Anti-Money Laundering Policy

Habtam Bet operates under the National Lottery Administration of Ethiopia with comprehensive compliance procedures designed to prevent money laundering, terrorism financing, and financial crime. This policy explains our customer verification requirements, transaction monitoring practices, and regulatory reporting obligations.

Regulatory Framework

Habtam Bet is regulated by the National Lottery Administration (NLA) of Ethiopia and operates in compliance with all applicable local regulations. We adhere to international standards established by the Financial Action Task Force (FATF) and maintain internal procedures that exceed minimum regulatory requirements. Our anti-money laundering program is built around three core principles: knowing who our customers are, understanding the source and destination of their funds, and detecting activity patterns that may indicate financial crime.

Every account registration, deposit, withdrawal, and significant transaction undergoes review by our compliance team. We maintain detailed records of all verification activities and transaction history for regulatory authorities and conduct ongoing monitoring throughout the customer relationship to identify suspicious patterns early.

Customer Identification and Verification

Account Registration Requirements

When customers open an account with Habtam Bet, they must provide their legal name, date of birth, national identification number, and current residential address. All information is cross-referenced against available databases and government records. False or misleading information during registration is grounds for immediate account suspension and forfeiture of any account balance.

Registration captures contact details and verifies the customer's geographic location and IP address. Customers registering from multiple locations or using VPN services that obscure their true location may trigger additional verification procedures. We also record the customer's stated occupation, education level, and experience with online gambling to establish a risk profile that guides our ongoing monitoring practices.

Know Your Customer (KYC) Verification Process

Before customers can withdraw funds from their account, Habtam Bet requires mandatory Know Your Customer verification. This process ensures we have reliable, verified information about our players and establishes a baseline for detecting unusual account activity. The KYC process typically completes within 24 to 48 hours after customers submit required documentation.

Customers must provide one of the following documents to verify their identity:

• National ID card (must be valid and not expired)
• Passport (must be valid and not expired)
• Utility bill or recent bank statement confirming the registered address

All documents must be clear, legible, and display required information without obstruction. Blurry, partially obscured, or damaged images are rejected and customers are asked to resubmit. Our verification team may request clarification or additional documents if initial submissions raise questions about authenticity or if information conflicts with the registration data provided.

Enhanced Due Diligence Procedures

Certain customer profiles require enhanced due diligence beyond standard verification. Customers with large deposit volumes, high-value transactions, unusual funding sources, or activity patterns that deviate significantly from their established profile trigger enhanced review. Customers from jurisdictions with elevated financial crime risk or those identified through sanctions screening may also be subject to additional verification requirements.

When enhanced due diligence is activated, our compliance team contacts the customer directly to request supplementary documentation, source of funds information, or explanations for unusual activity patterns. Failure to provide requested information or satisfactory explanations may result in account restrictions or closure.

Ongoing Transaction Monitoring

Habtam Bet implements continuous transaction monitoring systems that analyze all deposits, withdrawals, and betting activity against established customer risk profiles. Our systems flag transactions that exceed expected thresholds based on the customer's profile, show behavioral deviations, or match known money laundering patterns. All flagged transactions receive manual review from our compliance team within 24 hours.

Suspicious Activity Indicators

Our monitoring systems watch for rapid deposits followed by immediate large withdrawals with minimal or no gaming activity, also known as structuring behavior. We monitor for deposits from multiple distinct sources that converge into withdrawals to a single foreign account, deposits that appear inconsistent with the customer's stated occupation or income source, and activity suggesting the account may be operated by multiple individuals rather than the verified account holder.

We also track velocity patterns including unusually high transaction frequencies in short timeframes, sudden changes from dormant accounts to high-volume activity, and transaction sizes that spike significantly above historical norms. Customers with dormant accounts that suddenly show activity are subject to revalidation procedures and may require updated identification documents.

Behavioral Analysis and Account Assessment

Our compliance team regularly reviews customer account behavior to ensure gaming activity aligns with legitimate entertainment purposes. An account that receives multiple deposits but shows minimal betting activity, receives deposits only from high-risk payment methods or new sources, demonstrates evidence of layering or complex fund movements designed to obscure origin, or suddenly changes behavioral patterns without explanation may be restricted pending investigation.

