PEP Policy

Last updated: 08/09/2023

Definition of a Politically Exposed Person (PEP)

  1. Politically exposed individuals (PEPs) encompass officials who hold prominent public positions, such as political offices or senior appointments. Given the nature of their roles and the influence they wield, the financial community ascribes a heightened risk to PEPs. This is due to the potential for their positions to be exploited, increasing the likelihood of exposure to corrupt practices, bribery, and money laundering.
  2. The terms "politically exposed person" and "senior foreign political figure" are frequently utilized interchangeably, especially within international forums. However, it is essential to note that there is currently no universally recognized global definition for the classification of a politically exposed person.
  3. The term "PEP" commonly denotes customers, whereas the designation of "foreign official" pertains to the potential risks associated with third-party relationships across all industries. It is crucial to understand that these two terms are not inherently synonymous and should not be conflated.
A crucial component of the PEP Policy entails the AML Policy. Emphasizing the utmost importance of financial integrity and security, the meticulously designed AML policy of ComicPlay Casino serves as a robust framework to detect, prevent, and combat money laundering activities. The AML program of ComicPlay Casino has been strategically formulated to ensure compliance with the following:
  • EU: "Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering."
  • EU: "Regulation 2015/847 on information accompanying transfers of funds."
  • EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods.
  • BE: "Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash."
ComicPlay Casino recognizes the vital importance of conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) screenings for entities operating within the Virtual Asset Service Providers (VASPs), Financial Institutions (FIs), and other sectors subject to international regulations governing AML implementation.

Adhering to these practices is of utmost importance in order to avoid substantial penalties and mitigate the potential for severe reputational damage resulting from any association with money laundering activities.

As a regulated business, ComicPlay Casino acknowledges the responsibility to diligently carry out ongoing screenings of sanctions lists and Politically Exposed Persons (PEP) data.

Of course, KYC is one of the main types of screening in the online gaming industry. With our commitment to regulatory compliance, you can enjoy your gaming experience while we take care of ensuring a secure and responsible environment.

Step one verification:

Step one verification must be done by every user themselves upon the registration on the ComicPlay Casino website. During this process, the user fills out the requested fields with information such as 1) email address, 2) first name, last name, gender, birth date, 3) country, zip code, city, state/province, phone number, currency, and address.

Step two verification:

Step two verification must be done by every user who has deposited over $2000 (two thousand dollars) or requested their first cashout. Until step two verification is done, the related cash-out or deposit transaction will be placed on hold.

Step two verification requires the scan copy or photo of the user’s ID documents, taken by the user and sent to the Company. Only an official ID can be used for ID verification. Depending on the country, the variety of accepted IDs may be different. The user needs to go through a deposit method confirmation too if the step-one-verification data is correct. The deposit method confirmation will be checked by two different data banks to ensure the given information matches the one provided on the first step of verification. If a mismatch of the information occurred, the user/customer is required to send in confirmation of their current residence: a recent utility bill, bank statement, or any other government-issued document under their registered name.

Step three verification:

Step three verification must be done by every user who has deposited over $5000 (five thousand dollars) or cashed out over $5000 (five thousand dollars). Until step three verification is done, the related cash-out or deposit transaction will be placed on hold. Step three verification requires users to reveal a source of wealth.


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

In order to complete the KYC procedure, we ask our users to upload a set of valid, unexpired identification documents, which includes a valid proof of identity (ID, passport, or driver’s license), proof of residence (a recent utility bill, bank statement, or any other government-issued document under the registered name), and a clear copy of the card(s) used for funding the account (as a deposit confirmation method). In addition, those users who want to request a cashout are asked to add a wire instruction from the bank (if they want to receive the funds via the Bank Wire) or a screenshot of the BTC Wallet (if they want to receive the funds via the crypto payment method).

Please note that the Casino employee can conduct additional checks if the situation requires so.
If a player deposits over $5000 (five thousand dollars), according to the above-mentioned information, we may ask for the source of wealth (SOW).

Examples of SOW are:

  • Ownership of business
  • Employment
  • Inheritance
  • Investment
  • Family
It is critical that the origin and legitimacy of that wealth are clearly understood. Please note that the Casino employee reserves the right to conduct additional checks and ask for additional documents if the situation requires so.

If the user deposits the amount of funds equivalent to $5000 either in one or multiple transactions, their account will be frozen until all the above-mentioned steps are successfully completed. The user will be notified via email.

Sanctions list

Sanctions lists encompass comprehensive references to individuals, businesses, jurisdictions, and other entities that have been flagged due to their involvement in criminal activities or being under suspicion thereof.

To ensure accuracy and reliability, this information undergoes meticulous verification against multiple government watchlists and sanctions lists meticulously maintained by law enforcement agencies, international regulatory bodies, and renowned multinational organizations, including but not limited to Interpol, the European Union (EU), the United States Office of Foreign Assets Control (OFAC), the United Nations (UN), Her Majesty’s Treasury (HMT), the Financial Action Task Force (FATF), and various other national and supra-national regulatory bodies.

Media check

The primary objective of these sanctions lists is to proactively prevent and detect illegal activities, combat terrorist financing, and mitigate any other activities deemed a threat to national security.

In addition to conducting Politically Exposed Person (PEP) and sanctions screenings, an equally impactful tool for comprehending the risk profiles of prospective customers or candidates involves performing adverse media searches using their names. Individuals or entities referenced in media content flagged as negative are assigned an elevated risk profile and flagged for subsequent review or enhanced due diligence (EDD).