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Diamond Card Limited is committed to keeping high standard of integrity in serving the gaming community and to that end will actively prevent and take measures to guard against its facilities being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

We also intend to prevent the misuse of our technological platform in money laundering or terrorist financing schemes such as internationally accepted credit or debit cards and mobile money payment platforms.

This page to inform you of our policy regarding customer risk assessment, capture suspicious transaction, cash transaction and report same to the appropriate Anti Money Laundering authorities and the maintenance of such records and reports.


Money Laundering: refer to the concealment of the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses. It is the process where the identity of the proceed of crime is so disguised that it gives an impression of legitimate income.

Stages of Money Laundering:
  • Placement – The movement of cash from its source and placing it in circulation through financial institutions, casinos, businesses, disguised shops, forex bureau, transfers both local and abroad, etc
  • Layering – This is meant to make the trailing of illegal proceeds difficult for the law enforcement agencies, making it difficult to detect and uncover laundering activity.
  • Integration – This is the movement of previously laundered money into the economy mainly through the banking system thus legitimizing it.

Terrorist Financing: is where a person intentionally uses, possesses or receives funds which they know, or suspend will be used for the purposes of terrorism. Terrorist may raise funds through legitimate means may also use techniques like those of money launderers to evade authorities’ attention and to protect the identity of their sponsors and of the ultimate beneficiary of the funds.

Proliferation: A person engaged by another person who knows or reasonably suspects that a property is for financing of proliferation of weapons of mass destruction.

Scratch & Win Card and Money Laundering.
  • This could be where a criminal uses the money he/she earns from drug dealing to buy a car or a house, or the criminal spends the money he/she gained in a bank robbery or the criminal spends funds that he/she has stolen from his/her employer to buy scratch & win card.
  • These offences can be committed by any person, including the operator and their employees, who have knowledge or suspicion that a customer is using the proceeds of crime to buy and play scratch and win cards.
Customer Risk Assessment
You may be categorized into high or low risk customer based on
  • Know Your Customer (KYC) process and outcome
  • Payment methods
  • Number of accounts
  • Number of mobile money wallet
  • Deposit cash into your account, buy no card and withdraw out
  • A customer provides false identity
  • A person below the age of 18years
  • Customer demanding transfer into another person’s account
  • Compromise with employee(s)
  • Attempt of cheating or tempering with website or data base

We reserve the right to delete/block your account and prevent you from playing the game if you are believed to be a high risk customer. Deletion/Blockage of your account implies that any amount of money in the account as of that time will be lost by you. We may file a suspicious report with the authorities.

Know Your Customer

You will be required to provide the following information to register and play the game of scratch and win:

  • Date of Birth
  • Gender
  • First name and last name
  • Email Address
  • Country
  • Phone number
  • Momo Number (Mobile Money Wallet)
  • User Name
  • Password
  • Picture (optional)

The information provided by you in addition to your transactional records shall for the register for the keeps as required by law.

Verification of Customer Identity

Being an online product, we verify your identity by authentication of the mobile number provided and registered on our platform by:

  • 1.     Receiving a code on Your mobile number upon submission of the information we requested and you supply
  • 2.     You are required to enter the Received Code into a form appearing on your screen
  • 3.     A successful entry will complete of the registration process and you will be notified as “Congratulations”.
  • 4.     An ID matched against the person physically present shall be required when a winner is to be paid a certain amount so indicated by the game.
Suspicious Transaction Activity

Suspicious activity may be the type of behaviour which may indicate an offence includes you buying card(s) and cashing in the winnings (converting), or someone placing cash into your account and not using it (concealing), or placing money in an account and someone else withdraws the funds (concealing, disguising, transferring).

Cash Transactions
Any movement of funds in cash exceeding the threshold applicable to game.

Suspicious Transaction Report

Where you suspected of a transaction to be linked to proceeds of crime, the Systems Manager shall make a report to Financial Intelligence Centre (FIC) within twenty-four hours (24hrs) of the suspicion.

The System Manager will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a Suspicious Transaction Report (STR).

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By emai: info@ghscratch.com