AML Policy
Effective: 1 January 2024 · spinbetter.africa
CONTENTS
1. Purpose & Scope
Spinbetter, operated by Spin Entertainment N.V. (Curacao License No. 8048/JAZ), maintains a zero-tolerance policy toward money laundering and terrorist financing. This Anti-Money Laundering Policy establishes the framework for detecting, preventing, and reporting suspicious activity on the spinbetter.africa platform. This policy applies to all employees, contractors, and third-party service providers. We comply fully with Curacao gaming regulations and applicable international AML standards including FATF recommendations.
2. Customer Due Diligence & Enhanced Due Diligence
Standard CDD is applied at registration and requires: verified full name, date of birth, residential address, and government-issued photo ID. Source of funds documentation is required when cumulative deposits exceed EUR 2,000 in a 30-day period. Enhanced Due Diligence (EDD) is applied to Politically Exposed Persons (PEPs), high-risk jurisdictions, and accounts exhibiting unusual transaction patterns. EDD requires additional documentation including source of wealth declarations. All KYC documents are securely stored and accessible only to authorised compliance personnel.
3. Transaction Monitoring, Reporting & Record Keeping
All transactions on spinbetter.africa are monitored by automated systems and reviewed by our compliance team. Indicators of suspicious activity include: structuring transactions to avoid reporting thresholds, rapid deposit and withdrawal without gambling activity, use of multiple payment methods, and inconsistencies between declared and actual source of funds. Suspicious Activity Reports (SARs) are filed with the Curacao Gaming Control Board and relevant Financial Intelligence Units as required by law. All transaction records and KYC documentation are retained for a minimum of 5 years. For AML enquiries: [email protected].
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