AML Policy

HOW TO ENTER & DRAW RULES

  1. Answer the Question First – Before buying your ticket, you must answer our general knowledge question correctly.
  2. Ticket Limits – We limit the number of tickets per person based on the prize value. The limit is shown on each prize page.
  3. Sales Window – Each prize has a set start and end date for ticket sales. Once the deadline passes, no more entries can be bought.
  4. Draw Date – We draw the winner live on YouTube on the date advertised.
  5. Winner Contact – If you win, we’ll contact you by email. If you don’t respond within 14 days, we may redraw.
  6. Prize Delivery – Physical prizes are posted within 30 days. Digital prizes go to your email.
  7. Liability – We don’t guarantee the quality or safety of prizes from third parties. You’ll need to deal directly with them if there’s a problem.
  8. Fair Play – If we suspect cheating, fake accounts, or breaking our Terms, we can cancel your entry.

PRIZE DISCLAIMER

IMPORTANT: Participation in any prize draw is subject to our Terms & Conditions. This Prize Disclaimer supplements those Terms and applies to all Prizes offered.

  1. No Endorsement or Warranty
    1. All Prizes are provided “as is” without warranty of any kind, whether express or implied, including (but not limited to) warranties of merchantability, fitness for a particular purpose, satisfactory quality, or non-infringement.
    2. The inclusion of a Prize on our Website does not imply endorsement, sponsorship, or affiliation with the manufacturer, supplier, or service provider.
  2. Third-Party Prizes
    1. Many Prizes are supplied by independent third parties. We do not manufacture, own, or control these Prizes and we are not responsible for their performance, safety, or suitability.
    2. All claims, complaints, or issues regarding a Prize must be addressed directly to the third-party supplier in accordance with their own terms and conditions.
  3. Travel & Experience Prizes
    1. Where a Prize includes travel, accommodation, or an experience:
      • The winner is responsible for arranging valid travel documents, visas, insurance, vaccinations, and compliance with local laws.
      • We accept no liability for cancellations, delays, schedule changes, or events beyond our control.
      • All costs not expressly stated as included in the Prize description (e.g. meals, transfers, insurance, taxes) are the sole responsibility of the winner.
  4. Limitation of Liability
    1. To the fullest extent permitted by law, we are not liable for:
      • Loss, damage, or injury arising out of acceptance, possession, use, or misuse of any Prize;
      • Failure of the Prize to meet expectations; or
      • Indirect, incidental, or consequential losses.
    2. This does not affect your statutory rights where applicable.

ANTI-MONEY LAUNDERING POLICY

  1. Purpose
    1. This Anti-Money Laundering Policy (“Policy”) sets out the measures WinJourney (“we”, “our”, “us”) takes to prevent our website and services from being used for money laundering, terrorist financing, or other criminal activity.
    2. While WinJourney is not regulated by the UK Gambling Commission as a lottery or betting operator, our online tombola operations involve financial transactions and therefore must comply with the Proceeds of Crime Act 2002, Money Laundering Regulations 2017, and applicable international best practices.
  2. Scope
    1. This Policy applies to:
      • All employees, contractors, and partners of [Company Name];
      • All transactions and customer accounts on the Website;
      • All payment methods, including card payments, bank transfers, and e-wallets.
  3. AML Risk Assessment
    1. We assess the following risk factors:
      • Customer Risk – High-value ticket purchases, repeat entries from the same user, unusual activity.
      • Transaction Risk – Large payments relative to average transaction size, frequent small transactions followed by high-value withdrawals (if applicable).
      • Geographic Risk – Transactions from high-risk or sanctioned jurisdictions.
      • Product/Service Risk – Use of tombola entries as a vehicle for moving funds without genuine interest in participating.
  4. Customer Due Diligence (CDD)
    1. Basic CDD – For all customers, we collect:
      • Full name
      • Email address
      • Payment method details
    2. Enhanced Due Diligence (EDD) – Triggered if:
      • Cumulative spend exceeds £2,000 in a 30-day period;
      • Transactions originate from high-risk jurisdictions;
      • Multiple accounts are suspected to be linked.
      • EDD may include requesting:
        • Proof of identity (passport, driving licence)
        • Proof of address (utility bill, bank statement)
        • Verification of payment source (bank statement, payslip)
    3. If a customer refuses to provide requested information, we suspend their account and refund only legally permitted amounts.
  5. Transaction Monitoring
    1. We monitor transactions for:
      • Purchases far above normal entry values;
      • Multiple failed payment attempts;
      • Use of multiple payment cards in short succession;
      • Attempts to use prepaid cards or anonymous payment methods.
      • The system flags suspicious activity for review by the Compliance Officer.
  6. Record Keeping
    1. We retain:
      • Customer identity verification documents (where obtained);
      • Transaction logs;
      • Internal investigation records.
      • Retention period: minimum 5 years from the end of the business relationship.
  7. Reporting Suspicious Activity
    1. Staff must report suspicions of money laundering or terrorist financing immediately to the Nominated Officer (Money Laundering Reporting Officer – MLRO).
    2. The MLRO will:
      • Review the information;
      • Submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) if required;
      • Ensure no “tipping off” of the customer occurs.
  8. Sanctions Compliance
    1. We check customer details against the UK Sanctions List and other applicable watchlists for restricted persons or entities.
  9. Staff Training
    1. All relevant staff receive AML training covering:
      • Recognising suspicious activity;
      • CDD and EDD procedures;
      • Record-keeping requirements;
      • SAR submission process.
      • Training is repeated annually.
  10. Policy Review
    1. This Policy is reviewed annually, or sooner if:
      • There are changes in legislation;
      • Risk assessments indicate new threats;
      • There is an internal compliance breach.

Nominated Officer / MLRO: Robert Nagy
Contact Email: info@winjourney.eu

Last updated: 30.09.2025

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