AML and CTF Policy

We operate as a licensed gaming operator under Curaçao law. We do not act as a bank, money service business, or virtual asset service provider under Curaçao financial statutes. Even so, we apply strong compliance controls that reflect global anti-money laundering and counter-terrorist financing standards.
Our compliance framework focuses on risk awareness, prevention, detection, and response. Controls are designed to identify suspicious activity early and stop misuse of our platform. These controls adapt as regulatory expectations evolve.

Use of our products for money laundering, terrorist financing, or sanctions violations is not permitted under any circumstances. Our policies align with the AML and CFT regulations applicable in Curaçao and reflect guidance issued by global standard-setting bodies such as the Financial Action Task Force.
We review regulatory developments and industry guidance regularly. Internal policies are updated where required to reflect changes in law, risk trends, or operational scope.

Money laundering describes the process used to hide the origin of funds generated through illegal activity. The process typically involves three stages.
Placement involves introducing illegal funds into a financial system. Layering refers to complex transactions designed to hide the origin of those funds. Integration occurs when funds appear legitimate and re-enter the economy.
Suspicious activity includes behavior that suggests illegal intent, fraud, sanctions evasion, or terrorist financing. Sanctions are restrictions imposed by governments or international bodies to limit the activities of specific countries, entities, or individuals.

We maintain a formal compliance structure overseen by a Chief Compliance Officer. This role includes responsibility for policy oversight, regulatory alignment, internal controls, and investigation of unusual activity.
Employees receive compliance education relevant to their roles. Training focuses on identifying red flags, understanding reporting duties, and applying internal procedures consistently.
Independent reviews and monitoring support the effectiveness of our compliance program and help identify areas for improvement.

User due diligence forms the foundation of our AML framework. We apply a risk-based approach to understand who our users are and how they interact with our platform.

Some accounts present a higher risk due to transaction behavior, geographic indicators, or other red flags. In such cases, enhanced due diligence applies.
Enhanced review may require additional information, including full legal name, proof of address, identification documents, source of funds, and source of wealth. Verification may involve third-party providers.
Accounts under enhanced review may face temporary restrictions until review completion.

Account access is denied or restricted where users fail to meet compliance standards. Situations leading to rejection or suspension include failure to provide required information, submission of false documents, attempts to hide location, connection to sanctioned regions, or links to illegal activity.
We also restrict accounts where the source of funds raises concern or where platform use presents unacceptable risk.

We monitor transactions and account behavior on an ongoing basis. Monitoring combines automated systems with manual review to identify unusual patterns.

Beyond transaction review, we apply further controls to limit misuse of our services.

Employees receive AML, counter-terrorist financing, and sanctions training appropriate to their roles. Training covers regulatory obligations, internal procedures, and risk indicators.
Ongoing education supports consistent application of controls and helps adapt to emerging threats.

We report suspicious activity to relevant authorities where required by law. Reports may relate to sanctions exposure, suspected money laundering, terrorist financing, or other criminal conduct.
Cooperation with regulators and lawful authorities forms part of our compliance commitment. Information is shared only where legally required.

Our AML and CFT framework evolves alongside regulatory expectations and industry standards. Policies, systems, and controls undergo regular review to maintain effectiveness and relevance.