
Comprehensive AML/CFT/CPF Compliance Framework
Diamond Card Limited, operating the GhScratch.com platform under exclusive license by LaPalm Casino (Gaming Commission License Number: GCRO20A7314H), is unequivocally committed to maintaining the highest standards of integrity in combating money laundering, terrorist financing, and proliferation financing activities.
This Anti-Money Laundering, Counter-Terrorist Financing, and Counter-Proliferation Financing Policy ("AML/CFT/CPF Policy") establishes our comprehensive framework for preventing the misuse of our gaming platform and payment systems for illicit financial activities.
We maintain a zero-tolerance approach to money laundering and terrorist financing. We will:
This Policy is implemented in compliance with:
This Policy applies to:
MANDATORY COMPLIANCE: All persons subject to this Policy must comply fully with its requirements. Failure to comply may result in disciplinary action, termination of employment or business relationship, civil penalties, and criminal prosecution. Non-compliance exposes individuals and the Company to significant legal, financial, and reputational risks.
The Board of Directors of Diamond Card Limited has ultimate responsibility for AML/CFT/CPF compliance. Day-to-day implementation is overseen by:
For the purposes of this Policy, the following terms have the meanings set forth below:
Money Laundering means the process by which the proceeds of crime are transformed into ostensibly legitimate assets. It involves concealing the source, ownership, or control of illegally obtained funds and converting them into assets that appear to have a legitimate origin.
The physical disposal of bulk cash proceeds derived from illegal activity. This may involve:
Separating illicit proceeds from their source through complex layers of financial transactions designed to obscure the audit trail and provide anonymity. This may include:
Providing apparent legitimacy to criminally derived wealth. This involves:
Terrorist Financing means the provision or collection of funds, by any means, directly or indirectly, with the intention or knowledge that they will be used, in full or in part:
Key Distinction: Unlike money laundering, terrorist financing may involve funds from legitimate sources. The focus is on the intended use of funds rather than their origin.
Proliferation Financing means the act of providing funds or financial services for use, in whole or in part, for the manufacture, acquisition, possession, development, export, transshipment, brokering, transport, transfer, stockpiling, or use of nuclear, chemical, or biological weapons and their means of delivery and related materials (including technologies and dual-use goods used for non-legitimate purposes).
Predicate Offences (also called "underlying crimes") are the crimes that generate proceeds which may subsequently be laundered. These include but are not limited to:
Individuals who are or have been entrusted with prominent public functions, either domestically or internationally, including:
The natural person(s) who ultimately owns, controls, or benefits from a legal entity or arrangement, or on whose behalf a transaction is conducted. This includes:
A company without active business operations or significant assets, often used to conceal beneficial ownership.
The process of identifying and verifying the identity of customers and assessing the risks they pose.
Additional due diligence measures applied to higher-risk customers, transactions, or business relationships.
Reduced due diligence measures permitted for lower-risk situations (rarely applicable in gaming).
The process of verifying the identity of customers and understanding their financial activities.
A report filed with the Financial Intelligence Centre (FIC) when there are reasonable grounds to suspect that a transaction involves proceeds of crime or terrorist financing.
A report filed for cash transactions exceeding specified thresholds.
Reports required for transactions exceeding specified monetary limits.
The prohibited act of disclosing to any person that a STR has been made, or that an investigation is being or may be conducted.
A systematic methodology whereby resources are allocated according to identified risks, with higher-risk areas receiving more intensive controls and lower-risk areas receiving proportionate controls.
Ghana's financial intelligence unit responsible for receiving, analyzing, and disseminating suspicious transaction reports and other financial intelligence to law enforcement and regulatory authorities.
We conduct Customer Due Diligence on all customers before establishing a business relationship or conducting occasional transactions above specified thresholds. CDD consists of four core elements:
We collect the following information from all customers during registration:
| Information Type | Required Data | Purpose |
|---|---|---|
| Personal Identity | Full legal name, Date of birth, Gender, Nationality | Establish identity and verify age (18+) |
| Contact Details | Residential address, Email address, Mobile phone number | Enable communication and verification |
| Financial Information | Mobile money account number, Payment method details | Process transactions and verify ownership |
| Identification Documents | Government-issued ID (Ghana Card, Passport, Driver's License) | Verify identity (required for enhanced verification) |
| Photographic Verification | Selfie photograph, Liveness detection | Match against ID document (when required) |
We verify customer identity through a multi-layered approach:
Primary Verification (All Customers):
Enhanced Verification (Triggered Automatically):
Required when any of the following thresholds or conditions are met:
Enhanced Verification Requirements:
We assess and document:
CDD is not a one-time process. We continuously monitor customer relationships to:
CDD must be completed:
If we cannot complete CDD to a satisfactory standard, we will:
IMPORTANT: We will not execute transactions or maintain accounts for customers who refuse to provide required information or documentation. This is a non-negotiable requirement under Ghana law and international standards.
