Terms & Conditions

These terms and conditions, as well as the materials mentioned and linked to below (the “Terms”), provide the basis for the provision to you of the website maintained under the URL www.betbarter.com (the “Website”) and its associated or connected services (collectively, the “Service”).
Please review these conditions carefully since they constitute a legally binding agreement between you, our customer (“customer”) and us. By establishing an account (the “Account”) and using the service, you agree to be bound by these terms, as well as any future amendments.
If something is not evident to you, please contact us using the information below.
Sky Infotech N.V. is the supplier of the service.
Sky Infotech N.V., a Curacao-based limited liability company with business registration number 152377 and license number 365/JAZ Sub-License GLH-OCCHKTW0707072017, manages transactions and payment services.
Betbarter will only contact customers by email at their registered email address (the “Registered Email Address”) that was supplied when registering your Betbarter account. Communication from Betbarter shall be given solely through the following email: [email protected].

We retain the right to change the conditions (including any materials referenced and linked to below) at any time. If the change is minor, we may not notify you ahead of time. You will be advised in advance of any substantial changes to the terms, and you may be required to re-confirm your acceptance of the amended terms before they take effect. If you object to any such modifications, you must immediately cease using the service, and the cancellation procedures outlined below will apply. Continued use of the service signifies that you agree to be bound by these changes. Any bets that are not settled prior to the alteration to the terms taking effect will be subject to the previous terms.
If you have any questions regarding how to make bets or otherwise utilize the service, please go back to these terms or contact our customer service department at [email protected].

1. Your Obligations
By using the service, you consent to:
You are able to enter into a legally binding agreement with us if you are over the age of eighteen (18) or above the age of majority as specified by the laws of the applicable country.
It is the user’s obligation to confirm that they are in a nation where it is legal to use the service and to use this site exclusively in that capacity (if in doubt, you should obtain local legal counsel). It is your duty to confirm if using the service is permitted by law.
You have the right to transmit money to us; for example, you are the authorized user of the credit or debit card or other payment method you use.
You guarantee that making your bets won’t put you in any situation where there is a real, hypothetical, or perceived conflict of interest.
You are not operating on behalf of any third party or for any business purpose; rather, you are acting only in your own position as a private individual.
You run the risk of losing all or part of the money you deposit with us in compliance with these conditions when you place bets, and you bear full responsibility for such a loss.
You may only use the service for legal betting purposes. You may not attempt to manipulate any market or service feature in bad faith or in a way that jeopardizes our reputation or the integrity of the service.
You are prohibited from using any information you get while using the service to make bets if it violates any laws that are in effect in the nation in which you were at the time of the bet.
To avoid an obligation that was rightfully incurred, you must make all payments to us in good faith and refrain from attempting to have a payment reversed or from acting in a way that might lead to a third party doing so.
Other than that, you have to always, and for all bets placed through the service, behave in good faith toward us.
2. Registration
By using the service, you consent to always:
We retain the right, at our sole discretion and without any duty to provide a reason, to reject any applicant’s registration request in order to preserve the integrity of the service and for other operational reasons.
You must manually fill out the registration form, read these conditions, and agree to them before you may use the service. You can be asked to present a legitimate form of identification as well as any further documents that are thought to be required.
A photo ID (copy of a passport, driver’s license, or national ID card) and a bank statement, passbook, or check from your bank are examples of this, although they are not the only ones. Until the necessary information is obtained, we retain the right to stop accepting bets or to limit the options available on any account. This process is mandated by law and is carried out in compliance with the relevant gaming regulations as well as the legal requirements pertaining to the prevention of money laundering. Furthermore, you must finance your Betbarter account using the payment options listed in our website’s payment area.
You are obligated to give true and full information about yourself, including your working name, last name, address, and email address. You also need to update this information going forward to ensure it remains true and correct. It is your duty to maintain your account’s contact information currently. If you don’t, you could not get critical notifications and information from us regarding your account, such as updates to these terms. We use the registered email addresses of our customers to identify them and communicate with them. It is the customer’s obligation to keep an active and distinct email account, to give us an accurate email address, and to notify Betbarter of any changes to that address.
Every customer has complete responsibility for safeguarding their registered email address and preventing any unauthorized third party from using it. Any losses or damages that are thought to have arisen from correspondence between Betbarter and the customer via the registered email address are not covered by Betbarter’s liability policy. If a customer does not supply Betbarter with an email address, we will suspend their account until we get that address. If you knowingly give us fraudulent or erroneous personal information, we will suspend your account right away and send you a written notification to that effect. In some cases, we might also file a lawsuit against you for doing so, or we might get in touch with the appropriate authorities, who might file a lawsuit of their own.
With the service, you are only permitted to register one account. If it is discovered that you have more than one account registered with us, your accounts may be closed right away.
This covers the use of proxies, family members, associates, affiliates, linked individuals, and/or outside parties acting on your behalf.
We may utilize any third-party information sources that we deem essential to verify your identification and financial eligibility.
Your password for the service must be kept private. We have the right to presume that all bets, deposits, and withdrawals have been made by you, provided that the account information we required has been accurately provided. We recommend that you never give your password to a third party and that you change it frequently. Passwords must be at least eight characters long and must include one letter, one number, and one special character. It is up to you to keep your password secure; failing to do so will be at your own risk and cost. At the conclusion of each session, you have to log out of the service. You must contact us right away by emailing [email protected] with your registered email address if you think any of the information in your account is being abused by a third party, if your account has been hacked, or if a third party has found your password.

If your registered email address has been compromised, you must alert us. In order for us to confirm your identity, we may need further information or verification from you. As soon as we become aware of such an incident, we will suspend your account immediately. Until then, you are in charge of everything that happens on your account, including access from other parties, whether or not you gave them permission to do so.
It is prohibited for you to share any content or other information on the service with other customers or parties through screen captures or similar methods at any point. Additionally, you cannot display any content or information in a frame or in any other way that differs from how it would appear if the customer or third party had typed the service’s URL into their browser.
Our online sign-up page is just an invitation to treat; we are not obligated to establish an account for you. We retain complete discretion over whether or not to proceed with creating an account for you, and in the event that we decline, we are not obligated to give you a reason for the denial.
After receiving your application, we can get in contact with you to ask for more information or evidence so that we can fulfill our legal and regulatory requirements.

3. Restricted Use
3.1 You are not permitted to use the service if you are not of legal age to enter into a binding legal agreement with us or if you are less than eighteen (18) years old (or younger than the age of majority as specified by the laws of the jurisdiction in which you reside);
To gather aliases, email addresses, and/or other details from other users by any method (such as sending unsolicited emails, spam, or illegally framing or linking to the service);
To interfere with, improperly impact, or otherwise influence the way other customers are using the service or how it operates in general.
To encourage unsolicited commercial offers, affiliate links, and other solicitations that might be taken down from the service at any time;
In any manner that, based on our reasonable judgment, would be interpreted as an effort to: (i) defraud the service or another customer; or (ii) conspire with another customer to use the service dishonestly;
To infringe against our intellectual property rights or scrape our odds; or.
For any kind of illegal behavior.
3.2 You are not permitted to purchase a player account from a third party or sell or transfer your account to another person.
3.3 You are not permitted to move money between player accounts in any way.
3.4 Syndicate betting and fraud
3.4.1 Unless specifically asked and approved in advance, no individual or household may have more than one BetBarter account.
3.4.2 BetBarter has the right to cancel any number of accounts that violate this policy. Additionally, BetBarter has the right to identify and terminate duplicate accounts. In this instance, all pertinent information will be moved to the corresponding client’s oldest account following a thorough examination of the customer’s personal information through the request of legitimate and approved KYCs.
3.4.3 A customer’s client rights will be promptly withdrawn, and their wins and/or deposited funds may be confiscated if it is discovered that they have several accounts and have made similar bets.
3.4.4 When it appears likely that a client would operate in concert or as a syndicate, BetBarter does not take bets.
3.4.5 If there is reason to believe that there has been match-fixing or other illegal activity, BetBarter retains the right to reject or cancel any winning bets, seize any cash in the accounts, and terminate the accounts permanently.

3.5 If you use the Service for unauthorized reasons, we have the right to immediately cancel your Account and give you written notice. In some cases, we could even file a lawsuit against you for doing so.

4. Private
We shall strictly adhere to these Terms and our Privacy Policy while processing any information you provide us.

The identity of any user placing bets through the service will not be disclosed unless it is legally required by regulatory bodies, law enforcement (for example, to look into cases of fraud, money laundering, or issues pertaining to sports integrity), financial entities (such as banks or payment processors), or as periodically allowed by the Privacy Policy.

Your information will be entered into our database upon registration and retained in an accessible format by us for a minimum of five years beyond the termination of our partnership. By accepting these Terms, you consent to the transmission of your personal data as further described in our Privacy Policy and for the purpose of delivering the services that are the subject of this agreement.

