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AML Policy

NBG Ltd  |  Last updated: 06 June 2025

For Deposits and Withdrawals.

Bluebird10.com is operated by NBG Ltd., having its office at International Business Companies of the Autonomous Island of Anjouan, Union of Comoros. Company Registration number: 15762.

Objective of the AML Policy

We seek to offer the highest security to all of our users and customers on Bluebird10.com. A three-step account verification is done in order to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering.

Bluebird10.com also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

Bluebird10.com is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of Bluebird10.com is designed to be compliant with:

Definition of Money Laundering

Money Laundering is understood as:

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for Bluebird10.com

In accordance with the AML legislation, Bluebird10.com has appointed the "highest level" for the prevention of ML: The full management of NBG Ltd are in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System. The AMLCO is placed under the direct responsibility of the general Management.

AML Policy Changes and Implementation Requirements

Each major change of Bluebird10.com AML policy is subject to approval by the general management of NBG Ltd and the Anti Money Laundering Compliance Officer.

Three Step Verification

Step One Verification

Step one verification must be done by every user and customer to withdraw, regardless of the choice of payment, the amount of payment, the amount of withdrawal, or nationality. Step one verification is a document that must be filled out by the user/customer. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender and full address.

Step Two Verification

Step two verification must be done by every user who deposits over 2,000 EUR or withdraws any amount. Until step two verification is done the withdrawal, tip or deposit will be held. Step two verification will lead the user or customer to a subpage where they must send in their ID. The user must make a picture of their ID with a paperclip showing a six-digit random generated number next to the ID. Only an official ID may be used for ID verification.

There will also be an electronic check if the filled-in data from step one verification is correct. If the electronic test fails or is not possible, the user/customer is required to send in a confirmation of their current residence (a certificate of registration by the government or a similar document).

Step Three Verification

Step three verification must be done by every user who deposits over $5,000, withdraws over $5,000, or sends another user over $3,000. Until step three verification is done the withdrawal, tip or deposit will be held. For step 3, a user/customer will be asked for a source of wealth.

Customer Identification and Verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture.

Please note that all four corners of the ID have to be visible in the same image and all details have to be clearly readable. We might ask for all details if necessary.

Proof of Address

Proof of address will be done via two different electronic checks. If an electronic test fails, the user/customer has the option to make a manual proof.

A recent utility bill sent to your registered address, issued within the last 3 months, or an official document made by the government that proves your state of residence. Please make sure the document is sent with a clear resolution where all four corners of the document are visible and all text is readable.

For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.

Source of Funds

If a player deposits over five thousand euro there is a process of understanding the source of wealth (SOW). Examples of SOW are:

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or proof.

The account will be frozen if the same user deposits this amount in one go or through multiple transactions which amount to this. An email will be sent to them to go through the above process.

Bluebird10.com also asks for a bank wire/credit card to further ensure the identity of the user/customer.

Basic Document for Step One

The basic document will be accessible via the settings page on Bluebird10.com. Every user has to fill out the following information:

The document will be saved and created by an AI; an employee may do additional checks if necessary based on the situation.

Risk Management

In order to deal with the different risks and different states of wealth in different regions, Bluebird10.com will categorize every nation in three different regions of risk.

Region One: Low Risk

For every nation from region one, the three-step verification is done as described above.

Region Two: Medium Risk

For every nation from region two, the three-step verification will be done at lower deposit, withdrawal and tip amounts. Step one will be done as usual. Step two will be done after depositing $1,000, withdrawing $1,000, or tipping another user $500. Step three will be done after depositing $2,500, withdrawing $2,500, or tipping another user $1,000. Also, users from a low risk region that change cryptocurrency to any other currency will be treated like users from a medium risk region.

Region Three: High Risk

Regions of high risk will be banned. High risk regions will be regularly updated to keep up with the changing environment.

Additional Measurements

An AI overseen by the AML compliance officer will look for any unusual behaviour and report it right away to an employee of Bluebird10.com.

A data scientist supported by modern electronic analytic systems will look for unusual behaviour like: depositing and withdrawing without longer betting sessions; attempts to use a different bank account for deposit and withdrawal; nationality changes, currency changes, behaviour and activity changes; and checks if an account is used by its original owner.

A user must use the same method for withdrawal as used for deposit, for the amount of the initial deposit, to prevent any money laundering.

Enterprise-wide Risk Assessment

As part of its risk-based approach, Bluebird10.com has conducted an AML "Enterprise-wide risk assessment" (EWRA) to identify and understand risks specific to Bluebird10.com and its business lines. The EWRA is yearly reassessed.

Ongoing Transaction Monitoring

AML-Compliance ensures that an "ongoing transaction monitoring" is conducted to detect transactions which are unusual or suspicious compared to the customer profile. This transaction monitoring is conducted on two levels:

1) The first Line of Control:
Bluebird10.com works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the large majority of suspicious deposits from taking place without proper execution of KYC procedures.

2) The second Line of Control:
Bluebird10.com makes its network aware so that any contact with the customer or player must give rise to the exercise of due diligence on transactions on the account concerned. All transactions must be overseen by employees, overseen by the AML compliance officer, who is overseen by the general management.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.

3) The third Line of Control:
As a last line of defence against AML, Bluebird10.com will do manual checks on all suspicious and higher risk users in order to fully prevent money laundering. If fraud or money laundering is found, the authorities will be informed.

Reporting of Suspicious Transactions

In its internal procedures, Bluebird10.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analysed within the AML team. Depending on the result of this examination, the AML team will decide whether it is necessary to send a report to the FIU in accordance with the legal obligations provided in the Law of 18 September 2017, and whether or not it is necessary to terminate the business relations with the customer.

Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the intranet site of Bluebird10.com.

Record Keeping

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended. Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship. These data will be safely, encrypted, stored offline and online.

Training

Bluebird10.com human employees will make manual controls on a risk-based approach for which they receive special training. The training program includes:

These sessions are given by an AML-specialist working in NBG Ltd.'s AML team.

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security

All data given by any user/customer will be kept secure and will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering, may data be shared with the AML authority of the affected state.

Bluebird10.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC).

Contact Us

If you have any questions or complaints about our AML and KYC Policy, or about the checks done on your Account, please contact us: