1. Purpose and Scope
1.1. This Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Compliance Policy (the "AML Policy") sets out the principles, controls and procedures applied by Forecast Harbor N.V. (the "Company") in connection with the operation of cambet.cc.
1.2. The AML Policy applies to all Traders, prospective Traders, beneficial owners, payment counterparties, market participants, liquidity providers and authorised users of the Website and Services.
1.3. The AML Policy is designed to ensure that the Company:
- does not knowingly facilitate money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion or other financial crime;
- complies with applicable laws, regulations, regulatory guidance and recommendations of the Financial Action Task Force (FATF) and equivalent regional bodies;
- maintains effective risk-based controls proportionate to the size, complexity and risk profile of its activities.
1.4. By using the Services on cambet.cc, you acknowledge that the Company applies this AML Policy and that you are bound by its provisions.
2. Regulatory Framework
2.1. CAMBET operates under the Digital Prediction Market Technology Certificate of Operation No. DPM-CO-2026-0419 issued by the Curaçao Digital Commerce Registry.
2.2. The Company applies controls aligned with, where applicable:
- the laws of Curaçao governing financial-services technology providers;
- the National Ordinance on the Reporting of Unusual Transactions and equivalent local regulations;
- the FATF Recommendations, in particular Recommendations 10, 11, 15, 16, 20 and 22;
- the Travel Rule, where the Company processes transfers of virtual assets above the applicable threshold;
- the sanctions regimes administered by the United Nations Security Council, the United States Office of Foreign Assets Control (OFAC), the European Union, the United Kingdom (OFSI) and any other jurisdiction whose sanctions are applicable to the Company or its counterparties.
3. Risk-Based Approach
3.1. CAMBET applies a risk-based approach to identify, assess, monitor and mitigate money-laundering, terrorist-financing, fraud and sanctions risks.
3.2. Customer, geographic, product and channel risk factors are evaluated and rated as low, medium or high. The applicable level of due diligence, monitoring intensity and approval authority is calibrated accordingly.
3.3. The Company periodically reviews its risk assessment to reflect changes in the business, customer base, product mix, threat landscape, regulatory expectations and external typologies.
4. Customer Due Diligence (CDD)
4.1. The Company performs customer due diligence on every Trader before granting full access to the Services, and on an ongoing basis throughout the business relationship.
4.2. CDD measures may include, where applicable:
- identifying the Trader and verifying identity using reliable, independent source documents, data or information;
- identifying the beneficial owner of the Trader and taking reasonable steps to verify their identity;
- understanding the purpose and intended nature of the business relationship;
- obtaining information on source of funds and, where appropriate, source of wealth;
- screening against sanctions, watchlists, politically exposed persons (PEP) lists and adverse media databases;
- conducting blockchain analytics on wallet addresses connected to CAMBET.
4.3. The Trader undertakes to provide accurate, complete and current information and supporting documents promptly upon request. Failure to do so may result in suspension, restriction or termination of the account.
4.4. Verification of identity may be performed by the Company directly or by approved third-party identity-verification providers, including but not limited to VeriGate Compliance Ltd. and ChainTrace Analytics Ltd.
5. Enhanced Due Diligence (EDD)
5.1. Enhanced due diligence is applied where higher money-laundering, terrorist-financing or sanctions risk is identified, including:
- Traders associated with high-risk jurisdictions identified by FATF or CAMBET internal risk lists;
- Traders identified as PEPs, family members of PEPs or known close associates of PEPs;
- complex or unusual transactions without apparent economic or lawful purpose;
- large or rapidly escalating activity that is inconsistent with the Trader's stated profile;
- wallet activity flagged by blockchain-analytics tools as exposed to mixers, sanctioned addresses, ransomware, darknet markets, scam clusters or theft proceeds;
- any other factor that CAMBET reasonably determines elevates risk.
5.2. EDD measures may include obtaining additional identification documents, source-of-funds and source-of-wealth evidence, senior-management approval for the relationship, more intensive ongoing monitoring and reduced limits.
