1. Our position
SOBO Competitions Ltd runs prize competitions of skill. We are not a gambling operator and we are not a regulated financial institution, so the Money Laundering Regulations 2017 do not apply to us as a relevant person. We nonetheless apply proportionate controls because prize competitions can be targeted by fraud and by attempts to convert criminal funds into a legitimate-looking payout, and because we must comply with the Proceeds of Crime Act 2002 and the Fraud Act 2006.
2. What we do not accept
- Payment from an account or card not held in the entrant's own name.
- Cash, cryptocurrency or third-party money transfer.
- Multiple accounts operated by one person, household or group to evade per-person ticket caps.
- Automated entry, scripted purchasing, or use of bots or bulk-registration tools.
- Entry using false identity, age or address details.
- Requests to pay a prize to someone other than the verified winner.
3. Controls we operate
- Payments. All card payments run through Stripe with 3-D Secure and Stripe Radar fraud screening. We never handle raw card data.
- Bot protection. Cloudflare Turnstile plus server-side rate limiting on sign-up, sign-in, free entry, contact and newsletter forms.
- Per-person caps. Ticket limits are enforced in the database at the point of reservation, not just in the interface, so they cannot be bypassed.
- Duplicate-account signals. We review matching addresses, dates of birth, payment fingerprints and device signals and surface them to staff for manual review.
- Audit trail. Account changes, administrative actions, refunds, draw seeds and payouts are written to an append-only audit log with actor, timestamp, IP address and user agent.
- Segregated access. Administrative functions are role-gated and require multi-factor authentication.
4. Identity verification on prizes
Before releasing any prize we verify that the winner is the account holder, is aged 18 or over and is resident in the United Kingdom (England, Wales, Scotland and Northern Ireland). For cash prizes and prizes of higher value we may additionally request:
- photographic identification (passport or UK driving licence);
- proof of address dated within the last three months;
- confirmation that the receiving bank account is in the winner's own name; and
- a short declaration confirming the entrant did not use another person's payment method.
Prizes are paid only to the verified winner. We do not pay third parties, and we do not refund tickets in exchange for a prize. Verification documents are held securely, used only for this purpose, and deleted once verification is complete unless a longer retention period is legally required.
5. Escalation and reporting
Suspicious activity is escalated to our nominated officer. Where we have knowledge or suspicion of money laundering or of criminal property we will make a report to the National Crime Agency and we will not tip off the person concerned. Suspected fraud is reported to Action Fraud and, where a payment is involved, to Stripe. We cooperate fully with law enforcement requests supported by proper legal authority.
6. Consequences
Where we reasonably believe this policy has been breached we may suspend the account, void affected entries, withhold or reclaim a prize, refuse future entry and retain records of the breach. Where entries are voided because of the entrant's own dishonesty, ticket payments are not refunded. Where entries are voided for a reason not involving dishonesty, we refund under our Refunds & Cancellations Policy. Decisions can be challenged through our Complaints Policy.
7. Thresholds and review
The monetary thresholds at which enhanced verification applies are set internally, reviewed at least annually, and are deliberately not published so they cannot be gamed. Staff receive written guidance on recognising and escalating suspicious activity.
8. Reporting a concern
If you suspect fraudulent activity on the platform or on your account, email hello@sobocompetitions.com immediately. We treat reports confidentially.