EMTREE.LIVE
Compliance

AML Policy

Anti-money-laundering controls for payment activity, duplicate accounts, suspicious betting, withdrawals, and review escalation.

StatusDraft
MarketPH
ReviewLegal needed

Risk Signals

Track payment velocity, unusual deposits/withdrawals, duplicate accounts, risky devices, impossible travel, and suspicious play patterns.

Case Review

AML alerts must create a review case with user, payment, wallet, device, support, and game references.

Holds

Withdrawals can be held while compliance reviews payment-owner match, source, velocity, and suspicious activity.

Reporting

Any required regulatory reporting must be handled by qualified compliance staff and counsel.

01

Draft

Use this product draft to define operational requirements and missing data fields.

02

Review

Have Philippines gaming counsel, privacy counsel, and compliance owners review before launch.

03

Approve

Version the approved policy and connect it to registration, wallet, game, support, and admin flows.

04

Audit

Log player consent, admin actions, reviews, escalations, and policy-version changes.

Risk Review Matrix

SignalExamplesActionReal-Money Gate
Age/JurisdictionUnder 21, non-PH, KYC mismatchReject or restrictHard block
KYCFailed document, liveness mismatch, duplicate identityManual reviewHard block
AMLVelocity, structuring, duplicate accounts, unusual withdrawalsOpen AML caseHard block
DeviceVPN, proxy, impossible travel, new risky deviceChallenge or reviewSoft/hard block
Payment OwnerMaya/GCash name mismatchHold transactionHard block
Responsible GamingLimit reached, cool-off, self-exclusionRestrict play/marketingHard block
Launch Gate

Draft, not legal approval

This is an implementation and operations scaffold. Real-money launch still requires counsel-approved policies, licensing path, payment approval, KYC/AML readiness, and game certification.