6. Verification Deposit Requirement
6.1. As part of its risk-based controls, CAMBET may, at its sole discretion and at any time, require a Trader to fund the account with a verification deposit (account top-up) before granting or continuing access to certain features, including but not limited to withdrawals, settlement claims, promotional balances, market access or dispute resolution.
6.2. The verification deposit serves as a proof-of-control and anti-fraud measure. The deposit remains the property of the Trader and is credited to the Trader's balance once verification is satisfactorily completed.
6.3. Refusal or failure to satisfy a verification deposit request may result in temporary or permanent restriction of the account, including the inability to withdraw existing balances or claim settlement proceeds until verification is completed.
6.4. The verification deposit may be requested in addition to, or instead of, documentary identity verification, depending on the risk profile of the Trader and the activity in question.
7. Source of Funds and Source of Wealth
7.1. CAMBET may request information and supporting evidence regarding the origin of the assets used to fund the account and, where appropriate, the overall economic background of the Trader.
7.2. Acceptable evidence may include bank statements, payroll records, tax returns, business records, sale agreements, inheritance documents, blockchain transaction histories, exchange statements and other reliable documents.
7.3. The Company may decline to process deposits, withdrawals or trading activity until sufficient source-of-funds or source-of-wealth evidence has been provided.
8. Sanctions Compliance
8.1. CAMBET does not provide Services to persons or entities subject to economic, financial or trade sanctions administered by the United Nations, OFAC, the European Union, the United Kingdom (OFSI), Curaçao or any other applicable sanctions regime.
8.2. By using the Services, the Trader represents and warrants that:
- the Trader is not listed on any applicable sanctions, terrorist-financing, proliferation or watchlist;
- the Trader is not owned or controlled by, and is not acting on behalf of, a sanctioned person or entity;
- the Trader is not resident in, located in or accessing the Services from a sanctioned jurisdiction;
- the funds, wallets or accounts used in connection with the Services are not derived from or destined for any sanctioned person, entity, jurisdiction or activity.
8.3. The Company performs sanctions screening on Traders, beneficial owners, payment counterparties and wallet addresses at onboarding and on an ongoing basis. Matches are reviewed and, where confirmed, the relationship is terminated and the matter is reported to the competent authority.
9. Politically Exposed Persons (PEPs)
9.1. CAMBET screens Traders against domestic and foreign PEP lists.
9.2. Where a Trader is identified as a PEP, a family member of a PEP or a known close associate of a PEP, enhanced due diligence is applied, including senior-management approval for the relationship and additional source-of-funds and source-of-wealth checks.
9.3. The PEP status of a Trader does not, in itself, give rise to a presumption of unlawful conduct, but justifies a heightened level of scrutiny commensurate with the risk.
10. Ongoing Monitoring
10.1. CAMBET continuously monitors Trader activity, including deposits, withdrawals, orders, trades, positions, market behaviour, wallet activity and counterparty exposure.
10.2. Monitoring scenarios include, among others:
- unusual deposit or withdrawal patterns inconsistent with the Trader's risk profile;
- rapid in-and-out flows of funds with little or no trading activity;
- wallet exposure to mixers, tumblers, sanctioned addresses, darknet markets, scam clusters or stolen-funds clusters;
- structuring or smurfing patterns;
- activity suggesting market manipulation, collusion or insider trading;
- third-party funding, payment-method substitution or beneficiary changes;
- geolocation anomalies or use of VPN, proxy or anonymising services;
- activity inconsistent with the Trader's stated occupation, income or source of wealth.
10.3. Alerts generated by monitoring systems are reviewed by the AML team. Where suspicion is confirmed, the activity is escalated, the account may be restricted and, where appropriate, a suspicious transaction report is filed with the competent Financial Intelligence Unit.
11. Suspicious Transaction Reporting
11.1. The Company maintains procedures for the internal escalation and external reporting of suspicious activity to the competent Financial Intelligence Unit (FIU), in accordance with applicable law.
