Anti-Money Laundering (AML) Policy

Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Commitment: Prevention of Financial Crime and Ethical iGaming

Jurisdiction: Republic of Kenya

1. Introduction and Policy Purpose

Chicken Road Game Kenya (https://chicken-road-game.or.ke/) is dedicated to supporting ethical practices in digital entertainment. We take a firm stance against money laundering, terrorist financing, and illicit financial transactions within Kenya’s growing iGaming sector.

Although https://chicken-road-game.or.ke/ is an informational and review portal rather than a financial repository or gambling operator, we actively align our operations with the Proceeds of Crime and Anti-Money Laundering Act, 2009 (POCAMLA) of Kenya, the regulations of the Financial Reporting Centre (FRC), and guidance from the Financial Action Task Force (FATF).

This policy outlines our operational controls, our standards for vetting affiliate partners, and our cooperation with regulatory bodies to prevent financial crime.

2. Nature of Operations vs. Financial Responsibilities

To maintain full legal clarity:

  • Non-Financial Character: The website https://chicken-road-game.or.ke/ does not process customer funds, accept cash deposits, hold player balances, issue withdrawals, or operate digital wallets.
  • No Direct Financial Risk: Because we do not handle player transactions, our platform cannot be used directly to deposit, transfer, or launder illicit capital.
  • Informational Role: Our AML strategy focuses on screening third-party marketing relationships, preventing fraudulent traffic, and directing users only to licensed, fully compliant betting platforms.

3. AML and KYC Standards for Recommended Operators

Because we refer visitors to third-party casino platforms, we enforce strict compliance standards for every operator featured on our website. We only partner with operators licensed by the Betting Control and Licensing Board (BCLB) that demonstrate active adherence to POCAMLA regulations.

We require our partner casinos to implement the following controls:

a. Comprehensive Customer Due Diligence (CDD) and KYC

  • Mandatory player identification using Kenyan National ID cards, valid passports, or alien registration certificates before approving real-money withdrawals.
  • Phone number verification linking registered player profiles directly to legitimate Safaricom M-Pesa or Airtel Money accounts.
  • Clear identity verification procedures to prevent the use of stolen identities or burner mobile accounts.

b. Transaction Monitoring and Source of Funds

  • Continuous monitoring of deposit and withdrawal volumes to spot unusual transaction patterns, rapid fund turnover, or structuring attempts.
  • Enhanced Due Diligence (EDD) for high-value transactions, Politically Exposed Persons (PEPs), or high-risk accounts.
  • Enforcing strict closed-loop payment rules, ensuring withdrawals return to the same verified mobile money wallet used for deposits.

c. Statutory Remittance and KRA Tax Withholding

  • Automated compliance with Kenya Revenue Authority (KRA) tax requirements, including the mandatory 20% Withholding Tax (WHT) deduction on net winnings.
  • Routine reporting of suspicious transactions (STRs) to Kenya’s Financial Reporting Centre (FRC).

4. Preventing Illicit Activity on Our Platform

To ensure our website is not misused by bad actors, we maintain the following internal controls:

  • Prohibition of Shady Services: We never promote unlicensed casinos, unregulated crypto mixers, or underground bookmakers operating outside BCLB oversight.
  • Cybersecurity and Traffic Monitoring: We use automated monitoring to detect botnets, proxy networks, and suspicious traffic patterns designed to exploit referral programs.
  • Zero Tolerance for Financial Deception: We do not host guides on bypassing casino KYC procedures, dodging mobile money verification, or evading statutory KRA taxes.
  • Content Integrity: All tutorials focus on fair play, sound bankroll management, and verified game rules.

5. Staff Conduct and Commercial Due Diligence

Our editorial and commercial staff are trained to uphold high standards of integrity:

  • All potential advertising partners undergo thorough corporate screening to confirm valid licensing, beneficial ownership transparency, and regulatory standing.
  • We immediately sever affiliate ties with any operator that loses its BCLB license, faces sanctions for AML non-compliance, or engages in unfair financial practices.
  • Our team stays informed about updates to POCAMLA, BCLB directives, and Kenyan data protection regulations.

6. Cooperation with Law Enforcement and Regulators

We cooperate fully with Kenyan authorities in the fight against financial crime. Subject to lawful process and within the limits of our data protection obligations, we will assist:

  • The Betting Control and Licensing Board (BCLB)
  • The Financial Reporting Centre (FRC)
  • The Directorate of Criminal Investigations (DCI)
  • The Ethics and Anti-Corruption Commission (EACC)

If we identify evidence of fraud, identity theft, or financial crime connected to our platform, we will notify the appropriate authorities.

7. Reporting Suspicious Activity

We encourage our community to report any suspicious activity, unlicensed platforms, or financial irregularities encountered through external links on our site: