Anti-Money Laundering (AML) Policy
Introduction:
The Company has established dedicated AML rules designed to prevent and mitigate any risks of being involved in illegal activities, including money laundering and terrorist financing. These rules are aligned with the following laws and regulations:
The National Ordinance Penalization of Money Laundering (NOPML)
The National Ordinance on the Reporting of Unusual Transactions (NORUTO)
The National Ordinance on Identification of Clients when Rendering Services (NOIS)
Directive (EU) 2018/843, as amended
Recommendations of the FATF and CFATF
Definition of Money Laundering
Money laundering refers to:
Concealing or disguising the source, location, movement, ownership, or rights related to property obtained through illegal activity;
Converting, transferring, acquiring, possessing, or using property derived from criminal activity to conceal its illicit origin or to assist others in evading legal consequences;
Handling assets acquired through criminal acts committed in another jurisdiction.
Player Declarations and Obligations
By using the Website and creating an account, the player acknowledges and agrees to:
Having read and understood the AML rules;
Complying with all applicable laws and regulations relating to anti-money laundering and counter-terrorist financing;
Certifying that deposited funds are not derived from illegal sources or associated with any unlawful activity;
Providing any requested documentation or information required by the Company for compliance purposes;
Depositing funds solely for the purpose of using the Website’s services and participating in its games.
Information Sharing
The Company may disclose player information to financial institutions or law enforcement agencies when required by applicable law. By using the Website, the player consents to such disclosures, even without prior notice.
AML Procedures
To ensure compliance with AML laws and industry standards, the Company implements the following procedures:
Risk management
Know Your Customer (KYC), including identification and verification
Ongoing monitoring of player behavior and transactions
Reporting of suspicious activity
Record-keeping of relevant data and interactions
Risk-Based Approach
Recognizing the evolving nature of financial crime and limited resources, the Company adopts a risk-based approach, focusing AML efforts on higher-risk areas. Players are assessed at onboarding and continuously throughout their engagement based on:
Geographical risk, such as residing in high-risk jurisdictions
Personal risk, such as being a politically exposed person (PEP)
Behavioral risk, such as inconsistent or suspicious activity (e.g., multiple payment methods, mismatched geolocation data)
Monitoring and Suspicious Activity
The compliance department continuously monitors player transactions and behavior. Suspicious activity includes, but is not limited to:
Unusual patterns in betting or fund transfers
Use of multiple or inconsistent payment methods
Discrepancies in geolocation or identity indicators
When such behavior is detected:
The Company may contact the player for clarification or additional documentation;
The account may be suspended pending a satisfactory response;
If no adequate explanation is provided within 30 days, the account may be closed, and the matter reported to relevant authorities.
Prohibited Conduct and Enforcement
The following activities are strictly prohibited:
Operating or using multiple or duplicate accounts to commit fraud or abuse
Providing false or incomplete KYC information
Engaging in behavior indicative of financial crime
Using automated tools (e.g., bots) or manipulative techniques to gain an unfair advantage
In such cases, the Company reserves the right to:
Cancel bets and winnings
Suspend or close the account
Retain funds
Exclude the player from services
Report the player to authorities
Withdrawal Restrictions
Withdrawals will only be processed to the same source used for deposits unless verifiable documentation supports an alternative;
Withdrawals to third-party accounts are strictly prohibited.
Reporting Obligations
Suspicious transactions or behavior may be reported to the Financial Intelligence Unit of Curaçao or other relevant authorities. Decisions to report are based on objective and subjective indicators. If the Company decides not to report, the rationale will be documented and retained.
Players will not be notified if an internal investigation is initiated or if a report is filed, as such disclosure could compromise the integrity of the process.
Record Retention
The Company retains the following records for five years after the last transaction or the account’s closure:
Identification and verification documents collected during the KYC process
Transactional history and supporting documentation
Communication logs between the player and the Company
Privacy and Liability
All personal data collected for AML purposes is processed in accordance with the Company’s Privacy Policy. Actions taken by the Company in line with this AML Policy (e.g., account suspension, transaction denial) do not constitute a breach of contract or grounds for civil liability.