11.2. Staff are required to report any knowledge or suspicion of money laundering, terrorist financing, sanctions evasion, fraud or other financial crime to the Money Laundering Reporting Officer (MLRO) without delay.
11.3. The Trader will not be informed of any suspicious-transaction report ("tipping off"). Disclosure of such reports is prohibited by law and is a criminal offence in certain jurisdictions.
11.4. CAMBET may, where required or permitted by law, freeze funds, suspend transactions, restrict access or terminate the relationship without prior notice and without liability.
12. Record Keeping
12.1. The Company maintains records of identification data, supporting documents, account files, business correspondence and the results of analyses performed for the period required by applicable law, generally not less than five (5) years after the end of the business relationship or after the date of an occasional transaction.
12.2. Records of transactions, including on-chain and off-chain activity, orders, trades, positions and settlement events, are retained for at least the period required by applicable law.
12.3. Records are stored securely, in a tamper-resistant manner, and are made available to the competent authorities upon lawful request.
13. Travel Rule and Virtual Asset Transfers
13.1. Where the Services involve the transfer of virtual assets above the applicable Travel Rule threshold, CAMBET collects, retains and, where required, transmits prescribed originator and beneficiary information together with the transfer, using approved Travel Rule messaging protocols.
13.2. Transfers to or from non-compliant virtual asset service providers, self-hosted wallets or counterparties that cannot provide the required information may be blocked, delayed, reversed or reported.
13.3. The Trader undertakes to provide accurate beneficiary information for outgoing transfers and to use only wallets owned or lawfully controlled by the Trader.
14. Prohibited Conduct
14.1. The Services must not be used for, and the Trader undertakes not to engage in:
- money laundering, terrorist financing or proliferation financing;
- fraud, scam, phishing, identity theft or impersonation;
- sanctions evasion or circumvention of jurisdictional restrictions;
- market manipulation, insider trading, oracle manipulation or outcome manipulation;
- structuring, smurfing or layering of transactions to avoid reporting thresholds;
- use of multiple accounts to bypass limits or compliance controls;
- use of mixers, tumblers, sanctioned addresses or anonymising services for the purpose of concealing the origin of funds;
- any other activity prohibited by law or these Terms.
14.2. Engagement in prohibited conduct will result in immediate suspension or closure of the account, voiding of related transactions, withholding of balances to the extent permitted by law and reporting to the competent authorities.
15. Cooperation with Authorities
15.1. CAMBET cooperates fully with law-enforcement agencies, regulators, financial intelligence units, courts, sanctions authorities and tax authorities, in accordance with applicable law.
15.2. The Company may freeze assets, restrict access, disclose information and produce records pursuant to lawful requests, orders or instructions.
15.3. The Trader acknowledges that the Company may be compelled by law to disclose information about the Trader, the account and the related activity, and that the Company shall have no liability for such disclosures.
16. Governance and Training
16.1. The AML Policy is approved by senior management and reviewed at least annually, or more frequently where changes in business, regulation or risk warrant review.
16.2. The Company has appointed a Money Laundering Reporting Officer (MLRO) with sufficient seniority, independence and resources to discharge AML responsibilities.
16.3. Staff with AML-relevant responsibilities receive role-based AML training at onboarding and on an ongoing basis.
16.4. The effectiveness of the AML programme is subject to periodic independent review and, where applicable, external audit.
17. Trader Rights and Limitations
17.1. The Trader acknowledges that the application of AML, sanctions and fraud-prevention controls may, in certain circumstances, cause delays in deposits, withdrawals, settlement claims or access to the Services.
17.2. CAMBET shall not be liable for any loss or damage resulting from the application of such controls in good faith and in accordance with applicable law.
17.3. The Trader may request information about the personal data processed in connection with the AML programme in accordance with the Privacy Policy, subject to lawful restrictions on disclosure.
18. Contact
18.1. Questions regarding this AML Policy may be addressed to the AML team at [email protected].
18.2. Requests from competent authorities should be addressed to the registered office of Forecast Harbor N.V. at Kaya Isla di Futuro 27, Willemstad, Curaçao, marked for the attention of the MLRO.