AML and CTF program summary.
MarantelliBet Partnership is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the Act) and operates its AML/CTF program in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) (the AML/CTF Rules), including the Customer Identification Rules contained therein. The program is approved at the board level and reviewed at least annually.
Designated services and customer types
The wagering services provided by MarantelliBet Partnership constitute designated services within the meaning of Table 1, section 6 of the Act (including, without limitation, Items 50 and 56 relating to the acceptance of bets and the payment of winnings). Customers served are natural persons ordinarily resident in Australia who have satisfied identification and verification requirements.
Regulator and reporting
The Australian Transaction Reports and Analysis Centre (AUSTRAC) is the regulator to which the operator reports. Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs) and International Funds Transfer Instructions (IFTIs) are lodged via AUSTRAC Online in accordance with the statutory timeframes prescribed by the Act and the AML/CTF Rules.
Risk-based approach
A documented money laundering and terrorism financing (ML/TF) risk assessment is maintained and informs the design, calibration and operation of preventative controls. The assessment considers customer type, delivery channel, geography and product features, and is refreshed on a periodic basis and upon material change.
Customer due diligence
Each customer is identified and verified before any wager is accepted, in accordance with the Customer Identification Rules. Enhanced due diligence is applied where risk indicators are present. Ongoing customer due diligence (OCDD) is conducted throughout the customer relationship, including transaction monitoring, periodic review of customer information and re-verification where required.
Politically Exposed Persons
Politically Exposed Persons (PEPs) are screened at onboarding and on an ongoing basis. Foreign PEPs are treated as high risk; domestic and international organisation PEPs are assessed on a risk-sensitive basis. Senior management approval is obtained before establishing or continuing a business relationship with a PEP.
Sanctions screening
Prospective and existing customers are screened against the Department of Foreign Affairs and Trade (DFAT) Consolidated List and applicable United Nations Security Council sanctions lists. Screening obligations arise under the Autonomous Sanctions Act 2011 (Cth) and the Charter of the United Nations Act 1945 (Cth). Matches are escalated, frozen where required and reported in accordance with law.
Transaction monitoring
Wagering and payment activity is monitored against published typologies and internal risk indicators. Matters meeting reporting thresholds or suspicion criteria are escalated for assessment and lodgement.
Record-keeping
Identity records, transaction records and AML/CTF program records are retained for the period required by the Act and by the Financial Transaction Reports Act 1988 (Cth) where applicable.
Source of funds
Funding via consumer credit is restricted under the Interactive Gambling Amendment (Credit and Other Measures) Act 2023. Cryptocurrency and third-party payment instruments are not accepted.
Senior management and Compliance Officer
A named AML/CTF Compliance Officer of sufficient seniority and independence is appointed and reports to the board. The board retains ultimate accountability for the AML/CTF program and approves material policies and the risk assessment.
Staff training
All relevant personnel complete AML/CTF training at induction and an annual refresher thereafter, with role-specific modules for staff in higher-risk functions. Training records are retained.
Independent review
The AML/CTF program is subject to periodic independent review by a qualified party external to the day-to-day operation of the program. Findings and remediation are reported to the board.
International information sharing
Where lawful and appropriate, information is shared with AUSTRAC counterparts and foreign regulators under information-sharing arrangements and gateways permitted by the Act, including in support of cross-border investigations.
Related legislation
The program is administered with regard to related Commonwealth laws, including the Criminal Code Act 1995 (Cth) (in particular the money laundering offences in Division 400), the Financial Transaction Reports Act 1988 (Cth), the Autonomous Sanctions Act 2011 (Cth) and the Charter of the United Nations Act 1945 (Cth).
Interaction with the Privacy Act 1988 (Cth)
Personal information is handled in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Where a disclosure obligation under the Act or the AML/CTF Rules conflicts with the Privacy Act, the AML/CTF disclosure obligation prevails to the extent of the inconsistency.
Operated by MarantelliBet Partnership (ABN 98 032 757 426). Sports Bookmaker Licence VIC-BM-2022-0661 granted by the Victorian Gambling and Casino Control Commission. Registered office: 144 Hildebrand Road, COTTLES BRIDGE VIC 3099. Contact: support@marantellbet.com.
