Flush.com is operated by Fordegens Limitada, a limited liability company registered in Costa Rica with company registration number: 3102928865, with registered address: San Pedro, Barrio Dent, Costa Rican North American Center, Office 3. Flush.com is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros, and operates under License No. ALSI-202509008-FI1. Flush.com has passed all regulatory compliance and is legally authorized to conduct gaming operations for any and all games of chance and wagering.
Flush is committed to preventing money laundering (ML) and terrorist financing (TF). This Anti-Money Laundering (AML) Policy sets out our approach to identifying, preventing, and reporting suspicious activity in compliance with the AML/CFT Laws of the Autonomous Island of Anjouan and directives issued by Anjouan Licensing Services Inc.
Flush acknowledges that its products and services may be targeted by individuals seeking to launder criminal proceeds or facilitate terrorist financing. As such, we maintain a strong compliance culture and implement robust controls to detect and prevent illicit activity.
Money Laundering refers to the process of concealing the true origin and ownership of criminal proceeds to avoid prosecution and confiscation. Money laundering shall be regarded as such even when the activities which generated the proceeds were carried out in another jurisdiction. This includes:
Terrorist Financing refers to providing, collecting, or moving funds with the intention of using them to carry out terrorist acts or support terrorist organizations.
Suspicious Activity refers to transactions or behavior that may indicate fraud, money laundering, terrorist financing, sanctions evasion, or other illegal activities by users or third parties.
Sanctions refer to measures imposed by governments or international bodies to restrict activities of targeted individuals, entities, or nations involved in illegal activities or threats to international security.
Politically Exposed Person (PEP) refers to an individual who holds or has held a prominent public position, as well as their immediate family members and close associates.
Flush prohibits the use of its platform for any form of illicit activity, including money laundering, terrorist financing, and sanctions violations. Our approach includes:
Flush conducts regular risk assessments considering:
These assessments are reviewed annually or when significant operational changes occur.
Flush has appointed a Compliance Officer responsible for:
All relevant staff receive AML training upon hire, annually, and whenever regulations or policies change.
Flush applies risk-based Customer Due Diligence to verify the identity of its customers. Flush does not permit corporate entities or non-natural persons to register. Only individual users may create accounts.
CDD is required when:
During the verification process, customers must provide:
All documents must be in English or accompanied by a certified translation.
Enhanced Due Diligence is applied to higher-risk customers, including:
EDD may require additional documentation such as proof of source of funds (payslips, bank statements) and proof of source of wealth (tax returns, company financials).
As a crypto-friendly platform, Flush implements additional controls to address risks specific to digital assets:
Accounts flagged for suspicious crypto activity may be suspended pending further review.
Flush monitors customer transactions for unusual patterns, including:
Flush also implements procedures for ban evasion detection, duplicate account monitoring, and multiple account detection to prevent misuse of the platform. Users are prohibited from operating more than one account.
Where suspicious activity is identified, accounts may be suspended and additional information requested.
All customers are screened against:
Customers identified on sanctions lists will have their accounts closed and reported to relevant authorities. PEPs are subject to enhanced monitoring and source of wealth verification.
Flush is committed to reporting suspicious activity to relevant regulatory authorities in accordance with applicable laws and regulations.
Flush retains customer identification documents, transaction records, and compliance reports securely. Records are made available to regulatory authorities upon request.
Flush employs robust security measures to protect customer data, including encryption, firewalls, and intrusion detection systems.
Flush is committed to protecting the integrity of sporting events and preventing match-fixing, insider betting, and other forms of sports corruption.
Flush identifies and monitors customers connected to:
Such accounts are subject to:
Flush cooperates with sports governing bodies and regulatory authorities to maintain the integrity of sporting competitions.
Flush does not offer services to users from restricted or prohibited jurisdictions, including: Austria, France and its territories, Germany, Netherlands and its territories, Spain, Union of Comoros, United Kingdom, USA and its territories, all FATF blacklisted countries, and any other jurisdictions deemed prohibited by Anjouan Licensing Services Inc.
As a Flush customer, you agree to:
Flush will not accept and may suspend or block users who:
Flush reserves the right to suspend or close accounts for any other reason at its discretion.
For questions regarding this policy, contact our Compliance Team.