5. Your Account
Indian Rupees (INR) will be used to manage your account.

We don’t offer acknowledgement for using the service.

If you violate these Terms, or if we have good cause to think that you are not, we may close or suspend your account, return any money that was retained, protect the integrity or fairness of the service, or take other appropriate action. We might not be able to notify you in advance every time.

Without giving any previous warning, we retain the right to suspend an account and refund all money. However, we will uphold contractual commitments that have reached maturity.

We have the right to reject, limit, cancel, or restrict any wager at any time for any reason, including any wager that seems to have been made fraudulently to get around our system rules and/or betting limitations.

We reserve the right to cancel and/or nullify any bets you place if we shutdown or suspend your account as a result of your violation of these conditions.

If any money is inadvertently credited to your account, it remains our property. We will contact you and deduct the amount from your account as soon as we discover this mistake.

You will owe us the amount that your account has overdrawn if it does so for any reason.

As soon as you become aware of any inaccuracies pertaining to your Account, you must notify us.

6. Funds Deposit
Any of the ways listed on our website may be used to deposit money into your account. Indian rupees (INR) should be used for all deposits.

Since Betbarter is not a banking institution, credit and debit card deposits are processed through a third-party electronic payment processor rather than being handled by us directly. Your account won’t be credited with money that you deposit using a debit or credit card until we get an authorization code and approval from the company that issued the payment. Your account won’t be credited with those funds if the issuer of your card doesn’t provide such authorization.

Depending on the currency of your account, your funds are deposited and retained in the appropriate client account.

Since we are not a financial institution, any interest that accrues on any unpaid account balances will be paid to us; you will not be entitled to receive interest on any outstanding amounts.

Money that comes from improper sources shouldn’t be placed with us.

7. Withdrawal of Funds
Between the 1,000 INR payment minimum and the 500.000,00 INR transaction maximum, you are able to withdraw some or all of your account balance.

Before allowing you to make any withdrawals from your account, we have the right to ask for proof of identification. Additionally, we maintain the right to ask for this paperwork at any point in the duration of your partnership with us.

All withdrawals must be made to the original bank account, debit card, credit card, or payment method that was used to fund your betbarter.com account. We could permit you to withdraw to a payment method other than the one from which your initial deposit was made, but this would always be at our sole discretion. There will always be extra security checks applied to this.

If you want to take money out of your account but it’s locked, dormant, or unavailable, please email [email protected] to get in touch with our customer service department.

8. Payment Processors and Transactions
All money owing to us must be paid in full by you. To avoid an obligation that was rightfully incurred, you must make all payments to us in good faith and refrain from attempting to have a payment reversed or from acting in a way that might lead to a third party doing so. You agree to pay us back for any chargebacks, payment refusals, or reversals you make, as well as any resulting losses we may incur. In addition, we retain the right to charge an administration fee of €60, or the equivalent amount, for any charge-back, payment refusal, or payment reversal you make.

You agree to be governed by the terms and conditions of any third-party electronic payment processors and/or merchant banks that we may use to process payments on your behalf, provided that you are informed of them and that their terms do not contradict these terms.

Every transaction completed on our website may be examined to look for signs of money laundering or the financing of terrorism. Depending on which jurisdiction is in charge of the transaction, suspicious transactions will be reported to the appropriate authorities.

9. Mistakes
All wagers are void in the event that our system or any of its procedures malfunction or contain errors. If you discover any errors with the service, you have a duty to notify us right away. We shall not be liable to you or any third party for any direct or indirect costs, expenses, losses, or claims arising or resulting from such errors, and we reserve the right to void all games/bets in question and take any other action to correct any bugs, viruses, communication errors, system errors, or other problems that may arise in connection with the service and/or payments made to you as a result of a defect or effort in the Service.

All bets are invalid in the case of a malfunctioning casino system or disconnections. We keep the right to declare all wagers and bets that were the subject of any such error null and void and to deduct any money from your account related to the relevant bets or wagers in the event of such an error, any system failing, game error, or other malfunction in the casino system that results in an error in any odds calculation, charges, fees, rake, bonuses, or payout, or any currency conversion as applicable (the “Casino Error”).

We do our hardest to make sure that publishing is done correctly. We reserve the right, nevertheless, to cancel or void any wager made due to human error or system malfunctions if it is accepted at an odd that is: materially different from those available in the general market at the time the bet was made; or obviously incorrect given the chance of the event occurring at the time the bet was made.

We reserve the right to recoup any overpayment from you and to make any necessary account adjustments. Such an error may include entering an event’s result wrong or pricing improperly, for example. We have the right to request payment from you for any incorrect bets or wagers if there is not enough money in your account. As a result, we retain the right to revoke, diminish, or eliminate any outstanding plays, whether or not they were funded by the mistake.

10. General Rules
If a general rule conflicts with a rule unique to a particular sport, the general rule will take precedence.

The date of the event’s settlement will be used to decide the winner; contested or overturned rulings will not be accepted for wagering. If an event is postponed after the competition begins, the outcome will be determined in accordance with the wagering guidelines we specify for that particular sport.

Beyond 72 hours, all results will be posted and considered final; questions will not be accepted beyond that time. The firm will only reset or correct results if there is a human error, a system error, or a mistake made by the referring results source within 72 hours of the results being posted.

We shall set the minimum and maximum wager amounts for all athletic events, and we have the right to alter them at any time without giving previous written notice. Additionally, we maintain the right to change the limitations on certain Accounts.

The only people in charge of an account’s transactions are the customers. Before submitting your bets, please check them over for any errors. A transaction cannot be altered once it has been completed. We will not consider requests for discrepancies arising from missing or duplicate plays, nor will we accept liability for wagers that the Customer makes that are either missing or duplicate. Following every session, users may check their transactions in the My Account area of the website to make sure all of their desired bets were approved.

A contestant must attend and participate in the event in order for a wager on any specified contender in a Yes/No Proposition to have action.

We make an effort to adhere to standard practices by using vertical positioning on the desktop site version to designate the home and away teams. We make an effort to denote a neutral location by placing the letter “N” next to the team names.

Regardless of the League heading attached to the match, there will be activity in a given game or match. For instance, two clubs participating in a Cup tournament are from the same League. As long as the matchup is accurate, even if it is accidentally included in the League offering, the game or match will still go on. Put otherwise, a contest will be played regardless of the League header it appears under on our website, provided that both teams are correct.

All bets on an event are null and void if it is not played on the day the regulating body has specified. All bets are subject to action on the date declared by the regulating body in the event that we post an event with the wrong date.

Events, markets, and other products may be removed from the website at any time by Betbarter.

Betbarter has the power to deny any player admission to the casino without giving them advance warning.

Except in cases where the minimum number of games needed for the future to have “action” has not been played, the winner as decided by the Governing Body will also be deemed the winner for betting purposes in all futures wagering.

11. Communications and Notices
Any notifications or communications that you are required to send to us under these conditions should be submitted to [email protected].

Unless otherwise indicated in these terms, any correspondence and notices that we are required to send you under these terms will be posted on the website and/or emailed to the Registered Email Address that we have on file for the relevant Customer. Our full and exclusive discretion shall govern the mode of any communication.

When the service is not run by Betbarter, any notifications and communications that are required to be delivered under these terms by either you or us must be sent in writing in the English language to and from the Registered Email Address associated with your account.
12. Matters Beyond Our Control
Even though we took reasonable precautions to avoid it, we cannot be held responsible for any Force Majeure event that could be deemed to be beyond our control and result in a delay or failure in providing the service. Examples of these events include acts of God, labor disputes or trade disputes, power outages, pandemics, government actions or inaction, failures or obstructions of telecommunications services, or any other delay or failure caused by third parties. We also disclaim all liability for any loss or damage that may arise as a result of these events. Without being held responsible, we have the right to stop providing the Service in such a situation.

13. Liability
If we fail to fulfill our obligations under these terms, we will not reimburse you for any foreseeable loss or damage (direct or indirect), to the extent allowed by applicable law, unless we violate any legal duties, in which case we will not be held accountable to you if our failure is caused by:

Your own responsibility. A third party not directly involved in our performance under these conditions (for example, issues with connection, congestion, and performance of the communications network, or issues with the functionality of your computer equipment);

Anything else that, even with our best efforts, neither we nor our suppliers could have predicted or prevented. Since this service is solely intended for use by consumers, we disclaim all liability for any type of business damage.

Our whole aggregate liability to you under or in connection with these conditions shall not exceed: Should we be found responsible for any incident under these terms:

(A) The amount you bet or wagered using your account in relation to the relevant wager, bet, or product that resulted in the applicable obligation; or

(B) 500 EUR total, whichever is less.