We also assess whether a customer's gaming patterns are consistent with their stated experience level and preferences. New customers placing high-value bets on minimal-variance games alongside accounts showing simultaneous similar patterns may indicate shared operation or syndicate activity.

Payment Method Verification and Scrutiny

All payment methods used for deposits and withdrawals must correspond to the verified customer's identity. Habtam Bet does not permit deposits from third-party accounts or payment methods registered to names other than the account holder. This restriction applies uniformly across mobile money accounts, bank transfers, cryptocurrency wallets, and all other transfer mechanisms.

Our deposit methods in Ethiopia include mobile money platforms such as Telebirr and M-Birr with a minimum deposit of ETB 100 and instant processing, bank transfers via CBE, Awash Bank, Dashen Bank, and other licensed institutions with a 1 to 2 business day processing window, and cryptocurrency options including Bitcoin and Ethereum with variable minimums and 1 to 2 hour processing times.

Every payment method undergoes verification by comparing the account holder name with our verified customer records. Discrepancies result in transaction rejection and trigger enhanced verification procedures. All withdrawal requests must be sent to the same payment method used for the corresponding deposit unless the customer provides explicit written authorization to use an alternative destination. This requirement prevents rapid fund movement and layering schemes.

Suspicious Activity Reporting

Habtam Bet is legally obligated to report suspicious activity to the National Lottery Administration and relevant financial authorities when we identify transactions or patterns indicating potential money laundering, terrorism financing, sanctions violations, or other financial crimes. Our compliance team conducts thorough investigations into all flagged activity and prepares detailed reports documenting findings and the basis for our suspicions.

When an account is flagged for suspicious activity, Habtam Bet may implement temporary transaction holds, delay withdrawal processing pending investigation outcome, suspend the account entirely, or permanently close the account in cases where financial crime risk is determined to be unacceptable. Customers are notified of account restrictions and the general reason for restrictions where legally permitted, though investigation details may remain confidential.

Mandatory Reporting Obligations

Our compliance team reports to relevant authorities when we detect activity suggesting potential money laundering involving cryptocurrency or informal value transfer, terrorism or sanctions financing connected to designated individuals or organizations, fraud schemes involving customer accounts, structuring activity designed to circumvent reporting thresholds, or transactions involving customers appearing on international watchlists.

Reports are filed within the timeframes specified by applicable law and are treated with appropriate confidentiality protections. Customers are generally not notified that a suspicious activity report has been filed, as disclosure could compromise law enforcement investigations.

Staff Training and Compliance Culture

All Habtam Bet employees involved in customer service, payment processing, account management, or regulatory compliance receive mandatory anti-money laundering training. New staff complete training before handling customer accounts or processing transactions. Existing staff receive annual refresher training and immediate training updates when policies change or new threats emerge.

Training covers identifying suspicious activity indicators, proper document verification procedures, regulatory reporting requirements and timelines, customer interaction protocols for verification, and internal escalation procedures. Staff are trained to recognize social engineering attempts and understand their personal liability for knowingly facilitating financial crime.

Record Keeping and Documentation Requirements

Habtam Bet maintains complete documentation of all customer verification records, transaction history, and compliance investigations for a minimum of five years from the date of transaction or account closure. Records include customer identity verification documents and supporting materials, beneficial ownership information and declarations, detailed transaction records with source and destination information, communication records regarding flagged activity or investigations, and investigation outcomes and compliance decisions.

Records are stored in secure, encrypted systems with access restricted to authorized compliance personnel. All records can be provided to regulatory authorities or law enforcement upon official request within specified timeframes. Customers may request access to their personal records by submitting written requests and providing appropriate identity verification, subject to regulatory constraints on disclosure.

Third-Party Operation and Beneficial Ownership Verification

Habtam Bet does not permit account operation on behalf of third parties or different individuals than the verified account holder. Every account must be opened and controlled solely by the person whose identity has been verified through our KYC process. If we identify evidence that an account is being used by multiple individuals, operated by someone other than the verified account holder, or being used to facilitate transactions for other parties, we immediately suspend the account pending investigation.