We implement a comprehensive risk-based approach that allocates resources and applies controls proportionate to identified risks. Our methodology involves:
All customers are assigned a risk rating based on multiple risk factors. Risk categories are:
| Risk Level | Description | Controls Applied | Review Frequency |
|---|---|---|---|
| LOW RISK | Customers presenting minimal ML/TF/PF risk based on comprehensive assessment | Standard CDD, Automated monitoring | Annual review |
| MEDIUM RISK | Customers presenting moderate ML/TF/PF risk requiring enhanced attention | Enhanced monitoring, Periodic manual reviews | Semi-annual review |
| HIGH RISK | Customers presenting significant ML/TF/PF risk requiring intensive oversight | Enhanced Due Diligence, Senior management approval, Continuous monitoring | Quarterly review (minimum) |
| PROHIBITED | Customers we cannot do business with due to unacceptable risk or legal restrictions | Account blocked, No transactions permitted | N/A - Relationship terminated |
Customer risk is determined by evaluating the following factors:
Our systems automatically calculate a composite risk score (0-100) based on weighted factors:
DISCRETIONARY OVERRIDE: The MLRO or senior management may override automated risk scores based on professional judgment and additional information. All overrides must be documented with clear justification.
Enhanced Due Diligence must be applied to all high-risk customers and in the following circumstances:
Enhanced Due Diligence includes, but is not limited to, the following additional measures:
All high-risk customer relationships require approval from senior management before:
PEPs - SPECIAL REQUIREMENTS: For Politically Exposed Persons and their family members/close associates, we must:
Following EDD assessment, one of the following decisions will be made:
We deploy automated transaction monitoring systems that:
Our systems are programmed to detect the following suspicious patterns:
When monitoring systems generate alerts:
We have established the following transaction thresholds:
| Threshold Type | Amount (GH₵) | Action Required |
|---|---|---|
| Single Deposit | 2,000 | Automated alert for review |
| Single Withdrawal | 2,000 | Manual approval required |
| Daily Cumulative | 5,000 | Enhanced monitoring activated |
| Monthly Cumulative | 10,000 | Enhanced Due Diligence required |
| Cash Equivalent | 15,000 | Currency Transaction Report to FIC |
IMPORTANT: These thresholds are for internal monitoring only. Customers attempting to structure transactions to avoid these thresholds will be immediately flagged for investigation and potential STR filing.
Under the Anti-Money Laundering Act, 2020 (Act 1044), we are legally obligated to file a Suspicious Transaction Report (STR) with the Financial Intelligence Centre (FIC) when we know, suspect, or have reasonable grounds to suspect that:
LEGAL REQUIREMENT: Suspicious Transaction Reports must be filed within 24 hours of forming the suspicion. Failure to file or late filing is a criminal offense punishable by fines and imprisonment. The threshold for suspicion is LOW - "reasonable grounds to suspect" not "proof" or "certainty."
The following are red flag indicators that may warrant filing an STR:
Any employee who suspects suspicious activity must immediately report to the MLRO.
MLRO conducts preliminary assessment within 4 hours:
If preliminary assessment confirms suspicion, conduct detailed investigation:
MLRO determines whether to file STR based on:
If decision is to file, STR must include:
Filing Method: STRs are filed electronically through FIC's secure goAML portal within 24 hours of suspicion.
CRIMINAL OFFENSE: It is a serious criminal offense to disclose to any person (including the customer) that:
Penalty: Tipping off is punishable by imprisonment and/or substantial fines. Even unintentional disclosure can result in prosecution.
What This Means: You cannot tell the customer why their account is being reviewed, why a transaction is delayed, or that we have concerns about their activities. Use neutral explanations like "routine compliance review" or "additional verification required."
Under Ghana law, we and our employees are protected from civil and criminal liability when filing STRs in good faith:
Conversely: Failure to file STRs when required can result in severe penalties for both the institution and individuals.
In addition to STRs, we file Currency Transaction Reports (CTRs) for:
Note: While our platform uses mobile money (not physical cash), mobile money transactions may be treated as cash equivalents for reporting purposes.
Under the Anti-Money Laundering Act and Gaming Commission regulations, we must maintain comprehensive records for:
All records are:
We can retrieve records:
Records are destroyed only:
[Name and Title]
Diamond Card Limited
Accra, Ghana
Email: mlro@ghscratch.com
Phone: [To be provided]
24/7 Emergency Hotline: [To be provided]
Email: compliance@ghscratch.com
Phone: [To be provided]
Head Office
Accra, Ghana
Email: info@fic.gov.gh
Website: www.fic.gov.gh
goAML Portal: [Secure login required]
Accra, Ghana
Email: info@gamingcommission.gov.gh
Phone: [To be provided]
REPORTING SUSPICIOUS ACTIVITY: All employees and stakeholders have a duty to report suspicious activity to the MLRO immediately. Reports can be made confidentially 24/7 through the emergency hotline or email.
THIS POLICY WAS LAST UPDATED ON DECEMBER 22, 2024