Before using the service, we highly advise that you (I) carefully check that it is appropriate and compatible with your own computer hardware; and (II) take appropriate safety measures to guard against dangerous software or hardware, such as installing antivirus software.

14. Playing Poker When Underage
Your account will be suspended to prevent you from making any more bets or withdrawals from it if we suspect or learn that you are, or were, under the legal age of majority in the jurisdiction in which you placed any bets through the service. After that, we will look into everything, including if you have bet on behalf of or as an agent for someone under the age of eighteen (or under the age of majority as defined by the laws of the country that apply to you). After determining that you: (a) are now; (b) were, at the relevant time, under the majority age that applies to you; or (c) have been, as an agent or at the request of, a person who is, at the relevant time, under the majority age that applies:

i. All winnings that are in your account now or that are about to be awarded will be kept.

This requirement also applies to you if you are older than eighteen but are betting in a jurisdiction where the legal betting age is more than eighteen and you are less than the minimum legal age in that country.

We retain the right to take all necessary action to investigate the problem, including notifying the appropriate law enforcement agencies, if we believe you are violating the terms of this Clause 14 or are attempting to use them fraudulently.

15. KYC and Anti-Money-Laundering Policy
Betbarter aggressively works to stop its services from being used to support financial crime, money laundering, and terrorism funding.

Enforcing strict adherence to all relevant regulations will safeguard the firm’s senior management and employees from potential legal, regulatory, and supervisory breach risks. It will also protect Betbarter’s reputation from potential harm should it be linked to money laundering and terrorist financing operations.

In order to accomplish these goals, this company has a policy that:

Each employee is expected to fulfill their own commitments in accordance with their roles and duties;

Betbarter’s anti-money laundering commitment is unaffected by commercial considerations. The company will designate a Money Laundering Reporting Officer/Nominated Officer (“MLRO”) and a deputy to cover for them in their absence. All staff members will be provided with all the support and cooperation they need to fulfill their roles. The Chief Executive Officer (CEO) will serve as the deputy.

Betbarter will adhere scrupulously to all relevant AML/CFT laws and guidelines, emphasizing:

A compliance culture should be embraced and spread across the company in order to stop financial crime;
A promise to make sure that, at the necessary thresholds, the identities of the customers will be successfully confirmed;
A pledge to properly “know its customer” by taking the necessary measures to confirm the customer’s identity and keeping an eye on how they use BetBarter services, both at the time of acceptance and during the business relationship;
A dedication to setting up processes to carry out these objectives, as well as to guaranteeing that personnel get training and education on the law and their responsibilities under it;
Acknowledgment of the significance of employees disclosing internal suspicions as soon as possible:

The risk-based approach forms the foundation of our policies, processes, and controls. By using a risk-based strategy, we concentrate our efforts on high-risk areas.

Our internal controls, procedures, and policies are created to guarantee adherence to all applicable anti-money laundering and anti-terrorist financing laws and guidelines. They will be regularly reviewed and updated to make sure the right internal controls, policies, and procedures are in place to take into account changes in our company’s operations as well as changes in the laws.

15.1 Terrorism Financing and Money Laundering
The definition of money laundering is:

Conversion or transfer of property with knowledge that it is the result of criminal activity or participation in it, with the intention of hiding or disguising the property’s illicit origins or helping any individual involved in the commission of such activity avoid the legal ramifications of their actions;

b. Hiding or disguising the genuine character, origin, location, use, or rights pertaining to, or ownership of, property, with the knowledge that such property is generated from illegal activity or from an act of involvement in said conduct;

c. Getting, holding, or using property with knowledge, at the time of receipt, that it was obtained via illegal conduct or from an act of participation in illegal action;

d. Engaging in any of the activities listed in points (a), (b), and (c), as well as assisting, abetting, facilitating, and counseling the commission of any of these acts.

Even in cases where the actions that produced the property to be laundered took place on the territory of a third party or another Member State, it will still be considered money laundering.

The donation or collecting of funds, whether by direct or indirect methods, with the knowledge or purpose that they would be used, fully or partially, to carry out any terrorist act, is known as terrorism funding.

15.2 How the AML/CFT function is organized
15.2.1 High Level Executives
Senior Management is in charge of overseeing Betbarter’s whole compliance policy and making sure sufficient funding is available for staff training and risk system implementation. This includes computer programs that help with supervision. The Board of Directors, Executive Management, and MLRO make up Senior Management.

15.2.2 The Nominated Officer/Money Laundering Reporting Officer
In charge of reporting to the Curacao Gaming Control Board and accepting internal disclosures. first point of contact for employees with any compliance-related concerns. evaluates the risks associated with compliance systems. carries out routine random examinations of transactions, evaluating customer-provided documentation as well. helps with modifying the AML Policy as needed in accordance with the risk assessment. Make sure that everyone is kept up to date on any modifications to laws, rules, and procedures related to stopping money laundering and terrorist financing, as well as any new developments in these areas that may affect their line of work. Verifies that all required information has been gathered by reviewing client identifying data. Creates and executes the risk rating matrix in accordance with regulatory guidelines, and submits it for Senior Management evaluation and approval.

15.2.3 Staff
It is your responsibility to be aware of and comprehend the AML Compliance Policy. Make sure that the company’s protocols are followed, and gather all the documentation required as per the handbook. Make certain to notify the MLRO of any suspicious or odd activities.

15.3 The Plan for Compliance
15.3.1 The Reporting Officer for Money Laundering (MLRO)

For the sole purpose of overseeing Betbarter’s adherence to anti-money laundering regulations, the company has designated an MLRO.

The MLRO:

Will oversee the day-to-day functioning of Betbarter Trading’s AML/CFT policies and answer any reasonable request made by law enforcement or the Curacao Gaming Control Board;
Has the capacity to act independently in carrying out their tasks, including direct access to the Gaming Control Board of Curacao and competent law enforcement organizations, so that any unusual conduct may be reported to the proper authorities as soon as possible;
Has the authority and resources required to carry out their obligations effectively;
Is in a senior position with direct access to senior management and the board of directors;
May opt to assign certain obligations to other workers; but, whenever such delegation occurs, the MLRO retains ultimate responsibility for the compliance regime’s execution;
At least once a year, the MLRO shall provide a report (the MLRO Report) to Betbarter’s senior management on the operation and efficacy of its money laundering controls. This report will discuss improvements, remedial programs, the results of any internal audit evaluations of the AML/CFT processes, and other pertinent information.

15.4 Compliance Policy and Procedures
Betbarter employs rules and procedures to examine the risks associated with money laundering and terrorism funding. The policies and processes are:

Written and maintained by the MLRO under the guidance of top management;
Authorized by high management;
Everyone who deals with customers or their transactions must communicate, understand, and adhere to this policy, including those who work in the areas of customer identification, record keeping, and reportable transactions, who require sufficient information to process and complete a transaction properly, as well as to determine the identity of customers and keep records as required;
Procedures and guidelines that include relevant requirements for reporting, record keeping, customer identification, risk assessment, and risk reduction;
Although directors and senior officers may not be involved in day-to-day compliance, they must comprehend the regulatory obligations imposed on them, their employees, and Betbarter itself.

15.4.1 The Risk-Based Approach
In money laundering and terrorist funding, a risk-based strategy includes the following:

The process involves assessing risks in customer interactions and company operations, implementing controls to address identified risks, and maintaining up-to-date information on customer identity, beneficial ownership, and business connections;
Continuous monitoring of business contacts and transactions;
Existing regulatory responsibilities, such as customer identification, serve as a minimal requirement. Where expanded due diligence is required, a risk-based approach principle is to direct resources to where they are most needed in order to manage risks within our tolerance threshold.

15.4.2 Risk Mitigation
Risk mitigation entails putting in place procedures to restrict the possible money laundering and terrorist financing risks identified in the risk assessment so that the risk tolerance threshold is not exceeded. When the risk assessment shows that there is a high danger of money laundering or terrorist funding, we will create and implement risk mitigation solutions.

In all cases, risk management controls and procedures include the following:

Concentrating on activities (products and services, consumers and business connections, geographic areas, and any other relevant aspects) that are more susceptible to misuse by money launderers and criminals;
Notifying executive management of compliance activities, discovered compliance flaws, remedial action performed, and suspicious transaction reports filed;
Ensure program continuity despite changes in management, workers, or structure;
Focusing on completing all regulatory record keeping and reporting obligations, making suggestions for anti-money laundering and anti-terrorist financing compliance, and delivering timely updates in response to changes in regulations;
Enabling the prompt identification of reportable transactions and the proper submission of mandatory reports;
Including anti-money laundering and anti-terrorist financing compliance in job descriptions and performance assessments for suitable workers;
Providing proper oversight and instruction to workers who handle currency transactions, file reports, monitor for suspicious transactions, or engage in any other activity related to the anti-money laundering and anti-terrorist financing programs;
Raising awareness of high-risk scenarios across all business lines;
Increase the frequency of continuing monitoring of transactions or commercial ties;
Escalating approval for the formation of an account or connection even if it is not otherwise necessary;
Increasing ongoing controls and relationship evaluations;
Requesting that high-risk clients supply extra, documented information on the safeguards they have adopted to protect their operations from misuse by money launderers and terrorists;
Verifying consumers’ identities using reputable, independent source papers, data, or information;
Preventing any transaction with a potential consumer until identity and account opening details are acquired;
Implementing a process for approving high-risk relationships during customer acceptance or declining to do business with potential customers who exceed BETBARTER’s risk tolerance level. Also, implement a process for exiting an existing high-risk relationship if management deems it to be above the risk tolerance level.

