AML and CTF Program

upc0z is a licensed online wagering operator regulated by Liquor & Gaming NSW under licence 4597/2024/WB. As a provider of designated services, upc0z is a reporting entity under Australia's anti-money laundering and counter-terrorism financing regime and is enrolled with AUSTRAC, the national financial intelligence agency and regulator. This page explains our Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program and what it means for you as a customer.

Money laundering and terrorism financing cause real harm. upc0z takes its obligations seriously and applies a risk-based approach designed to detect, deter and disrupt the misuse of our services, while treating customers fairly and protecting their personal information.

Our AML/CTF Program

We maintain a documented AML/CTF Program made up of two parts. Part A sets out how we identify, assess, manage and reduce the risk that our services could be misused for money laundering or terrorism financing. Part B sets out our customer identification and verification procedures. The Program is built and operated in accordance with the AML/CTF Rules and is reviewed and updated as our business, customer base and the risk environment change.

A risk-based approach. We assess money laundering and terrorism financing risk across our customer types, the designated services we provide, the channels we use to deliver them, and the jurisdictions we deal with. Where risk is higher, we apply stronger controls; where it is lower, we apply proportionate controls. This risk-based approach drives the intensity of the checks we apply to individual customers and transactions.

Designated services and customer types. The wagering and account services we provide are "designated services" under the legislation. Our customers are predominantly individual retail account holders resident in Australia. We tailor our controls to the profile of these customer types and the way they use our services.

Customer due diligence

Before you can deposit, bet or withdraw, we must verify your identity. We collect and verify identification information in line with our Customer Identification Rules and Part B procedures. This is why we ask for details such as your full name, date of birth and residential address, and why we may request additional documents.

Ongoing Customer Due Diligence (OCDD). Identity checks are not a one-off event. We carry out Ongoing Customer Due Diligence by monitoring account activity, keeping customer information up to date, and reviewing transactions against expected behaviour. Unusual or unexpected activity may trigger further enquiries or requests for information.

Politically Exposed Persons (PEPs). We screen customers to identify Politically Exposed Persons — individuals who hold or have held prominent public positions, and their close associates and family members — because they can present a higher risk. Identified PEPs are subject to enhanced due diligence and senior management oversight.

Sanctions screening. We screen customers against Australian and international sanctions lists. We will not provide services to, and will freeze dealings with, any person or entity subject to applicable sanctions, consistent with our obligations under the Autonomous Sanctions Act 2011 (Cth) and the Charter of the United Nations Act 1945 (Cth).

Governance, people and training

Our Program is owned by a designated AML/CTF Compliance Officer who oversees day-to-day compliance, reporting and escalation. Senior management approves the Program, oversees its effectiveness and ensures appropriate resourcing — AML/CTF is treated as a board and executive responsibility, not just an operational task.

All relevant staff complete AML/CTF training so they understand their obligations, can recognise red flags and know how to escalate concerns. The Program is subject to regular independent review to test that it is effective and being followed in practice, with findings reported to senior management.

Reporting to AUSTRAC

We report to AUSTRAC through AUSTRAC Online. This includes:

Suspicious matter reports (SMRs) where we form a suspicion on reasonable grounds about a customer or transaction;
Threshold transaction reports (TTRs) for cash transactions at or above the reporting threshold; and
Compliance reports and other reporting as required.

We may also participate in lawful international information sharing with overseas counterparts and authorities to combat cross-border money laundering and terrorism financing. We are not permitted to "tip off" a customer about an SMR.

Privacy and record-keeping

The information we collect for AML/CTF purposes is handled in accordance with the Privacy Act 1988 (Cth) and our Privacy Policy. We use it only for permitted purposes and protect it with appropriate security controls. We retain AML/CTF records for 7 years as required by law — see the data retention section of our Privacy Policy for more detail.

Governing laws

Our AML/CTF Program operates within the framework of the following laws and rules:

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1)
Autonomous Sanctions Act 2011 (Cth)
Charter of the United Nations Act 1945 (Cth)
Financial Transaction Reports Act 1988 (Cth)
Criminal Code Act 1995 (Cth) — Division 400 (money laundering offences)
Customer Identification Rules

Customer awareness and contact

You can help us keep our services safe. Always use your own account, fund it from accounts in your own name, and never let anyone else use your account. We may from time to time ask you to confirm or update your information, or to explain a transaction — please respond promptly so we can continue to provide services without interruption.

If you have questions about our AML/CTF Program or an identity verification request, contact us at our support email (see Contact Us) or call 1800 858 858. General information about Australia's AML/CTF regime is available from AUSTRAC at austrac.gov.au.

See also: Privacy Policy, Integrity, Complaints.