Cosmobet May Charge a 20% Fee on Deposits It Returns to Politically Exposed Players

The policy states that its standards are based on the EU anti-money-laundering directive, Directive (EU) 2015/849, and sets out client identification, a risk-based approach, a rule for politically exposed persons and the duties of a Compliance Officer. One clause attaches a charge to a status rather than to anything the player did.

• A 20% fee for politically exposed persons. The policy states "In case the mentioned checks show that the Player is a PEP, the Company reserves the right to terminate the Account and transfer back the existing deposits to the Player. In such case the Company may at its sole discretion charge the Player with the administrative fee in amount of 20% of the amount transferred." The clause speaks of deposits only and says nothing about winnings. €1,000 of deposits returned this way could arrive as €800.
• PEP checks at any time. The company carries out PEP checks at any time, at its sole discretion, and the policy does not define who counts as a politically exposed person. The status can be found, and the fee applied, long after the account was opened.
• Identity before any transaction. The Client Identification Program is carried out before any financial transaction can be made, and no transaction is permitted with incomplete identity or, where needed, residence verification. Clients submit their name, email address, date of birth, a copy of an ID or passport and a proof of residence, such as a bank statement or utility bill, not older than 6 months. As written, the check comes before the first deposit, not at the first withdrawal.
• Records kept for at least 10 years. "Records of all documents obtained for the purpose of identification and all transaction data, as well as other documents are kept electronically for at least 10 years." No upper limit or deletion rule is given. The policy sets a floor on how long the documents are kept and no ceiling.
• Enhanced checks on the company's own findings. The company may carry out enhanced due diligence on clients it considers high-risk based on its own findings, on funds whose origin is unclear and on transactions of higher value and frequency, and its risk assessment may cover a client's background, country of origin, source of funds and volume of transactions. No amount is given that triggers these checks. A player cannot tell in advance which deposit will bring a source-of-funds request.

Most of the policy is the standard anti-money-laundering set: identity before the first transaction, screening against sanctions lists, a compliance officer. The PEP clause is the exception. It lets the company keep a fifth of the deposits it returns, for a status rather than for anything the player did.