KYC DOCUMENTATION FROM USERS WHEN THE USER REACHES USDT$3,000 OF DEPOSITS OR WITHDRAWALS.

Enhanced Due Diligence and Ongoing Monitoring

Esportsbet performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, Esportsbet has implemented a set of red flag indicators that help it determine such behaviours and require further action from Esportsbet in assessing the customer information.

Whenever one of those red flags is triggered, the user account will be suspended and Esportsbet will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of:

Full legal name;

Country of citizenship;

Permanent Address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office or other physical location);

Identification number (either a taxpayer identification number, or, if unavailable, a passport number and country of issuance, alien identification card number or number and country of issuance of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);

Identification Document; and

Source of Funds and Source of Wealth.

Esportsbet may use third party service providers to verify any of the above information as determined to establish a reasonable basis to know the true identity of the user where the user’s activity warrants such action.

Acceptance Policy

Esportsbet will not accept and will block the users that:

Do not provide the identification information requested by Esportsbet;

Provide fake identification documents;

Try to use different means to deceive about their location;

Are from restricted or prohibited jurisdictions; or

Are subjected to United States, European Union, or other global sanctions or watch lists;

Are gambling addicted or have mental health issues;

Its source of funds are originated or exchanges in restricted jurisdictions;

Esportsbet reserves the right to block and suspend player for any other reasons at its own description

17. Transactions Monitoring

Esportsbet is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose Esportsbet established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring.
Esportsbet will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review user history and patterns of activity to detect and report any unusual activity as required and to develop and implement any additional controls or limits in its platform.
Esportsbet implemented procedures addressing the following two key components of unusual or suspicious activity management:

identification of unusual activity through methods of identification may include employee and customer identification, law enforcement inquiries, other referrals, or transaction and surveillance monitoring system reports; and

alert management that focuses on processes used to investigate, evaluate and document identified unusual or potentially suspicious activity.

Esportsbet will use the following processes to achieve both goals:

Transaction Monitoring for Sanctioned or Prohibited Jurisdictions . Esportsbet may in its reasonable discretion impose certain due diligence requests at user balance withdrawal. Esportsbet presently conducts a mixture of manual and automated transaction monitoring processes to identify “red flag” behaviour. Where such red flag behaviour is identified, Esportsbet may refuse to process any withdrawal attempts or collect additional information from the recipient. Esportsbet will further endeavour to limit any attempted user account funding from prohibited jurisdictions (which are identified in the Esportsbet user facing disclosures and updated from time to time internally) where the associated wallet address indicates that the user or the user’s funds are located in such a prohibited jurisdiction. For instance, Esportsbet may prohibit a user from funding their Esportsbet account using a known U.S. based exchange wallet as such assets indicate that the user is a U.S. person. Users will have the ability to rebut any suspension with additional information as part of Esportsbet’s ongoing transaction monitoring and user due diligence standards.

Withdrawal Threshold KYC. Additionally, and independently, every account, wherever or with whomever associated, will be suspended until adequate KYC diligence occurs once that account reaches a withdrawal threshold dependent on the accounts risk characterisation over the life of the account.

Other Ongoing Monitoring Controls

Additionally to the above mentioned controlling procedures, Esportsbet has also implemented the following procedures to complement its know your customer and ongoing monitoring procedures:

Ban Evasion Detection . In addition, Esportsbet will utilise third-party service provider software designed to detect the use by one user of multiple accounts. This software relies on detection of links between the same devices used to access multiple accounts. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform. Esportsbet accounts are funded by users using local (non-custodial) or hosted (custodial) wallets. In addition to a Chainalysis screening, Esportsbet monitors user activity within the Esportsbet platform and any withdrawals must meet Esportsbet’s and its third-party service provider’s verification processes. Esportsbet further prohibits peer-to-peer account transfers within the Esportsbet platform infrastructure. Any attempts to circumvent this restriction will be treated as a red flag.

Time Zone Monitoring. Esportsbet has implemented time zone controls that detects the users device information and crosses it with restricted jurisdiction to understand if they are trying to use geo location software to hide the jurisdictions where they are connecting from.

Products and Services Review. Esportsbet will establish additional procedures to avoid facilitating user attempts to exploit the Esportsbet platform. Esportsbet has a robust set of user-facing terms that users attest to in order to utilise the Esportsbet platform. Esportsbet will establish certain additional safeguards to mitigate against the risk of such misuse. For instance, Esportsbet may establish policies or procedures for limiting which user assets can be onboarded to the Esportsbet platform. Esportsbet lists the assets that are available for use on the Esportsbet platform. Esportsbet does not allow the use of anonymity enhancing technologies such as mixers, tumblers, or certain coins and tokens. Where Esportsbet becomes aware that an anonymity enhancing technology is being used on the Esportsbet platform, Esportsbet will disallow such use.

Vendor Management. Esportsbet works with reputable third-party service providers as part of its compliance infrastructure. Esportsbet will periodically assess the strength of its key third party service providers to determine if additional services are needed, the third-party service provider is not performing consistent with its contractual obligations, or if other remedial action is necessary for Esportsbet to comply with this policy. Esportsbet may request information from any third-party service provider as part of its vendor review process.

Compliance Innovation . In addition to vendor management, Esportsbet will continuously monitor any non documentary compliance mechanisms to determine their viability for the Esportsbet program. Esportsbet may run test or trial programs on a limited basis with such compliance vendors to determine the effectiveness of such programs. Blockchain native compliance tools include fraud prevention services, on-chain KYC providers, and other tools designed to reflect the technological features associated with blockchain platforms.

Education and Training

Esportsbet, with the assistance of its legal counsel and under the oversight of its CCO, may provide employees AML, anti-terrorist financing and trade sanctions compliance training on a periodic basis, as deemed appropriate.

Reporting

Esportsbet is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity to the regulator.