Anti-Money Laundering and Counter-Terrorist Financing Policy

We operate as an online casino, not as a financial institution, yet we voluntarily apply controls similar to those used in regulated financial environments. Protection against criminal misuse is essential for the long-term stability of our platform, so our internal policy reflects the same caution found in higher-risk industries.

Our approach is built on several principles:

• Applying reasonable safeguards against financial crime;
• Maintaining rules that evolve as global standards change;
• Ensuring oversight through designated compliance staff;
• Reviewing procedures regularly to strengthen our internal structure.

These principles guide our decisions when handling user information, analysing transactions, and granting access to our services.

Several long-established concepts in compliance form the backbone of our policy. Understanding them helps explain why certain actions are required and why we restrict particular behaviours.

Money laundering refers to the process of concealing the origin of criminal proceeds. It usually involves three phases: placement of illicit funds into a system, layering through multiple transactions that obscure the source, and integration, where the funds appear to be legitimate.

Suspicious activity involves behaviour that does not match a user’s profile or raises questions about intent. It may involve unexpected transaction patterns, concealed locations, or wallet activity linked to known high-risk areas.

Sanctions reflect restrictions issued by governments or international groups. They target individuals, jurisdictions, and organisations associated with criminal networks, terrorism, or destabilising activity. Observing sanctions requirements forms a critical part of our obligations.

These definitions allow us to respond correctly when user behaviour triggers concerns or when conflicts with regulatory requirements appear.

A strong governance structure supports the entire AML policy. Oversight is led by our Chief Compliance Officer, who coordinates implementation of all rules, manages internal investigations, evaluates risks, and communicates with regulators when necessary. The role includes assessing new legal requirements and adapting our internal standards when global expectations shift.

Staff across different departments receive regular AML and CTF training so they understand risks, reporting channels, and the purpose of our controls. Training helps maintain a unified approach, especially when user behaviour changes or when external risks become more prominent.

Independent reviews and periodic system checks ensure that controls remain effective. We co-operate closely with technology teams and operational departments to ensure that AML expectations remain integrated across the entire platform.

We apply identity checks to ensure that only eligible users gain access to our services. KYC procedures are adapted to the risk level and may vary depending on account activity, deposit behaviour, and geographic location.

The process begins with the collection of information such as name, date of birth, nationality, address, and identification documents. We also review wallet information for crypto users to assess whether the source appears legitimate and free of sanctions exposure. Third-party verification services assist us in confirming document authenticity and verifying location.

Enhanced checks apply when user actions suggest elevated risk. A sudden change in deposit size, inconsistent transaction behaviour, unusual wallet indicators, or activity linked to high-risk jurisdictions may trigger a request for further information. Temporary restrictions may apply until the user provides the required details.

We do not accept users who refuse verification, hide jurisdiction, provide non-authentic documents, or appear on sanctions or regulatory watchlists. Certain jurisdictions remain blocked entirely, and we apply geo-blocking to prevent access from those regions. Our policy also prohibits participation by any user attempting to use tools designed to conceal identity or routing.

Transaction monitoring is central to our AML and CTF program. We use internal systems supported by specialist analytics providers to review deposits, withdrawals, and behavioural patterns. Every crypto deposit and withdrawal undergoes blockchain-based analysis to identify signs of risk or links to known problematic networks.

Our monitoring approach focuses on changes in size, pattern, and velocity. A user may attract attention if their behaviour suddenly differs from their historical activity or if wallet information suggests links to high-risk zones. Unusual patterns, repeated small deposits designed to avoid thresholds, and activity from prohibited exchanges may all require further review.

When signs of risk appear, we may temporarily pause withdrawals or request supporting information. Additional documents may be required to confirm the source of funds or to clarify the purpose of the activity. If a user cannot provide acceptable confirmation, the account may remain restricted.

We also maintain internal detection measures that help identify attempts to register multiple accounts or bypass security controls. Device analysis, time-zone consistency checks, and unusual routing patterns can indicate attempts at evasion. Our policy prohibits peer-to-peer transfers between accounts inside the platform, and attempts to bypass this rule are treated as red flags.

One controlled list is used here to improve clarity:

• Deposits and withdrawals screened through blockchain-forensics tools;
• Checks for geographic inconsistency;
• Alerts for interaction with known high-risk wallet clusters.

These measures support rapid identification of activity that contradicts normal patterns.

Training forms a crucial part of our AML structure. Employees receive clear guidance on suspicious behaviour, reporting channels, and responsibilities. Training sessions take place regularly and include updates related to changes in law, international standards, and new forms of criminal activity.

We encourage cooperation across departments to support early detection of risk. When staff identify unusual activity, reports are escalated directly to the compliance team. Internal communication ensures that concerns are examined thoroughly and handled with consistency.

We comply with Curaçao’s reporting obligations under the National Ordinance. Suspicious activity is reported promptly when evidence indicates a connection to money laundering, terrorist financing, sanctions-listed parties, or financial crime. Our compliance team keeps secure, detailed records to support each report and to assist regulatory inspections or legal obligations.
We also cooperate with authorities in jurisdictions where users are located whenever required. Maintaining trust with regulators protects our licence and supports a safe environment for all legitimate users.