AML and CTF Policy

Stake operates as a licensed gaming operator under Curaçao law and does not act as a bank, money service business, or virtual asset service provider under Curaçao financial statutes. Even so, the platform applies strong compliance controls that reflect global anti-money laundering and counter-terrorist financing standards.

The compliance framework focuses on risk awareness, prevention, detection, and response. Controls are designed to identify suspicious activity early and prevent misuse of the platform, while continuously adapting to evolving regulatory expectations.

Use of the platform for money laundering, terrorist financing, or sanctions violations is not permitted under any circumstances. Stake’s 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.

Regulatory developments and industry guidance are reviewed regularly. Internal policies are updated where required to reflect changes in law, risk trends, and operational requirements.

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.

Stake maintains a formal compliance structure overseen by a Chief Compliance Officer, who is responsible for policy oversight, regulatory alignment, internal controls, and the investigation of unusual activity.

Employees receive compliance training relevant to their roles, with a focus on identifying red flags, understanding reporting obligations, and consistently applying internal procedures. Independent reviews and ongoing monitoring support the effectiveness of the compliance program and help identify areas for continuous improvement.

User due diligence forms the foundation of Stake’s AML framework. A risk-based approach is applied to understand who users are and how they interact with the 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.

Transactions and account behavior are monitored on an ongoing basis. Monitoring combines automated systems with manual review to identify unusual patterns.

Beyond transaction review, additional controls are applied to limit misuse of the 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.

Suspicious activity is reported 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 the compliance commitment, and information is shared only where legally required.

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