AML Policy of pavilion88

Last updated: 13.07.2025

Introduction

This Anti-Money Laundering (AML) Policy applies to pavilion88, operated by BitPulse Solution N.V., having its office at Zuikertuintjeweg Z/N (Zuikertuin Tower), Curaçao, Company registration number: [registration number]. The objective of this AML Policy is to ensure the highest level of security for all users and customers on pavilion88. To achieve this, we implement a three-step account verification process designed to confirm that registration details are accurate and that payment methods are legitimate and not used by unauthorized parties. This framework is established to combat fraud and money laundering. Depending on the customer's residence, origin, payment method, and withdrawal requirements, different safety measures must be taken.

General AML Measures

pavilion88 implements robust measures to control and mitigate money laundering risks, including the allocation of appropriate resources. pavilion88 is committed to maintaining high standards of anti-money laundering (AML) in accordance with the guidelines and regulations of the European Union (EU), Malaysia’s Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act (AMLA), and the Personal Data Protection Act (PDPA). We require our management and employees to enforce these standards to prevent the use of our services for money laundering purposes.

Our AML compliance program is designed to adhere to internationally recognized regulations, including:

  • EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 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.”
  • EU: Various regulations imposing sanctions or restrictive measures against designated persons and embargoes on certain goods and technology, including all dual-use goods.
  • BE: “Law of 18 September 2017 on the prevention of money laundering and limitation of the use of cash.”

Definition of Money Laundering

Money laundering is understood as:

  • The conversion or transfer of property (especially money), knowing it is derived from criminal activity, for the purpose of concealing its illegal origin or helping any person involved evade legal consequences.
  • The concealment or disguise of the true nature, source, location, disposition, movement, or ownership of property, knowing it is derived from criminal activity.
  • The acquisition, possession, or use of property, with knowledge at the time of receipt that it was derived from criminal activity.
  • Participation in, association with, attempts to commit, or the aiding, abetting, facilitating, or counseling of any of the aforementioned actions.

Money laundering is considered as such even when the activities generating the property are carried out in another Member State or a third country.

Organization of AML at pavilion88

In accordance with AML legislation, the highest authority for the prevention of money laundering at pavilion88 is the full management of BitPulse Solution N.V. An AML Compliance Officer (AMLCO) is appointed to enforce the AML policy and procedures within the system and is directly accountable to general management. Any major changes to the pavilion88 AML Policy must be approved by the general management of BitPulse Solution N.V. and the AMLCO.

Verification Procedures

Step One All users and customers must complete step one verification before any funds can be withdrawn. This applies regardless of the payment method, payment amount, withdrawal amount, or nationality. Step one requires the user to provide the following information: first name, last name, date of birth, country of usual residence, gender, and full address.

Step Two Users who deposit over MYR 2,000 or withdraw any amount must complete step two verification. Until verification is complete, any withdrawal, tip, or deposit will be held. In this step, the user must submit a photo of their official ID with a paperclip displaying a randomly generated six-digit number beside it. An electronic check is performed to compare the data from step one with different databases. If the electronic check fails, the user must provide a government-issued certificate of registration or a similar document confirming their current residence.

Step Three Users who deposit over MYR 5,000, withdraw over MYR 5,000, or send another user over MYR 3,000 must complete step three verification. Until verification is complete, any withdrawal, tip, or deposit will be held. For this step, the user is required to provide information regarding their source of wealth.

Customer Identification and Verification (KYC)

The formal identification of customers is a critical element of our AML and KYC policies. This is accomplished by:

  • Providing a copy of a passport, ID card, or driver's license, alongside a handwritten note with six randomly generated numbers.
  • Submitting a second photograph of the customer’s face (a "selfie").

The customer may blur non-essential information for privacy, but the date of birth, nationality, gender, first name, surname, and photograph must remain visible. All four corners of the ID must be visible in the image, and all details must be clearly legible.

Proof of Address

Proof of address is verified through two separate electronic checks using different databases. If electronic verification fails, the user must manually provide a recent utility bill (issued within the last 3 months) or an official government document that validates their residence.

Source of Funds

For users intending to deposit over MYR 5,000, a source of wealth (SOW) verification is required. Acceptable evidence includes proof of business ownership, employment, inheritance, or investments. The origin and legitimacy of the funds must be clearly established. If a user deposits this amount in one or more transactions, their account will be temporarily frozen, and they will be notified to complete SOW verification. pavilion88 may also request bank wire or credit card information to further verify the user's identity.

Verification Form for Step One

The verification form is accessible on the settings page of the pavilion88 website. All users must complete this form with their first name, last name, country of residence, gender, and date of birth.

Risk Management

To address varying risk levels, pavilion88 categorizes nations into three risk regions:

  • Region One (Low Risk): Users from these nations undergo the standard three-step verification process.
  • Region Two (Medium Risk): For these nations, verification is required at lower thresholds. Step two is required after deposits/withdrawals of MYR 1,000 or tips of MYR 500. Step three is required after deposits/withdrawals of MYR 2,500 or tips of MYR 1,000. Users from low-risk regions who exchange cryptocurrency to other currencies are also treated as medium-risk.
  • Region Three (High Risk): Players from high-risk regions are banned from the platform. The list of high-risk regions is updated regularly.

Additional Measures

  • An AI system monitors for unusual activity and reports it to a Compliance Officer.
  • A data scientist, supported by modern analytical systems, observes unusual behavior (e.g., depositing and withdrawing without betting, attempts to use different bank accounts, changes in region or currency).
  • Users must use the same method for withdrawals as for deposits to prevent money laundering.

Enterprise-wide Risk Assessment

As part of our risk-based approach, pavilion88 has conducted an AML "Enterprise-wide Risk Assessment" (EWRA) to identify and assess risks specific to our business. The AML risk policy is determined after identifying inherent risks in our services, users, transactions, delivery channels, and geographic locations. The EWRA is reassessed annually.

Ongoing Transaction Monitoring

AML-Compliance ensures ongoing transaction monitoring to detect unusual or suspicious transactions. This is structured in three tiers:

  • First Line of Control: pavilion88 works exclusively with trusted Payment Service Providers that maintain effective AML policies.
  • Second Line of Control: Any staff interaction with a customer triggers due diligence on the account’s transactions. All transactions are overseen by employees who report to the AML Compliance Officer.
  • Third Line of Control: As a final safeguard, pavilion88 conducts manual checks on all suspicious and high-risk users. If fraud or money laundering is detected, the relevant authorities will be notified.

Reporting of Suspicious Transactions on pavilion88

Internal procedures define when and how staff must report atypical transactions. The AML team analyzes these reports and decides whether to file a report with the local authorities (FIU) and whether to terminate the business relationship with the customer.

Procedures

The AML rules, including minimum KYC standards, are translated into operational guidance, which is available on the pavilion88 website.

Record Keeping

Records of identification data will be retained for at least ten (10) years after the business relationship ends. All transaction data will be kept for at least ten (10) years. This data will be securely encrypted and stored both offline and online.

Auditing

Internal audits are conducted regularly to assess AML activities and ensure compliance.

Data Security

All data provided by any user/customer will be stored securely and will not be sold or disclosed to any third party, except when required by law or for AML purposes. pavilion88 adheres to all guidelines of the PDPA and the Data Protection Directive (Directive 95/46/EC).

Contact Us

If you have any questions regarding our AML and KYC Policy, or if you have any complaints, please contact us by email at: [email protected]