These policies set out the principles, controls, and procedures adopted by FootballSX and FootballPX to prevent money laundering, terrorist financing, fraud, and excessive chargebacks, ensuring compliance with applicable laws across markets operations are active in.
These policies apply to:
- All group entities, directors, officers, employees, contractors, and agents
- All customers, transactions, and payment methods
- All products and services operated by the Company
- Board of Directors: Overall responsibility for compliance and oversight
- MLRO / Compliance Officer: Responsible for day-to-day AML, fraud, and chargeback management; primary contact for compliance queries
- All Staff: Required to follow these policies and report suspicious activity immediately
4.1 Risk-Based Approach
The Company adopts a risk-based approach to AML, assessing risks across:
- Customer type and profile
- Geography
- Payment methods
- Transaction behaviour and volume
Enhanced controls are applied where higher risk is identified.
4.2 Customer Due Diligence (CDD)
For all users, the Company performs CDD including:
- Identity verification (name, date of birth, address)
- Age verification (18+)
4.3 Enhanced Due Diligence (EDD)
EDD applies where higher risk is identified, such as:
- High-value or unusual transactions
- Customers from higher-risk jurisdictions
EDD measures may include additional documentation and source-of-funds checks.
4.4 Ongoing Monitoring
Customer activity is continuously monitored for:
- Unusual trading patterns
- Rapid deposits and withdrawals
- Behaviour inconsistent with a customer profile
4.5 Suspicious Activity Reporting
Where suspicion of money laundering or terrorist financing arises:
- Accounts may be restricted or suspended
- An internal report is escalated to the MLRO
- A Suspicious Activity Report (SAR) is filed with the relevant authority where required
5.1 Fraud Risk Areas
Key fraud risks related to transactions include:
- Identity fraud
- Payment fraud or card abuse
- Account takeover
- Bonus abuse
- Collusion or market manipulation
5.2 Preventative Controls
Controls include:
- Identity and device verification for all new users
- Velocity and behaviour monitoring
- Transaction limits and player exposure limits
- Manual review of flagged activity
5.3 Fraud Detection & Response
When fraud is suspected:
- Accounts may be frozen pending investigation
- Transactions may be reversed or withheld
- Findings are documented and retained
- Relevant authorities or PayModem may be notified
6.1 Chargeback Monitoring
The Company actively monitors chargebacks:
- Volume and ratios
- Reasons
- User-level chargeback behaviour
6.2 Prevention Measures
To minimise chargebacks, the Company ensures:
- Clear user onboarding and rules
- Transparent pricing and limits
- Accurate merchant descriptors for payment transactions
- Accessible customer support
6.3 Chargeback Handling Procedure
Upon receipt of a chargeback:
- The transaction is logged and reviewed
- Supporting evidence is gathered (KYC, logs, confirmations)
- A response is submitted within scheme deadlines
- Outcomes are recorded and analysed
6.4 Excessive Chargebacks
Users with repeated or abusive chargebacks may:
- Have accounts restricted or closed
- Be excluded from future services
The Company retains all records relating to payments, verification, transactions, and AML/fraud investigations for at least the statutory period. We partner with Veriff Station on verification of all new users.
- All relevant staff receive AML and fraud awareness training
- Training is refreshed periodically
- Attendance and completion are documented
These policies are reviewed:
- At least annually
- Following regulatory or guideline changes
- After any material incident or breach
These policies are approved by the Board of Directors and are effective immediately upon adoption.
Approved by Directors
James Gallagher, Conaire Creaney
Questions about this policy?
Contact us at [email protected] and we'll be happy to help.