15.4.3 Risk Assessment.
Betbarter is obligated to investigate possible risks and vulnerabilities to money laundering and terrorism funding to which the company may be subject in a risk assessment.

The risk assessment will record and analyze the following:

Products, Services, and Delivery Channels;
Geographic locations and regions of operation;
Customers.

The risk assessment may uncover high-risk circumstances that necessitate risk mitigation and monitoring measures. The risk assessment is not static; it will alter over time.

When a client is recognized as high-risk, their customer identity information is monitored and updated on a more frequent basis, as well as any other relevant increased safeguards.

Betbarter must conduct an initial risk assessment at the start of each new client engagement, as well as on a continuing basis for current customers.

15.5 Client and Business Risk
15.5.1 Products, Services and Delivery Channels

Betbarter will identify items and services, or combinations of them, that represent a high risk of money laundering or terrorism funding. For example, goods and services that facilitate the transfer and conversion of assets into, through, and out of the financial system are high risk. Financial regulators, governmental entities, or other trustworthy sources have also classified the following services as being high-risk for money laundering or terrorism financing:

Types of transactions include wire transfers, third-party transactions, and non-face-to-face commercial partnerships.

15.5.2 Geographic Locations and Areas of Operation
Countries identified as non-cooperative in combating money laundering or terrorist financing by the Financial Action Task Force (FATF) or subject to a FATF statement, as well as those with inadequate laws and regulations or high levels of corruption, may be subject to sanctions.

Betbarter does not do business with or offer services to anybody in any of the nations listed below, which are subject to extensive international sanctions.
15.5.3 Customer Relationships

Knowing your customers (“KYC”) is required for risk assessments. This is more than just identifying and recording consumers; it is also about understanding their actions, transaction patterns, and how they function.

Examples of criteria that will be evaluated include:

How long have we known the customer and had a commercial relationship;
Customers seeking significant transactions or facing regulatory or enforcement concerns;
Customers with several online complaints;
Customers’ identities are tough to verify;
Customers who are politically exposed;

Each customer is assigned a risk rating of low, medium, or high for money laundering and/or terrorism funding. The rating assigned at the start of the business partnership may be altered following the re-assessment and may fluctuate over time. The extent of client due diligence will vary depending on the customer’s risk assessment at the start of the relationship and as it evolves. For all high-risk players, increased due diligence is immediately undertaken.

15.5.4 Regulatory risk
Regulatory risk occurs when we fail to satisfy our commitments under relevant legislation. Examples of violations of regulatory responsibilities are:

Issues with customer identification and inadequate staff training;
Bot has an anti-money laundering and anti-terrorism financing (AML/CFT) program;
Failure to disclose suspicious transactions;
Not having an MLRO;
Failing to maintain comprehensive customer records.

15.6 Compliance Training
Betbarter provides training to all necessary employees and other persons who operate on behalf of the company. The purpose of this course is to ensure that people who interact with customers, observe customer transaction activity, or handle cash in any way understand the reporting, customer identification, and record-keeping standards.

Betbarter requires all new employees to take anti-money laundering and terrorist financing compliance training within their first few months of work, and customer-facing staff get training before engaging with clients.

Training is currently provided internally by the company’s more experienced team members on the field. The MLRO regularly reviews and updates the training curriculum to suit changing requirements. The compliance training includes a test that everyone must pass before their training is considered complete.

To ensure that staff training is current, all existing employees will get monthly follow-up training on new and existing AML and regulatory standards (at least one year after their previous training). If the online training test results indicate that a staff member does not grasp the training content, Betbarter will provide specialized one-on-one training to help the staff member understand the topic.

The MLRO and HR departments maintain an employee log of assigned and finished training materials for administrative purposes. These records will be retained for five years.

Compliance training is tailored to the employee’s function within the firm. The MLRO will examine functions and plan to deliver appropriate and tailored training.

Our training will involve at least:

Awareness of reporting, customer identification, and record keeping obligations, as well as consequences for failing to satisfy those criteria;
Making all personnel aware of the internal rules and procedures for discouraging and identifying money laundering and terrorism funding related to their jobs;
Provide workers and suppliers with a clear awareness of their duties under these rules and procedures;
All people who interact with customers, observe customer transaction activity, handle cash or money in any manner, or are in charge of implementing or managing the compliance regime must be aware of the reporting, customer identification, and record-keeping requirements;
Making all personnel aware of how Betbarter is susceptible to exploitation by criminals laundering the proceeds of crime or terrorists funding their activities;
Making all employees and agents aware that they cannot disclose that they have submitted a suspicious transaction report, or reveal the substance of such a report, with the aim of prejudice a criminal investigation, whether it has started or not;
All employees and agents realize that no criminal or civil procedure may be initiated against them for filing a report in good faith.

Background information on money laundering so that everyone who needs it may grasp what it is, why criminals choose to launder money, and how the process normally works.
Details on what terrorist funding is and how it normally operates.
The MLRO is responsible for keeping everyone up to date on changes in anti-money laundering or anti-terrorist financing laws, policies, and procedures, as well as current developments in money laundering or terrorist activity funding schemes that are relevant to their responsibilities.

Certain workers, such as those in compliance, customer service, and operations, require specific supplementary training, which may be delivered either externally or internally. The training curriculum is evaluated and revised to match changing requirements.

15.7. Minimum standards: KYC POLICY
Betbarter has created guidelines for Know-Your-Customer (“KYC”). These standards require due diligence on each prospective customer prior to establishing a business relationship, which includes identifying and verifying his identity and, as applicable, his legal representatives and beneficial owners using documents, data, or other information gathered from a reliable and independent source that is compliant with domestic and European AML/CFT legislation and regulations.

The interpretation of the KYC principle begins with identifying the customer using the relevant identity papers.

This identity, together with other information obtained, allows the Customer Acceptance Policy to be implemented.

In addition to these objective criteria, there are subjective characteristics that may raise doubts about a consumer and should be carefully considered.

Finally, because KYC involves dynamic data derived from the customer’s connection rather than static data, it necessitates customer follow-up and monitoring.

15.7.1. Customer identification and verification (KYC)
To ensure the greatest degree of security, we demand that all of our members supply us with specific paperwork in order to confirm their accounts.
Please keep in mind that identification processes must be completed before a cardholder may operate and use our merchant’s services.

There are various explanations:
We are dedicated to offering a socially responsible platform for online gaming. All of our members must be 18 or older, and we are required by our license agreement to verify this.
Second, as a reputable online and worldwide organization, it is in our best interests to provide optimum security in all transactions.

Thirdly, compliance with international banking standards is a requirement set by our payment processors. To ensure the safety of all parties, a documented business connection with each and every member is required. We are also required to abide by this under our license agreement.
Finally, you may prevent the annoyance of “missing payments” by making sure all of your account data is accurate. Finding, recalling, and resending the material with the exact details might take weeks or even months at times. Our processors charge more as a result of this drawn-out procedure.

Please supply us with the necessary papers so that we may properly complete our KYC procedures:

A color copy of a current government-issued ID (driver’s license, passport, state ID, or military ID) serves as evidence of identity.
A copy of a current utility bill with your address on it serves as verification of address.
You don’t need to present further evidence of address if your government-issued ID displays your address.
Depending on the withdrawal option you select, further paperwork may be needed.
In the event that we do not possess the necessary paperwork, all outstanding withdrawals will be reversed and returned to your account. The notification system will let you know when this occurs.
These files can be uploaded using our secure form here after being scanned or supplied through a high-quality digital camera photo. Save the images as JPGs.
Your documentation’s security is extremely important. At every stage of the review procedure, every file is safeguarded using the strongest encryption possible. Every document that is received is handled with the highest discretion and respect.
We would like to express our gratitude for your assistance in helping us make Betbarter.com a safer gaming environment. As usual, please use the contact us options on this page to get in touch with us with any queries you may have regarding our policy or anything else.
One of the most important components of the KYC policy and the legislation pertaining to money laundering is the official identification of consumers when entering into business contacts.