If customers disclose that family members or other parties have beneficial interests in account funds, we collect additional information about these parties and verify their identities according to standard procedures. Accounts showing evidence of complex ownership structures or frequent beneficial ownership changes may be subject to enhanced monitoring and periodic revalidation.

High-Risk Jurisdictions and International Sanctions Screening

Habtam Bet screens all customers and transactions against international sanctions lists maintained by the United Nations Security Council, European Union, United States Office of Foreign Assets Control (OFAC), and United Kingdom Foreign Office. Customers from countries subject to international sanctions, embargoes, or comprehensive financial restrictions may be unable to open accounts or access our platform.

Customers identified as matching sanctioned individual or entity lists are subject to immediate account suspension pending investigation. We do not process transactions involving sanctioned parties and report such activity to appropriate authorities. Customers believing they have been incorrectly identified may request delisting reviews and provide documentation supporting their position.

Politically Exposed Persons (PEPs) Compliance

Habtam Bet conducts screening to identify customers who are politically exposed persons or close family members of PEPs. This category includes current and former government officials at senior levels, military officers, judges and judiciary members, state enterprise executives, and immediate family members of these individuals. Accounts identified as involving PEPs are subject to enhanced due diligence and increased ongoing monitoring.

PEP identification involves screening against government databases, international watchlists, and news sources. Customers believing they have been incorrectly identified as PEPs may submit documentation for compliance team review and potential account status adjustment.

Anti-Terrorism Financing Procedures

Habtam Bet implements specific procedures to detect and prevent financing of terrorist organizations and activities. We screen all customers and transactions for connections to designated terrorist organizations and individuals. Transactions showing indicators of potential terrorism financing are immediately reported to the National Lottery Administration and other relevant authorities without delay.

Indicators we monitor for include deposits from unknown or undocumented sources immediately followed by large withdrawals to foreign accounts, activity patterns consistent with informal value transfer systems such as hawala networks, accounts showing sudden unexplained transaction volume increases, and customers with documented or disclosed connections to designated terrorist organizations.

Beneficial Ownership Transparency Requirements

For corporate or business accounts, Habtam Bet requires full disclosure and verification of all beneficial owners and controlling parties. We require business registration documentation establishing legitimate operation, identification of all shareholders, partners, or owners, and verification of individuals with ultimate beneficial ownership or control. Complex ownership structures require legal documentation explaining the ownership hierarchy and fund control mechanisms.

Business accounts showing characteristics of shell companies, deliberately obscured beneficial ownership, or frequent rapid ownership changes may be subject to suspension and investigation.

Policy Review and Updates

This AML policy undergoes annual review and is updated to reflect changes in applicable law, regulatory guidance from the National Lottery Administration, and emerging financial crime trends. Material updates to our policy are communicated to customers through website notices and email notifications. Customers' continued use of Habtam Bet following policy updates constitutes acceptance of revised terms and procedures.

Responsible Gambling Integration

Our anti-money laundering compliance program operates in tandem with our responsible gambling initiatives. Account restrictions implemented for AML compliance may overlap with responsible gambling interventions including self-exclusion options or deposit limit enforcement. Customers subject to account restrictions should contact our support team for clarification regarding their account status and the specific restrictions in place.

Detailed information about responsible gambling resources, gambling addiction support services, and tools to manage account activity is available on our Responsible Gaming page. We provide links to national and international support organizations including BeGambleAware and GamCare.

National Lottery Administration Contact Information

The National Lottery Administration of Ethiopia oversees Habtam Bet's compliance with anti-money laundering and gaming regulations. Customers with concerns about our regulatory compliance or who wish to report suspicious activity directly to the regulator may contact the authority below.

Policy Effective Date and Version

This Anti-Money Laundering Policy is effective as of 2026 and supersedes all previous versions. Habtam Bet reserves the right to modify this policy at any time without prior notice. Material changes will be communicated via email or website announcement. The current version of this policy is always available at habtam-bet.co/aml.