AML Policy

Company Business Model

1.1. LTD. (" " or the " Company ") is a company incorporated under COUNTRY NAME that was established in DATE and operates the online casino under the LICENSENUMBER.

As part of its global operations, has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

Company Policy Statement

2.1. is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (" AML/CFT ") applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, expressly prohibits and rejects the use of products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering (" AML ") laws, regulations and norms. continues to monitor norm setting parameters promulgated by the Financial Action Task Force (" FATF ") and certain gaming trade groups in addition to the Curaçao Gaming Control Board and will take necessary action as it deems appropriate to reflect changes in law.

2.2.'s intention is to follow global best practices in guarding against products being used to facilitate such activities. Those best practices include:
  • Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;
  • Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;
  • Provision of related education and training to relevant personnel; and
  • Independent reviews, monitoring and maintenance of the policy, procedures and controls.


The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler's checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets. Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions.For example, they are used:
  • To encourage a change in behaviour for a target country or regime;
  • To apply pressure on a target country to comply with set objectives;
  • As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or
  • To prevent and suppress the financing of terrorists or terrorist acts.

Know Your Customer Procedure

4.1. will apply appropriate user due diligence and ongoing monitoring measures required by law. will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity. uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.

4.2. Customer Due Diligence collects certain documentary and non-documentary information commensurate with the nature of the type account and services that offers. This includes:
  • Collecting baseline (e.g., wallet address, email address) information at account creation through's user onboarding portal;
  • Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user's account;
  • Maintaining records of the information used to identify the user; and
  • Determining if a user appears on any list of known or suspected terrorists or terrorist organisations provided to the financial institutions based on the above information.
4.3. Identity and Age Verification . A third-party service provider will support's ability to determine the legitimacy of the identification information other KYC materials or information provided and will confirm that the user is permissible. The service provider also will confirm that the user does not appear to be located in a comprehensively-sanctioned or otherwise prohibited jurisdiction and will search global sanctions lists to confirm that the user does not appear thereon using onboarding information such as wallet addresses.

4.4. Customer Information . will collect details on each user to form a reasonable belief that knows the identity of its users commensurate with the user's risk profile. For instance, may collect such details as the wallet address, name, address, country, date of birth, or postal code (collectively, " KYC Information "). will collect any of the above KYC Information prior to issuing a funding address to users. does not presently allow users who are non-natural may, at its own description rely on the performance by another institution of some or all of the elements of our CIP.

4.5. Geo-blocking for Prohibited Jurisdictions . will require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.

Enhanced Due Diligence

5.1. performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, has implemented a set of red flag indicators that help it determine such behaviours and require further action from in assessing the customer information.

5.2. Whenever one of those red flags is triggered, the user account will be suspended and will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of:
  • Full legal name;
  • Country of citizenship;
  • Permanent Address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office or other physical location);
  • Identification number (either a taxpayer identification number, or, if unavailable, a passport number and country of issuance, alien identification card number or number and country of issuance of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);
  • Identification Document; and
  • Source of Funds and Source of Wealth. may use a third party service provider to verify any of the above information as determined to establish a reasonable basis to know the true identity of the user where the user's activity warrants such action.

Acceptance Policy

6.1. will not accept a and will block the users that:
  • Do not provide the identification information requested by;
  • Provide fake identification documents;
  • Try to use different means to deceive about their location;
  • Are from restricted or prohibited jurisdictions; or
  • Are subjected to United States, European Union, or other global sanctions or watch lists;
  • Are gambling addicted or have mental health issues;
  • Its source of funds are originated or exchanges in restricted jurisdictions;
6.2. reserves the right to block and suspend players for any other reasons at its own discretion.

Transactions Monitoring

7.1. is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring.

7.2. will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review user history and patterns of activity to detect and report any unusual activity as required and to develop and implement any additional controls or limits in its platform.


8.1. is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity to the regulator.
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