The following basic principles are necessary for this identification:
– Original supporting documentation must be used to identify each customer, which is defined as each individual person and/or each person participating in the case of a legal company;
– A centralized system will be used to record these papers;
– Every individual found needs to be registered using IT methods;
– Should the identification procedure turn out to be unsatisfactory, the individual will not be approved as a customer.

This pertains specifically to the conduct of due diligence in accepting politically exposed individuals (PEPs).

Regardless of where they live, Betbarter’s concrete applicability is demonstrated via a unique identification process for clients referred to as PEP.

15.7.2. Calculating the risk profile
A “Compliance” risk profile is first determined upon entering into relations (Low, Medium, High), and it is subsequently recalculated every day to help determine the amount of AML/CFT due diligence to be done with regard to the Customer.

15.7.3. Signs of anomalous transactions
I. OBJECTIVE INDICATORS

A. A transaction that was reported to the court or police:

Any transaction related to money laundering or funding terrorism that is reported to law enforcement or the judiciary is reported to these agencies.

B. A planned transaction made by or on behalf of an individual, organization, or list created in accordance with the Sanctions Ordinance:

A planned transaction carried out by or on behalf of an individual, organization, group, or other entity included on a list created in accordance with the Sanctions Ordinance.

C. A transaction of at least NAf 5000,00 (€ 2.404,05), regardless of whether it is made with cash, a cheque or other form of payment, electronically, or by another non-physical method:

In any event, this comprises:

A giro transaction with a minimum value of NAf 5000,00 (€ 2.404,05);

A giro transaction occurs when a consumer requests a transfer from the service provider’s bank account to another local or foreign bank account;

The depositing or release of funds equivalent to at least NAf 5000,00 (€ 2.404.05) that is maintained in reserve;

Selling gaming tokens to a customer for at least NAf 5000,00 (€ 2.404,05);

Prize money in the amount of at least NAf 5000,00 (€ 2.404,05).

II. SUBJECTIVE INDICATORS

Suspected sponsorship of terrorism or money laundering:

A transaction for which there is cause for suspicion that it has anything to do with financing terrorism or money laundering.
If there is a subjective indicator, the transaction is deemed unusual if the reporting entity has reasonable grounds to believe that the transaction is connected to money laundering or terrorism financing (based on its knowledge of its clients, their income and business activities, and any other relevant circumstance).

15.7.4. Deadline for reporting
All reporting organizations are required to submit their unusual transaction reports for objective indicators no later than 48 hours following the execution of the transaction or the indication that a transaction was intended.

When it comes to subjective indications, the interval between the transaction’s execution (or the desire to conduct one) and the compliance officer’s receipt of the report shouldn’t be more than 24 hours.

The Compliance Officer will have ten working days from the time they receive the transaction report to do any necessary research about potential money laundering.

Situation with Terrorism Financing.

15.7.5. Policy for customer acceptance

15.7.5.1. Identification of the Client
The purpose of client identification is to verify the existence, identify, and gather supporting identity information of the person with whom Betbarter has a commercial connection. This comprises actions to:

Verify the person’s existence with their identity documents;
Perform due diligence to confirm the customer’s identification, including checking the customer’s name against government watch lists, figuring out whether they are politically exposed, and figuring out if there are any third parties involved;
Maintain records of all the data and papers you acquire.

15.7.5.2. Customer Identifying Information
The normal identity criteria for those who have done business with Betbarter are outlined in this section. Most of the time, this outline should be adequate. However, Betbarter requests extra identification information and raises the degree of verification if it determines that the customer poses a greater risk of money laundering or terrorism financing based on our determined risk matrix.

The number of matches needed to be fairly satisfied with an individual’s identification will climb in cases where the normal verification check results raise doubts or concerns about identity. The MLRO must be notified of any concerns.

Customers could not be allowed to keep an account if they are unable to provide a primary ID, and the reasons for this should be documented.
Every piece of documentation has to be current.
Driver’s licenses and passports must be current and not expired.
A check, passbook, or bank statement.
We shall inquire with each client about whether they are working on their own behalf or in their own capacity with regard to beneficial ownership. We will need information if they are operating on behalf of someone else.

Sources of proof:

Acceptable photo identity as proof of identity:
A valid driver’s license (complete or provisional);
A valid passport or a national identity card.

When taking a customer’s identification proof, it’s critical that we verify the information sufficiently to be confident in the customer’s identity and that we maintain a record of those verifications. Either the MLRO or someone working under their direction will handle this.

Typical ID checks with photos might be:

Likeness in opposition to the client;
If the evidence’s birth date corresponds to the customer’s stated age;
If the ID still works;
If names have the same spelling as in other papers the customer has provided;

Exams for secondary identification evidence might consist of:

If the addresses are the same as the ones on the picture ID;
If the customer’s name matches the name on the ID photo.

15.7.5.3. Triggers for Identity Verification
The following circumstances may lead to the customer’s identity being verified:

When a client asks for a withdrawal to be made to an account other than the one that was used for the deposit (for example, because some payment service providers don’t allow incoming payments or for other reasons). In certain situations, the withdrawal requests will be completed once the customer’s identification has been confirmed to make sure the money is going to the correct person, however they will be instantly taken out of their account;
When a client deposits money more than once in a brief period of time;
Employees notice unusual deposit patterns or the usage of many credit cards (three or more distinct payment methods in a single week);
IP and registration country do not match. In some situations, the player’s account might not be disabled, allowing them to continue playing games and making deposits, but they won’t be able to withdraw money until verification is complete;
All of the identification-related papers will be maintained in copies.

15.7.5.4. Additional Documents
Customers may be asked to provide more documentation to support their actions or to better understand their patterns:

Proof of Bank Account: When a customer asks for a withdrawal to be placed into a bank account, this can be a snapshot or a copy of the bank statement that includes the customer’s name, IBAN, and bank name;

Proof of Payment Card: This might be a picture or duplicate of the card’s front side, or it could be a bank statement that has the customer’s name and the card information on it (in the event that questionable deposit patterns are found). Betbarter advises customers that, while they may conceal some card details for security reasons, the customer’s name and the first and last four digits of their card number must always be displayed.

Paystubs and bank statements may be requested from clients who exhibit potentially problematic gambling patterns or when the client’s external data does not support the amounts they are wagering. In such circumstances, Betbarter would ask its higher volume clients for papers that would substantiate the amounts being spent on gaming.

15.7.5.5. Mitigation of Impersonation Risk
Several extra identity verification checks are permitted on a risk-based approach. These examinations might consist of the following:

Requiring the initial payment to be made using a customer-named account with a credit institution regulated by the EU/EEA or a comparable jurisdiction;
Verifying extra parts of the customer’s identification, or of their electronic ‘footprint’.

15.7.5.6. Maintaining Current Information
A customer’s identity does not need to be verified again once it has been established. That identification, including the customer’s identity, will be requested once again if there is any uncertainty regarding the information held.

After reviewing the customer documentation, Betbarter is free to make any necessary updates. Any modifications to identity, such as a customer’s name change, would necessitate obtaining new paperwork.

15.7.5.7. Continuous observation of transactions
A few automatic controls are in place to keep an eye on what customers are doing, such as:

Initial deposits;
Notifications for cash-outs above NAf 5000,00 (€ 2.404,05).
Moreover, the Payments Team processes each cash-out request by hand and reviews them every day. Prior to approval, each request is subjected to security checks to make sure that the source of the cash or wins complies with both the company’s terms and conditions and the Gaming Control Board Curacao Policy.

15.8. Internal Control Organization
As Betbarter’s Nominated Officer, the MLRO is the person to whom any member of the organization can report questionable activity. A suspicious action is defined as one in which it is known or believed that there are good reasons to believe that someone is trying to finance terrorism or launder money.

15.8.1. Reporting of suspicious transactions
To be knowledgeable is to know that something is true. One might deduce knowledge from the environment; so, for instance, a neglect to inquire about obvious matters may indicate knowledge. But, Betbarter had to have learned about it from a disclosure (to the MLRO) or from commercial dealings.

Suspicion lacks the objective evidence basis of proof and is more subjective. Suspicion has a grounding and is more than just conjecture.

A strange transaction doesn’t always mean it’s suspect. Unusual gambling patterns, such as spending unusually large sums of money in comparison to the casino or a customer’s profile, should be investigated; however, unusual behavior should not always give rise to suspicions of money laundering or the need to report it to the FIAU. The MLRO must evaluate all of the facts, and in certain situations, it could be beneficial to get more information from the client or other parties. The decision is based on the information already available to the client and the transaction, as well as how simple it is to contact inquiries.

Employees who see a transaction or behavior as suspicious would not always be required to determine the specifics of any underlying criminal violation, or to know that the specific monies or property were obtained through criminal activity, money laundering, or funding of terrorism. An objective standard of suspicion is introduced by “reasonable grounds to know or suspect.” When a staff member is aware of information or circumstances that a reasonable person in a payments business would have used to determine knowledge or to develop a suspicion that someone else was involved in money laundering or terrorist financing, the test is likely to be passed.

