AML Policy

The Company has established dedicated Anti-Money Laundering (AML) policies designed to prevent and minimise the risk of the Company being inadvertently involved in any form of unlawful activity. These policies are built to ensure compliance with the relevant legislation, including 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, and recommendations set forth by the FATF and CFATF.

Money laundering and terrorist financing represent serious threats to both national and global economies. As a result, all sectors exposed to such risks must have effective prevention strategies in place.

In general, money laundering involves:

• Concealing or disguising information related to the true origin, location, movement, ownership, or rights over property gained from criminal activities.
  
• Converting, transferring, acquiring, possessing, or using property obtained through illegal means with the intent to obscure its illicit source, or to help individuals involved in crimes evade legal consequences.
  
• Engaging in activities where the property stems from criminal offences committed in another country.
  

By registering and using the Website, players confirm the following:

• They have read, understood, and accepted the AML policies.
  
• They commit to adhering to all applicable laws and regulations aimed at combating money laundering and terrorist financing.
  
• They confirm that the funds used to deposit on the Website, whether in the past, present, or future, are not sourced from illegal activities or connected to the laundering of unlawfully obtained income.
  
• They agree to provide any information the Company may request under applicable legal and regulatory obligations related to the prevention of money laundering.
  
• They acknowledge that all deposits are intended solely for playing games and using services available on the Website.
  

The Company is legally obligated to share player information with financial authorities and law enforcement as required by law and may do so without needing prior consent. By using the Website, players grant the Company permission to comply with such legal requirements.

To ensure compliance with relevant regulations and international standards, the Company employs specific procedures when players use the Website. These include:

• Implementing a risk-based management approach.
  
• Conducting Know Your Customer (KYC) procedures, which encompass identifying and verifying player identities (details can be found in our KYC section).
  
• Ongoing monitoring of player activities and transactions.
  
• Reporting suspicious activities.
  
• Maintaining records.
  

Given that money laundering tactics and terrorist financing methods evolve, and considering resource constraints, the Company employs a risk-based methodology. This allows us to concentrate AML efforts where the potential for risk is highest.

Each player is assessed for their risk level when establishing a business relationship, and reassessed continually throughout their engagement with us. A player's risk level may change at any time depending on their activities.

The risk assessment process considers:

• Geographical factors: players residing in certain jurisdictions may be classified as higher risk.
  
• Personal factors: players may be considered higher risk if they meet certain criteria, such as being a Politically Exposed Person (PEP).
  
• Behavioural factors: unusual or suspicious behaviour, such as frequent use of multiple payment methods in a short span or inconsistencies in geolocation data (citizenship, residency, mobile carrier, IP address, card BIN number), can raise risk levels.
  

The KYC process mandates player identification and verification, further detailed in the respective section of our Terms and Conditions.

Our Compliance Team continually monitors all player activities, deposits, and bets on the Website. We invest in industry-leading technology to mitigate risks associated with money laundering, terrorism financing, fraud, and other criminal conduct.

The Company regularly reviews player behaviour for suspicious activity. Indicators include atypical betting patterns or irregular deposit and withdrawal behaviours. Our criteria for suspicious activity align with applicable regulations. When suspicious activity is identified, the player will be contacted for clarification. If the explanation is unsatisfactory, the account may be suspended until the necessary documentation is provided. Failure to respond within 30 days may result in account closure and a report to relevant authorities.

Additionally, the Company strictly prohibits the use of multiple accounts. If a player is found to have created or used multiple or duplicate accounts with the intention of defrauding the Company or abusing the Terms and Conditions, their accounts may be terminated.

Withdrawal restrictions include:

• Withdrawals must typically be returned to the same payment method used for the original deposit unless adequate documentation supports an alternative.
  
• Withdrawals to third-party accounts are not permitted.
  

The Company reserves the right to cancel bets, void winnings, suspend accounts, exclude players from games, withhold payments, and notify authorities if:

• Players provide false or incomplete information during the KYC process.
  
• Player activity is deemed suspicious without adequate explanation.
  
• There is evidence of violation of AML policies, game rules, or other site regulations.
  
• Players use the Website's services fraudulently, cheat, exploit other players, or engage in unlawful activities.
  
• Players employ automated tools, bots, external software, or manipulative strategies that distort fair gameplay.
  

Should the Company encounter transactions or behaviour it cannot reasonably justify, it may report these to Curaçao’s Financial Intelligence Unit.

When deciding whether to file a report, the Company evaluates both objective and subjective factors. Records are maintained for all decisions where reporting was deemed unnecessary, with each decision being sufficiently documented.

If an internal investigation is initiated or a report is filed with authorities, the player will not be informed to prevent interference with the investigation or destruction of potential evidence.

The Company retains the following records for five years from the date of the player’s last transaction or account closure:

• Data gathered during identification and verification.
  
• Transaction records, including deposits and withdrawals, along with supporting documents.
  
• All communications with the player.
  

All personal information collected under this policy is handled in accordance with our Privacy Policy.

Lastly, any actions the Company undertakes under AML obligations, including blocking transactions, suspending, or closing accounts, do not establish grounds for civil liability towards the player for any resulting losses or obligations.