Megapari Counts Source of Funds as Minimum ID and May Ask for Notarised Copies

Megapari's Anti-Money Laundering policy is short, about 4,500 characters, and most of it restates the duties anti-money-laundering law places on any operator: identify the customer, monitor the account, report suspicion. Its own choices sit in what the minimum check covers and in what it leaves out.

• Source of funds is part of the minimum. The minimum set of identification data the company checks is the player's full name, date of birth and residential or registered address, followed by the sources of funds the player plans to deposit into the account. Personal data is also checked against lists of persons suspected of terrorism. Explaining where deposits come from is part of the baseline check, not a step the policy reserves for large sums.
• Notarised copies in "certain cases". To verify identity the company may ask for a passport or ID card showing name, date of birth and photograph, and for the address a utility bill receipt not older than 3 months or another address document. "In certain cases, the Company may also require notarized copies of documents from the User." The policy does not say which cases, or who pays the notary.
• Suspect funds are blocked, with no stated way back. When there is reason to suspect deposited funds are related to illegal activity or terrorism financing, the company is bound to inform the competent authorities. "The company is also obliged to block such funds and to undertake measures provided for by the rules of the AML policy." The policy says when funds are blocked and names no step, deadline or outcome that releases them.
• A ban at any time, without being told why. "The company has the right to ban the User at any time, if the Company has grounds for supposing that this operation has any relation to money laundering and criminal activity." It adds that, in accordance with international law, it is not obliged to inform the player of the suspicion or that it has been passed to the authorities. A player banned on these grounds may never learn the reason, and the policy cites the law for that silence.
• Verification that does not end. "In accordance with the internal AML procedures the Company performs initial and ongoing personal identity verification procedures as provided by the level of risk of each User." The company records and keeps all data and ID, the methods of confirmation used and the results. Passing the check once does not close it, and the player's risk level decides when it comes back.
• The player vouches for deposits not yet made. On opening an account the player confirms having no information or suspicion that funds used for depositing in the past, present or future come from an illegal source, and agrees to immediately provide any information the company thinks fit to require. The warranty covers money the player has not deposited yet.

None of these clauses is unusual in an anti-money-laundering policy. The gap is at the end of the process: the policy explains in detail how funds come to be blocked and never describes what a player can do, or wait for, once they are.