Employees can defend themselves against failing the test of suspicion by demonstrating that they made a reasonable attempt to get to know the client and the goal of the transaction, activity, or direction.

15.8.2 How to File a Report on Suspicious Activity
Any odd transaction that is carried out or planned to be carried out must be reported by Betbarter to the FBI right away. A report must, to the greatest extent feasible, include the following data: The client’s identity, the kind and number of their identity document, the transaction’s nature, timing, and place, the volume, destination, and origin of the items involved in the transaction, and the transaction itself are all listed in order of importance.
The conditions under which the transaction is deemed exceptional.

Additionally, Betbarter is required to give particular attention to any complicated or abnormally large transactions, as well as any strange patterns of transactions without an obvious economic or functional reason. In order to promptly react to information requests from the qualified supervisor, Betbarter must retain the data related to the notice and record it in a way that allows the data to be delivered and the transaction in issue to be reconstructed.

Betbarter needs to register with the Curaçao Financial Intelligence Unit (FIU).

The goAML reporting portal (http://mot.cw/Web/MOTWeb/MOTWeb.nsf/web/goaml%20the%20new%20portal%20for%20fiu%20curacao) is where unusual transactions are reported electronically. The service provider can access this portal only after registering and having his registration validated by the Financial Intelligence Unit Curaçao.

To report a transaction using the goAML Reporting Portal, complete the two-part online form:

1. Details on the assigned reporting person and the reporting service provider. Every report this individual makes uses the same information;
2. The actual transaction data, which is input based on the selections given on the online form for every transaction. Which fields need to be filled in and submitted will be indicated by the Financial Intelligence Unit Curaçao. Each transaction report has to have information filled in, including any attachments, any transaction-specific facts, and any appropriate indicator(s). The reporting platform has an English language writing style.

15.8.3 How to Identify Suspicious Activity
Regardless of the amount of money involved, transactions may provide reasonable grounds to assume that they are connected to money laundering or the financing of terrorist activity. There is no minimum amount required to file a SAR. When many seemingly unimportant elements come together to form a suspicious transaction, it may be assumed that the transaction is connected to the actual or attempted commission of a money laundering or terrorism funding violation, or both. Generally speaking, if a transaction—or a series of transactions—raises doubts or causes unease, fear, or suspicion, it may be linked to money laundering or the financing of terrorist activities.

As far as is practically practicable, Betbarter will investigate the history and intent behind any complicated, unusually large transactions as well as any strange patterns of transactions that don’t seem to have any discernible legal or economic purpose.

One important consideration for evaluating suspicion is the context of the transaction, which varies depending on the consumer.

Transactions will be examined based on what appears to be appropriate and within standard business standards, as well as our knowledge of the customer. The fact that transactions do not appear to be in accordance with standard industry norms might be an important consideration.

Suspicions are assessed based on a reasonable judgment of relevant information, including knowledge of the customer’s company, financial history, background, and behavior. Not people, but their behavior is suspicious. To assist with this assessment, we have included a list of indications below.

15.8.4 Indicators of Suspicious Transactions
Certain items, services, activities, or channels may be more susceptible to money laundering. Listed below are numerous anti-money laundering risk indicators, or “red flags” that may raise concern. The list is neither full or definitive, but it will serve as a starting point for further research and investigation, in addition to other materials.

A single signal does not always suggest that there are reasonable reasons to infer money laundering or terrorist funding. However, if many signs are present during one or more transactions, we will consider additional considerations before determining whether the transaction must be reported.

If a transaction is canceled because it is suspected that the property is owned or controlled by or on behalf of a terrorist or terrorist group, a terrorist property report is required. If there are reasonable reasons to believe that the transaction is connected to an attempted conduct of a terrorist activity, funding, or money laundering violation, a suspicious transaction report is needed.

Certain signs may raise reasonable suspicion that one or more earlier transactions (that did not appear suspicious) were connected to money laundering or terrorist funding.

15.8.4.1 Application and Identification
Information mismatch from the application:

Inconsistencies in application information, address, and customer details from the first registration. Inability to produce a government-issued identity;
Change of address to a high-fraud region or difficult jurisdiction immediately after the application;
Lack of credible third-party and/or government verification of individuals;
The address specified (or verified) is classified as a mail drop or other high-risk address, rather than an actual street address;
The transaction volume, deposits, and cash-outs are inconsistent.

15.8.4.2 Account Settlement.
Large cross-border wire transfer payments.
Settlements/partial settlements with unconnected third parties
Excessive or continuing significant credit refunds.

15.8.4.3 Transaction and Customer Monitoring
When a customer’s stakes grow particularly large or out of the ordinary, the customer is suspected of spending above his or her means. This needs some understanding on the part of the consumer; yet, there may be situations that look strange and arouse the suspicion that he is using money obtained illegally.
It is possible that the consumer lives in low-cost housing with no recognized source of income, yet is nevertheless spending well above his or her apparent means.
There is no standard quantity that determines when a SAR should be sent, and much depends on what is known or suspected about the consumer.
A consumer engages in unconventional gambling behaviors with an almost assured return or minimal financial risk.
It is understood that some customers like to gamble in this manner; nonetheless, in other cases, the acts may generate suspicion since they depart from the customer’s usual gambling patterns.
A consumer deposits money or holds it for a set amount of time before withdrawing it without using it to gamble.
For example, any significant sums put in gaming machines or gambling accounts and then paid out or withdrawn after very little game play or gambling may raise concerns.
A client seems to find a certain amount of loss tolerable and frequently wagers big sums of money.
In this case, the consumer could be spending the proceeds of criminal activity and considers the losses incurred during the process of laundering those funds to be reasonable.
Over time, a customer’s spending climbs, hiding high spending and even money laundering.
A customer’s yearly aggregate expenditure is large and inconsistent with his predicted spending, even though he spends little but often.
A client exhibits high-spending but low-risk gambling behaviors, such as playing roulette red and black. The client may be using a method of money laundering that ensures little loss.
High consumer spending volumes that put the operator in a serious financial danger might potentially be an indicator of suspicious conduct.

Although there are significant distinctions, most indicators to establish suspicion that a transaction may be tied to an offense of financing terrorist activities mirror those related to money laundering. For instance, the sums associated with financing terrorism might often be lower.

15.8.5. Financial Sanctions
BETBARTER’s policy is to confirm each customer’s identification and make sure they aren’t the target of any legal actions that would prevent the company from offering its services, such as penalties. Using the screening techniques outlined by the MLRO, the employee completing the identity verification procedure will conclude by ensuring that the client is not the target of any penalties or other legal actions. These include asking direct questions of the potential client, screening all new clients against databases and sanctions (by using a commercially available product or by directly referencing an official list), and continuously screening all client names (through automatic uploads and ongoing subscriptions to commercially available products).

15.8.6. Adverse Media
In addition to PEP databases and sanctions, third-party services screen people for negative publicity. Such a service is used by Betbarter to determine whether a customer has been linked by the media to financial crime, financing of terrorism, or other illegal behavior. After being verified as one and the same by the media and BETBARTER users, these people would only be permitted to use Betbarter services following a thorough examination by the MLRO and/or senior management.

15.9. Anti-Bribery and Whistleblowing
Betbarter uses anti-bribery and whistleblowing policies and procedures in addition to AML/CFT activities. These are stand-alone documents that are part of the onboarding package and are accessible to all employees.

15.10. Background checks on employees
In order to ensure that it can be confident in the honesty of every new hire and, consequently, in their propensity to adhere to Betbarter rules and processes, the company is dedicated to establishing and maintaining procedures. In order to comply with this obligation, the Human Resource Department must complete all of the stated checks on new hires and keep the relevant documentation:

If needed, get and validate references;
Verify their previous job history and credentials;
Obtain a certificate of recent police conduct;
Find out what regulatory action(s) have been taken against them.

16. Deception
If a customer engages in fraud, dishonesty, or other illegal activity, we will pursue criminal and contractual repercussions against them. If any of these are suspected, we will not pay that customer. In the event that the Customer engages in fraud, dishonesty, or other criminal activity, we will be held harmless, and the Customer will be responsible for paying any costs, charges, or losses that we suffer or incur (including any direct, indirect, or consequential losses, loss of profit, loss of business, and loss of reputation).

17. Responsible Gaming Policy
In addition to raising awareness of problem gambling and enhancing prevention, intervention, and treatment, Betbarter is dedicated to supporting responsible betting among its clientele.

In its Responsible Gambling Policy, Betbarter outlines its dedication to reducing the harmful consequences of compulsive gambling and to encouraging responsible gaming.

