Source of Funds guide

Documentation submission guidance

In order to comply with the Money Laundering and Terrorist Financing Prevention Act of the Republic of Estonia, in certain situations, as a regulated entity, we are obliged to request a particular type of information and documentation from our Customers.

If we ask you to submit a particular type of information or documentation, it does not automatically mean that we suspect you are involved in any illicit activity. However, we are required to receive this information from you to establish risks in our cooperation and evaluate your activity and source of funds, which is standard practice. If you have not performed any illicit activity and fully and quickly comply with our requests, the investigation process will be quick. You will be able to continue to enjoy our services in no time.

We understand that submitting the correct required documentation and information can be frustrating and often confusing. Therefore, we have developed this guidance on how to correctly prepare documents and information for submission for most common cases so that your account approval is as fast as possible.

1. General guidance

Whenever we ask you to submit a particular type of documentation or information with precise expected characteristics (for example, account statement of a particular time frame, account statement from specific accounts, invoice or agreement on a particular transaction, explaining the relationship with particular persons, etc.) you must submit information and documentation exactly as requested, otherwise request will be made again, and approval process will take much longer time. For example, if you are asked to submit an account statement for the past 6 months but only submit one for the past 3 months, this document will be denied, and a new request will be created for you.

Whenever you cannot provide the required documentation, you must submit a written explanation of why such documentation cannot be provided and any other alternative documentation to justify particular transactions or situations.

When submitting documentation or written explanations, please make sure you submit documentation or describe reasons that include as many details on particular transactions or situations as possible. This will help us make the investigation process as quick as possible with fewer additional requests.

2. Account statements

When submitting accounts statements, please make sure these statements include:

• All incoming and outgoing transactions
• Dates of transactions
• Transactions amounts
• Full name of senders/receivers
• For international transactions, complete addresses of senders/receivers
• Full payment details
• Your name as the account holder
• Account number
• Balance of the account before/after a transaction

Account statements must be for the requested period of time. Shorter period statements will not be accepted.

Account statements must be original unedited PDF files downloaded from your internet banking cabinet (or other applicable financial institution platforms). Any other format files like MS Excel or screenshots turned into PDFs will not be accepted.

To save time, if funds on your account where you deposited from into our platform came from your other account/-s, please submit a full statement also from this other account/-s as we will in any way request this statement if we do not see a direct source of funds in your account where you deposited from and will result in longer processing time.

When submitting account statement/-s, do not exclude, filter out or cover any of the transactions in the requested period, such statement will be denied, and repeated requests will be made, resulting in prolonging of the investigation period.

3. Explanations on particular transactions

• If a full account statement since a particular deal/transaction is requested, you must submit a statement that involves all the transactions in the account since particular transaction till the date of request. For example, if a full account statement is requested since a transaction on 18.05.2018, you must submit a full statement starting from 18.05.2018 involving all transactions up until the date of this request. Statements showing only this one particular transaction or statement with missing time periods will not be accepted.
• If you are asked to submit particular transaction/-s supporting documentation, please make sure all the relevant documents are submitted so that it helps us understand particular transaction/-s and resolve questions as fast as possible. For example, if you have sold an apartment, submit a purchase/sale agreement and official proof of your previous ownership and transfer of ownership to the buyer.

Whenever submitting requested information and documentation on particular transactions, to understand the scope of what you need to submit, make sure (as far as it is possible) that this information and documentation include:

• Date of transaction/-s
• All involved parties (seller, real-estate agent, government institution, bank, etc.)
• Involved accounts
• Clear subject of the transaction/-s (sale of a car, sale of a house, sale of shares, received loan, received benefits, etc.)
• Ownership switch
• Total value of transactions
• Involved jurisdictions

4. Source of funds documentation

When investigating your source of funds, we are required to acquire account statements and proof of legitimacy for these transactions backed by documentation. There are many types of deals and transactions that can be the source of your funds deposited with Hitz, but to guide you on our expectations for the most typical cases, below, we have listed examples of sources of funds and expected minimum documentation/information that should be prepared and submitted so that the investigation process is fast and smooth so you can get back to enjoying our services as quickly as possible.

4.1. Salary

• A full employment contract or, if applicable to your jurisdiction, a payslip and tax report.

4.2. Investments in securities

• Statement from a trading account with visible initial investments and gains turned into profit and withdrawn.

4.3. Investments in tangible assets

• Documentation proving previous ownership
• Documentation (contract, agreement, etc.) proving the sale of said tangible asset

4.4. Pension

• Governmental issued document proving pension receiving status and amount.

4.5. Dividends from a private company

• Documentation, proving ownership and amount of shares in particular legal entity (can be a statement form official governmental registry)
• Decision of shareholders to pay out dividends with indication on the size of dividends

4.6. Winnings

• Downloaded PDF statement from a particular operator where all your deposits, winnings and withdrawals are visible.
• If a particular operator does not provide such statement, then you can provide a screenshot from your player’s panel, but in this case, you must also provide a screenshot with a message from the operator that they do not provide such statements.
• Statements or screenshots from other operators must include at least visible name of the operator, your name, the date of the statement, and transaction dates.

4.7. Sale of own real-estate

• Statement from land registry of previous ownership and transfer of ownership
• Contract of sale of the real-estate

4.8. Rent of own real-estate

• Statement from land registry of the real-estate ownership
• Contract of the real-estate rent

4.9. Rent of other property

• Document (official governmental or property acquisition proving document) proving the ownership of particular property.
• Contract of property rent

4.10. Sale of other movable or immovable property

• Document (official governmental or property acquisition proving document) proving the ownership of particular property.
• Contract of sale of a particular property

4.11. Inheritance

• Deed of inheritance or other legally binding documentation proving the right to inheritance (a will, court order, agreement, trust, certificate of death, etc.). 

   

4.12. Private company share sale

• Extract from company registry that proves a change of ownership and any legally binding document (agreement, shareholder decision, account statement, etc.) that proves actual payment obligation and amount of sale. In case there is no open company registry, instead of extract, a legal company document proving previous ownership (certificate of incorporation, memorandum of association, shareholder register, declaration of trust, etc.).
• If any, agreement of company share sale

4.13. Loan

• Full loan agreement
• Written explanation justifying proper use of the received loan in gambling

4.14. Gift/support from relatives or friends

• Written explanation of the relation to particular persons and reason for support

4.15. State/municipality benefits

• Legally binding official documentation proving and explaining the benefit payment reason

4.16. Savings

• Written explanation of how savings were accumulated
• If savings were acquired in transactions that are not connected to regular income, provide supporting documentation for these transactions

5. Explanations on relationship with particular persons

It is normal that you might have lots of transactions in your accounts with different persons (friends, relatives, family, etc.) for everyday needs or private matters, but there can be situations when we will need to know more details on these transactions and relationships you have with these persons in order to prove these transactions are legitimate and for private matters. If we ask you to explain such transactions and relationships that any legal documentation might not support, please make sure you provide as detailed explanations as possible as it will help us to perform our investigations as quickly as possible and close the matter in an as short time as possible. Therefore, make sure to mention any minor details, even if these details might not seem relevant to you, on your relationship with these persons and what is the reason for transactions with them in your account.

6. Cash transactions

Please be aware that if your account statements have an unusually large amount of deposits or withdrawals of cash via ATMs, we will be required to request an explanation and documentation identifying the source of this cash or further use of this cash. As cash transactions are related to a certain difficulty in establishing their source of further movement, you will need to be precise and detailed in your explanations and document submission in order for the investigation process to go successfully. There is no information too insignificant that can help us resolve the matter and help us in our investigations.