Financial Crime Controls & Reporting Policy
| Policy owner | SuperSubBetting (sole trader) |
| Effective date | 1 January 2025 |
| Version | 1.0 |
| Review frequency | Annually |
1. Purpose
This policy documents SuperSubBetting's financial crime controls and reporting obligations. It explains clearly:
- What financial crime controls apply to a digital publisher.
- When SAR reporting under POCA 2002 is — and is not — directly required.
- When escalation to an operator, bank, payment provider or competent authority is the appropriate response.
2. Scope
All financial transactions of SuperSubBetting, including contractual business receipts, payments to service providers and freelancers, and bank account activity.
3. Financial crimes relevant to this business
| Crime type | Applies? | Notes |
|---|---|---|
| Money laundering (POCA 2002) | General law applies | POCA 2002 principal offences (ss.327–329) apply to all persons in the UK. MLRs 2017 regulated-sector obligations do not apply to digital publishers. |
| Terrorist financing (Terrorism Act 2000) | General law applies | Offences under the Terrorism Act 2000 apply to all persons; escalate immediately to NCA / police if suspected. |
| Fraud (Fraud Act 2006) | General law applies | The business must not commit fraud; report suspected fraud against the business to Action Fraud. |
| Bribery (Bribery Act 2010) | Applies | See Anti-Bribery Policy. |
| Tax evasion (Criminal Finances Act 2017) | Applies | Sole trader is responsible for accurate self-assessment. The facilitation of tax evasion offence under the CFA 2017 applies to all businesses. |
4. SAR reporting — when it applies and when it does not
4.1 When a SAR is directly required
SuperSubBetting must submit a SAR to the NCA (via the UKFIU portal) if the sole trader knows or suspects that:
- A business payment or other funds received are the proceeds of criminal conduct.
- A payment instruction from an operator or third party is designed to launder money.
- Any person is attempting to use the business to move, conceal or acquire criminal proceeds.
- There is any connection to terrorist financing.
A SAR must be submitted before proceeding with a transaction where consent to proceed is required (a "consent SAR"). Do not proceed until either consent is given by the NCA or the seven-working-day moratorium period expires.
4.2 When a SAR is NOT directly required — escalate instead
Because SuperSubBetting operates outside the MLRs 2017 regulated sector, many scenarios that would trigger a mandatory SAR for a supervised entity instead require escalation to the appropriate party:
| Scenario | Appropriate action |
|---|---|
| End-user suspected of using a betting operator for money laundering | Escalate to the operator's compliance team. SuperSubBetting has no visibility of or control over end-user transactions; this is entirely the operator's responsibility. |
| Unusual or unexpected payment from an operator | Contact the operator's compliance team for clarification first. If concern persists, submit a SAR to the NCA where appropriate. |
| Bank account receives an unexpected payment from an unknown source | Contact the business bank immediately. Do not spend the funds. The bank will advise on next steps and may contact NCA directly. |
| Suspected fraud against the business (e.g. phishing, impersonation) | Report to Action Fraud (0300 123 2040) and the business bank. A SAR is not required unless money laundering is also suspected. |
| Suspected tax evasion by a third party | Report to HMRC via the tax evasion hotline (0800 788 887). A SAR is separate and not automatically required. |
5. Practical controls
- All business receipts are accepted only from identified counterparties via named bank transfer.
- Bank statements are reviewed monthly for unexplained credits or debits.
- The sole trader maintains HMRC-compliant records for self-assessment purposes.
- No cash transactions are conducted by the business.
- New operator relationships are verified against the UKGC public register or equivalent before commencing.
6. Escalation contacts
- NCA UKFIU (SAR submission): nationalcrimeagency.gov.uk
- Action Fraud: 0300 123 2040 / actionfraud.police.uk
- HMRC tax evasion: 0800 788 887
- Business bank: fraud / suspicious transaction hotline (varies by provider)
7. Record-keeping
- All SARs submitted — retained for five years from date of submission.
- Records of operator due-diligence checks — six years.
- Bank statements and financial records — six years (HMRC requirement).
- Log of any financial crime concerns raised and actions taken — six years.