With a variety of games and entertainment options, Betbarter caters to the next generation of online gamblers. We also accept accountability for our range of products.

The mission of Betbarter is to offer the most cutting-edge and secure adult gambling platform available worldwide. With the help of the provided secure and transparent goods, every user may get the best possible service while staying within their means. Honesty, equity, and dependability serve as the cornerstones of Betbarter’s work. Therefore, it is obvious that Betbarter should make every effort to prevent and minimize the issues that may result from engaging in gambling, especially when playing excessively. In addition, it’s critical to uphold the legal rights of those who use games of chance as a moderate form of amusement.

At Betbarter, responsible gaming is founded on three essential tenets: player security, game security, and addiction prevention. We collaborate with organizations, research centers, and therapeutic facilities to develop a responsible, trustworthy, and safe online gaming environment.

Player security

We accept responsibility for the safety of our players. The protection of the players is based on prohibiting children from participating in games and protecting privacy, which includes the appropriate handling of personal data and payments. Independent groups regularly check the fairness and randomness of the items given. Marketing communication is likewise aimed toward player protection: we promise just what we can deliver in our transparent line.

Protection against gaming addiction: research – prevention – intervention

The majority of people who place sports bets, casino bets, and other gambling offerings do it in moderation for fun. Certain routines and behavior patterns (such as shopping, playing sports, eating, or drinking alcohol) that are thought to be normal and unproblematic might evolve into addictions for certain people and create issues. Similarly, sports betting and gambling can cause issues for a tiny number of clients.

Clients with a gaming addiction are barred from continuing involvement in the gaming line-up. Customers are then given contact information for organizations that can provide expert guidance and support.

Self-responsibility is the most sustainable form of prevention

The primary premise supported by Betbarter is that the client should make the ultimate decision and take responsibility for whether or not to participate, as well as how much money may be spent on the game.

As a result, the most effective type of addiction prevention is the customer’s own responsibility. Betbarter sees its job as aiding clients by offering transparent goods, complete information, and maintaining a clear code of behavior.

Responsibility towards problems

Betbarter provides a wide range of games and bets, which are popular forms of enjoyment among most consumers. At the same time, the corporation accepts responsibility for its consumers by offering assistance and resources for maintaining a safe and enjoyable environment while taking into consideration the inherent risks.

Clients that struggle with risk assessment, self-awareness, or gambling addiction are unable to enjoy our product range responsibly and consider it as a kind of fun. Betbarter accepts responsibility for such users and restricts their access to its goods for their own safety.

Get informed about the major concerns.

Most individuals play for enjoyment. Moderate engagement in games within their financial means is perfectly appropriate. However, for a tiny minority of people, gambling is not a source of amusement, but rather a task that must be taken seriously.

What is the problematic gaming behavior?

A problematic game habit is defined as any conduct that interferes with a person’s or family’s way of life, employment, financial situation, or health. Long-term engagement in games is uncharacteristic of such a person and can have harmful implications.

Pathological gaming dependency was formally recognized and categorized as a psychiatric disorder in the international categorization systems DSM-IV and ICD-10 in 1980. It is characterized as a lengthy, repeated, and frequently amplified desire to play despite existing bad personal and societal situations, such as a debt, a breakdown in family relationships, and a delay in professional development.

In what circumstances should a person’s behavior be deemed dependence?

It should be noted that diagnoses of gaming dependency can only be qualified by professionals. The information offered on this website will assist you in estimating and defining your own gaming behavior.

The unique risk of addictions that are not linked to any drug is that it is extremely difficult to distinguish between pleasure and addiction. Nonetheless, there are various diagnostic indications that might hint at existing issues. The presence of at least five of the following symptoms indicates a significant chance of serious dependence:

1. The player is heavily infatuated with gambling, and the game consumes all of his thoughts;
2. Over time, the wager amount rises;
3. It seems that his attempts to stop playing the games or limit his involvement have failed;
4. A person feels irritated and disappointed when he limits his gambling activities;
5. You can escape from troubles or pain by playing the game;
6. The player attempts to recoup the sum they lost;
7. Lie about how he played;
8. Engages in unlawful activity;
9. Damages or destroys relationships with family and coworkers;
10. Borrows money to play the games.

18. Guidelines for Appropriate Gaming
If you follow the rules given below, you can play the game without experiencing any anxiety:

1. Only begin to play when you are focused and at ease;
2. Take frequent pauses;
3. Determine how much you can afford to spend each month on the game in advance;
4. After establishing a maximum restriction, don’t raise it again;
5. Establish the maximum winning amount before you begin, since this will indicate when you should quit;
6. Determine how much you can afford to lose in advance;
7. Never begin playing while under the influence of drugs or alcohol;
8. Avoid starting a game when you’re depressed;
18. Copyright.

The Betbarter name and logo are registered trademarks, and we do business as Betbarter. If you use our trademark and logo without permission, you risk having legal action taken against you.

We are the owners of the unified resource locator (URL) www.betbarter.com. Unauthorized use of the URL on any other website or digital platform is prohibited without our prior written approval.

The rights in and to the Service, our technology, software, and business processes (collectively, the “Systems”), as well as our odds, belong exclusively to us.

It is prohibited for you to utilize your personal profile for profit (e.g., selling your status update to an advertisement). Additionally, if you choose a pseudonym for your account, we have the right to take it down or recover it at our discretion. You are not permitted to use our URL, trademarks, trade names, trade dress, logos, and/or odds (collectively, the “Marks”) in connection with any non-Original Product or Service, that in any way might mislead Customers or the public, or that in any way disparages us.

We and our licensors do not give you any explicit or implied rights, license, title, or interest in or to the Systems or the Marks, except as expressly stated in these Terms. All such rights, license, title, and interest are expressly reserved by us and our licensors. You acknowledge that you will not monitor or copy web pages or material from the Service using any kind of equipment, automated or manual. You might face legal repercussions for any unauthorized use or duplication.

19. Your License
Subject to these conditions and your adherence with them, we provide you a non-exclusive, restricted, non-transferable, and non-sublicensable license to access and use the Service for personal, non-commercial use solely. Our license to you expires if our arrangement with you under these Terms is terminated.

Except for your personal material, you may not alter, release, transmit, transfer, sell, reproduce, upload, post, distribute, perform, display, create derivative works from, or otherwise exploit the service and/or any of its content or software, except as expressly permitted in these terms or elsewhere on the website. No data or materials on the Service or made accessible to you associated with the Service may be modified or altered, merged with other data, or published in any form, including screen or database scraping and any other activity aimed at collecting, storing, reorganizing, or manipulating such information or content.

Any violation of this Clause may also constitute an infringement of our or third parties’ intellectual property and other proprietary rights, exposing you to legal liability and/or criminal prosecution.

20. Conduct and Safety
We want you to appreciate the service. However, for your and other Customers’ protection, publishing any content on the service, as well as conduct in connection with it and/or the service, that is illegal, unsuitable, or unwanted, is absolutely banned – it is banned Behaviour. If you participate in Prohibited Behaviour, or if we believe you are engaging in Prohibited Behaviour, your betbarter.com Account and/or access to or use of the Service may be canceled immediately and without notice to you.

Another Customer, a third party, enforcement agencies, or we may take legal action against you for engaging in Prohibited Behaviour.

Prohibited Behaviour includes accessing or using the Service to:

i. disseminate or distribute information that you know to be inaccurate, deceptive, or illegal; ii. engage in any unlawful or illegal activity, including but not limited to any activity that supports or encourages criminal activity or enterprise; iii. violate the privacy or other rights of another customer or third party; iv. inflict harm on minors; v. transmit or make available any content that is unlawful, harmful, threatening, abusive, tortuous, defamatory, vulgar, obscene, lewd, violent, hateful, or racially or ethnically objectionable;
v. transmit or make accessible any content—including without limitation, material that violates a third party’s copyright, trademark, or other intellectual property and proprietary rights—that the user is not authorized to make available under any legal, contractual, or fiduciary connection;
vi. distribute or make accessible any content or material containing any computer virus or other programming code, including HTML, intended to obstruct, damage, or change the way the Service functions, how it is presented, or how any other website, piece of hardware, or software operates;
vii. interfere, disrupt, or reverse engineer the service in any way, including, but not limited to, intercepting, emulating, or redirecting the communication protocols that we use; viii. use any robot, spider, or other automated mechanism to retrieve or index any information from the service; viii. create or use cheats, mods, or hacks, or any other software intended to modify the service;
ix. take part in any conduct or action that, in our sole and absolute judgment, causes another Customer to be duped or threatened with deception;
x. use any automated system to create betbarter.com accounts or operate under false or fraudulent pretenses; xi. impersonate a different client or third party; xii. transmit or make available any unsolicited or unauthorized advertising or mass mailing, including but not limited to junk mail, instant messaging, “spim,” “spam,” chain letters, pyramid schemes, or other forms of solicitations; xii.

