Anti-Money Laundering Policy at SapphireBet

We apply strict measures to detect and block fraudulent schemes in Bangladesh. Money laundering is the process of legitimizing the proceeds of crime. The main objective is to hide the real source of income and present it as legitimate. This process is used by criminals to hide the profits from corruption, drug trafficking, fraud, cybercrime, and other illegal activities. Money Laundering consists of three structured stages:

• Placement. Money obtained illegally is introduced into the financial system, most often through deposits, purchases, or casino bets. For example, a user makes the replenishment of a large amount of cryptocurrency and immediately requests a refund, attempting to launder the funds;
• Layering. At this stage, multiple money transactions are created, often between fake accounts or using anonymous payment systems. This is intended to make it more difficult to trace the source of the funds. May include crypto transfers between dozens of wallets, currency exchanges, bets, and withdrawals from different accounts;
• Integration. Cleared funds are put back into the economy as supposedly “legitimate”. For example, the money can be spent on property, investments, or used to fund a new business.

Terrorist financing is similar in mechanics to Money Laundering but with different objectives. In this case, the funds can come from both legal and illegal sources. For example, terrorist organizations in Bangladesh receive money from charitable foundations, arms, or human trafficking, and then use it to prepare attacks or recruit. The main problem is that the funds may be legal in source but illegal in purpose.

Our website, under the direction of DOLCETECH LIMITED, registered in Saint Lucia with number 2025-00158, adheres to a strict anti-money laundering and anti-terrorist financing policy. SapphireBet is fully compliant with international requirements in this area, has an official license with a number ALSI-202505019-FI1 under processing, and applies a Risk-Based Approach aimed at identifying suspicious Bengali clients, their transactions. We also regularly train our employees and implement technology to effectively identify all unusual transactions. The safety of Bangladeshi players is our priority.

Customer Due Diligence is a mandatory process of verifying the identity of the customer. As part of the Know Your Customer principle, we ask for official documents of Bengali players such as a passport or ID card, proof of residential address, and contact details. This is necessary to verify the identity of the user from Bangladesh and eliminate fraud.
We also check if the customer is not on the list of politically exposed persons (PEPs) or sanctions lists (OFAC, EU, UN). We analyze behavior on the website, namely transaction amounts, geolocation, change of devices, VPN usage, and other parameters. The Bengali user will not be abale to deposit or withdraw funds until this check is completed. All collected data is securely protected and is not shared with third parties.

Our website uses a risk assessment model based on the principle of an individualized approach to each Bangladeshi customer. We divide players into three categories, such as low, medium, and high risk, depending on several factors (country of residence, payment instruments used, frequency of transactions, presence of VPN, and other attributes).
High-risk customers undergo additional Enhanced Due Diligence (EDD) checks, and all suspicious activities are recorded and analyzed manually or through automated systems. For example, if a Bangladeshi user suddenly changes payment methods, increases deposit amounts, or uses non-standard IP addresses – this will activate the check.
SapphireBet also dedicates resources to supervising the actions of those Bengali customers who are potentially involved in money laundering or other irregularities. This effectively prevents abuse, keeping the gambling process fair and compliant with international legislation.

Politically Exposed Persons are Bengali players who hold, previously held, high government or public positions. They also include close relatives and partners of such persons. According to international practice, this category of clients is subject to Enhanced Due Diligence (EDD), as they carry a higher risk of involvement in corruption schemes and financial abuse.
During the registration and KYC process, we use automated tools to screen customers from Bangladesh for PEPs. Regular monitoring is also conducted to detect possible changes in the player’s status. If a user is identified as a PEP, there will be applied additional controls such as:

• Manual document verification;
• Analyzing sources of funds;
• Real-time transaction tracking;
• Limiting transactions.

We ensure transparency of all activities related to such customers and work strictly in accordance with international FATF standards and regulatory requirements.

Our website adheres strictly to international sanctions control regulations and applies a comprehensive approach to prevent access to users from sanctioned and prohibited countries and individuals. The company regularly checks Bangladeshi users’ data against major international databases, including OFAC (USA), the European Union, and UN lists. If a player matches a person from these lists, their account is blocked or frozen, and access to financial transactions is restricted.
SapphireBet doesn’t serve users from countries that are under international sanctions or recognized as high risk under the AML and CFT. Such countries include Cuba, Iran, North Korea, Syria, Ukraine (Crimea, Donetsk, Luhansk), Russian Federation, Burma, Côte d’Ivoire, Congo, Eritrea, Iraq, Lebanon, Liberia, Libya, Somalia, Afghanistan, Burma (Myanmar), Central African Republic, Congo, Ethiopia, Sudan, Venezuela, Yemen, Zimbabwe, Australia, Austria, Belgium, Belize, Bulgaria, Colombia, Croatia, Curacao, Denmark, Estonia, Finland, France, Georgia, Germany, Italy Netherlands, Panama, Portugal, Romania, Spain, Sri Lanka, United Kingdom, United States, Aruba, Bonaire, Saba, Statia, St. Martin.
Registration and financial transactions are prohibited for customers from these countries. Attempts to circumvent the restrictions using VPN, proxies, or other means of anonymization are considered suspicious and will result in account blocking.

We use advanced technology and a comprehensive approach to continuously monitor all transactions on the site. Our system automatically analyzes each financial transaction, assessing it in terms of fraud risk and compliance with AML policy.
Special attention is paid to attempts to circumvent restrictions, VPN usage, and transactions related to jurisdictions on the risk list. We monitor suspicious activity such as:

• Abnormally large amounts;
• Frequent transactions in a short period;
• Sudden changes in user behavior;
• Use of uncommon payment methods.

If suspicious activity is detected, then the transaction will be blocked, so the client will be subjected to additional scrutiny. There is a thorough analysis and, if necessary, a further verification procedure is carried out, and a report is made to the competent authorities.

If you are a Bangladeshi player, you are required to provide complete and accurate information when registering and conducting financial transactions. False information or attempts to conceal your identity will be considered a violation of the rules and may result in suspension or blocking of your account.
It is forbidden to use other third-party methods or accounts to make deposits and withdrawals. All transactions must be made only from your official payment instruments. This allows us to prevent fraud and ensure transparency.
In addition, our players from Bangladesh are required to comply with SapphireBet’s rules, including geolocation restrictions and identification procedures. Breaking the terms of use, attempting to circumvent, and using prohibited access methods are prohibited and will result in sanctions.