The list of prohibited behaviors above is not all-inclusive, and we reserve the right to change it at any moment. Please get in touch with us via the website’s “Contact Us” area if you learn that another customer or anybody else is abusing the service. In the event that a customer or third party engages in, or knowingly permits any third party to engage in, Prohibited Behavior, with or without notice to the customer or third party, we reserve the right to investigate and to take any and all actions that we, in our sole discretion, deem appropriate or necessary under the circumstances. This includes, without limitation, deleting the customer’s posting(s) from the Service and/or terminating their account.

21. Links to Other Websites
Links to external websites that are not owned by, affiliated with, or under our control may appear on the Service. Links to these websites are just offered to customers for their convenience; we do not examine, monitor, or verify the authenticity or completeness of the information on these links in any manner. Links to these websites do not indicate that we support, condone, or have any association with the linked websites, their owners, or their content. Regarding their availability, correctness, completeness, accessibility, and utility, we have no control or liability. As a result, we advise you to use these websites with caution, following standard procedures when visiting a new website, such as checking the terms of use and privacy statement.

22. Self-exclusion
Consumers are free to self-unsubscribe from [email protected]. These inquiries must be submitted to [email protected] using the customer’s registered email address. Customers who wish to request self-exclusion must submit a written request together with a copy of their identity document and a picture. Please fill out and email us this form:

Download Form
Note that self-exclusion does not need to last longer than five years, although it can go for as long as one wishes.

Additionally, customers may place restrictions on how much they can risk and lose. Such a request must be addressed to [email protected] using the customer’s registered email address. Implementing and raising limits will be handled carefully; however, requests to remove or reduce limitations must wait seven days after the original request to allow for a cooling-off period.

Your Account cannot be pledged, sold, or transferred to another individual. The transfer of any valuable assets, including but not limited to ownership of accounts, winnings, deposits, bets, and any rights or claims associated with these assets—whether legal, commercial, or otherwise—is prohibited. In addition, but not limited to, the aforementioned transfers are prohibited in any way by the encumbrance, pledging, assigning, usufruct, trading, brokering, hypothecation, and/or gifting in conjunction with a fiduciary or any other third party, company, natural or legal individual, foundation, and/or association.

Please write an email to [email protected] using your registered email address if you would want to cancel your account.

What occurs if one excludes oneself?

You may still log in and take out any money that’s left in your account during a Self-Exclusion period, but you won’t be able to use it for betting. Your account cannot be opened again for any reason, and betbarter will make every effort to identify and terminate any further accounts you might create.

Next actions

We’ll take you out of our marketing databases, but before that, we advise you to uninstall/delete any Betbarter downloads, applications, and social network connections, as well as remove Betbarter from your alerts. For further information, go here. You might also want to think about installing software that prevents access to websites that provide gambling.

To aid you with your issue, we advise that you get assistance from a problem gambling support service.

By selecting Self-Exclusion in the Members area of My Gambling Controls, you can self-exclude your account.

As an alternative, you may get help and more details by getting in touch with our customer service staff.

Notice of Self-Exclusion

If you want to self-exclude from Betbarter, we highly advise you to request exclusion from any other online gaming providers with whom you are registered.

In case you feel that gambling has become an overwhelming influence in your life or the life of someone else, please get in touch with a service like Fundashon pa Maneho di Adikshon (Tel: +599 9 461-5977, WhatsApp: +599 9 670-5544).

23. Complaints
Please send an email to [email protected] to reach our Customer Service Department with any questions or complaints you may have about these terms.

Despite the aforementioned, we disclaim all liability to you or any other person for our response to any complaints we receive or actions we take in connection with them.

Customers of the Service should use their registered email address to contact our Customer Service Department at [email protected] with any questions or issues they may have about these Terms or the settlement of any betbarter.com market.

Customers may write our Customer Service Department at [email protected] with the specifics of their issue if they are unhappy with how a bet was handled. We will make every effort to reply to inquiries of this kind in a few days.

Disputes need to be filed no later than three (3) days following the decision on the particular wager. Thereafter, no claims will be honored. All transactions on the Customer’s account are their responsibility alone. Disputes and complaints must be made from the customer’s registered email address to [email protected].

Should a disagreement arise between you and us, our Customer Service Department will make an effort to come to a mutually acceptable resolution. In the event that our Customer Service Department is unable to resolve the issue with you, it will be brought to the attention of our management in line with our Complaints Procedure, which is accessible upon request.

If the customer is not satisfied with the resolution of a problem, they have the option to file a complaint with one of our licensing authorities.

24. Registration and Account Security
Users of the service are required to give their true identities and contact details. In addition, all users are required to abide by the following guidelines while creating and keeping an account:

I. You must not create an Account for anyone other than yourself or provide false personal information on the Service. ii. You must not use your personal profile for commercial gain (e.g., selling your status update to an advertiser). iii. If you choose to give your Account a nickname, we reserve the right to remove or reclaim it if we think it is appropriate.
25. Assignment
You may not assign these conditions or any rights or duties under them without our prior written agreement, which we may withhold without justification. If a third party is able to offer a service that is at least somewhat comparable to the Service, we may transfer all or any portion of our rights and duties under this Agreement to them without your approval by publishing a written notice to that effect on the Service.

26. Severability
To the extent permitted by applicable law, and in accordance with the original text’s intention, any provision of these conditions that is found to be unenforceable or invalid by a competent authority will be changed to that effect. None of these terms’ other sections will be rendered invalid or unenforceable.

27. Breach of These Terms
If, in our reasonable view, you violate any substantial condition of these Terms, we may, without limiting our other remedies, suspend or terminate your account and refuse to continue providing you with the service, in any event without providing you with prior notice. You will, however, be notified as soon as any such action is taken.

28. Governing Law and Jurisdiction
The laws of Curacao shall exclusively control, be interpreted, and be construed in relation to this Agreement. Arbitration will be used to settle any disagreements, complaints, etc. under Curacao. Following proper approval from both the user and the corporation, the arbitrator will be chosen by the latter. Curacao will serve as the arbitration location.

29. General Provisions
Duration of the contract. For as long as you are a customer of betbarter.com or access or use the service, these conditions will be fully enforceable. Should your betbarter.com account be terminated for any reason, these conditions will still be in effect.

Gender. Words bringing in the masculine gender must encompass the feminine and neuter genders and vice versa; words importing the singular number shall include the plural and inversely vice versa; and phrases bringing in persons must include people, partnerships, associations, trusts, unincorporated organizations, and corporations.

Waiver. If we waive any term or condition of these Terms, it will only be effective against us and binding upon us if it is made in writing and duly signed by us. Unless otherwise specified in the written waiver, it will only apply to the specific breach that we have waived. This applies to both conduct and other forms of waiver. Any term or condition of these Terms that we fail to enforce at any point shall not be interpreted as a waiver of that provision or of our right to enforce it at a later date.

Headings. The division of these Terms into paragraphs and subparagraphs, as well as the inclusion of headers, are for reference purposes only and have no bearing on the construction or interpretation of this Terms agreement. The phrases “these Terms,” “hereof,” “hereunder,” and similar expressions relate to these Terms rather than any specific paragraph, sub-paragraph, or other component of this document, and include any additional agreements hereto. Unless the subject matter or context indicates otherwise, references to paragraphs and subparagraphs in this document relate to paragraphs and subparagraphs of these Terms.

Acknowledgement. By accessing or using the Service, you indicate that you have read, understood, and agreed to each and every paragraph of these Terms. As a result, you irrevocably waive any future dispute, claim, demand, or proceeding adverse to anything stated in these Terms.

Language. If there is a conflict between the English language version of these rules and another language version, the English language version shall be considered correct.

Restricted countries. Betbarter is one of the world’s largest and most well-known bookmakers, however it does not operate in every nation owing to regulatory limitations. As a result, our service is limited to the following countries: Australia, Austria, Belgium, Bulgaria, Brunei, Cambodia, China, Croatia, Cyprus, Denmark, Dutch West Indies, Estonia, Finland, France, Georgia, Germany, Italy, Japan, Lebanon, North Korea, Panama, Poland, Qatar, Romania, Singapore, Spain, Sri Lanka, the Netherlands, the United Kingdom, Turkey, the United Arab Emirates, and the United States.

Complete agreement. These Terms comprise the complete agreement between you and us regarding your access to and use of the Service, and supersede all earlier agreements and communications, whether oral or written, with respect to the subject matter hereof.

Betting RulesAny disagreement over the sports betting product should be directed to: [email protected].

Casino Rules: Any problem regarding the casino product must be directed to [email protected].

Accepting the terms and conditions.

You hereby acknowledge that you have read, understood, and agree to abide by the Terms & Conditions listed above.