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AML-KYC Policy

Introduction

Spinmills Casino has a lot of problems with people moving money and giving money to terrorists. We follow Dutch and EU rules to keep our online casino safe and open. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy explains how we do that. We follow the greatest legal and moral standards by making sure participants are who they say they are, keeping an eye on potential dangers, and reporting any strange behavior.

Legal Framework

Spinmills Casino operates under strict laws and regulations designed to combat financial crime. Key legal frameworks include:

  1. Dutch AML Law (Wwft): The Dutch Money Laundering and Terrorist Financing (Prevention) Act (Wwft) is something that we adhere to in a very tight manner. Consistent Wwft changes bring Dutch law into conformity with the anti-money laundering regulations of the FATF and the EU. As a result of this rule, we are required to conduct thorough assessments of prospective customers, keep track of financial transactions, and report activity that raises questions.
  2. EU AML Directives: Our company is allowed to run casinos in the EU, so we have to follow the 5th and 6th AMLD. These standards make European laws against money laundering stronger by requiring accurate reporting and record-keeping, as well as risk-based due diligence on clients. Spin mills changes how it does business to meet EU rules and the newest EU standards.
  3. Remote Gambling Act (KOA) and KSA:The Netherlands Gambling Authority (Kansspelautoriteit, or KSA) regulates Spinmills and issues licenses under the Dutch Remote Gambling Act (KOA). The KSA ensures that we meet all requirements related to gambling, including AML/KYC requirements. We keep thorough internal controls to avoid money laundering, monitor transactions on a continuous basis, and conduct thorough client due diligence as part of these licensing obligations.
  4. Financial Intelligence Unit (FIU-Nederland): The Dutch Financial Intelligence Unit is a partner of Spinmills. To help with the fight against money laundering, we must notify FIU-Nederland of any suspicious or irregular transactions. In the event that additional investigation is required, the FIU collaborates with law enforcement and is the primary recipient of our reports.

Customer Identification and Verification

Identity verification for all customers is crucial to our AML/KYC program. An automatic system checks Spinmills account holders’ details. Thus, when you register, our system quickly verifies that your identity evidence is valid. We only accept government-issued IDs like passports and national ID cards for security reasons. These IDs are acceptable in the EU and Netherlands. An automatic system analyzes the ID against your records to verify its authenticity and match your name, date of birth, and photo.

This consumer identification stage has many uses. All players must be legal, use their true names, and we must know who they are. It helps prevent account misuse and fraud.

Our compliance team will manually review the documents and request extra proof if the automatic technology cannot validate them or if any information is unclear. Players whose identification verification fails due to faulty documents or being under 18 cannot deposit or play until the issues are resolved. Spinmills follows legal KYC rules to validate identification from the start, ensuring community safety as we gamble.

Risk-Based Approach and Monitoring

When it comes to anti-money laundering (AML), Spinmills takes a risk-based strategy. This means that we analyze each customer and their activities individually to determine their risk profile. We constantly evaluate different risk criteria because no two players or transactions are the same; some may pose a greater threat of money laundering than others. The player’s home country, the amount deposited or withdrawn, the frequency of transactions, and any other suspicious activity on the account are all examples of such factors. An example of a trend that would warrant additional attention would be a pattern of extremely big deposits or fast high-value bets. Similarly, we consider a customer to be of higher risk and implement extra precautions if they are found to be a Politically Exposed Person (PEP) or hail from a nation lacking adequate anti-money-laundering controls.

In order to put this strategy into reality, we employ both automatic and human-oversight monitoring technologies for money and gaming transactions. Any suspicious activity, such as an unexpected increase in deposits, the use of the same payment information by several accounts, efforts to bypass our withdrawal and deposit limitations, or transactions coming from regions with a high risk of fraud, will be detected by our systems. Our compliance team launches additional investigations whenever a player’s profile is known to be inconsistent with unusual or suspicious transactions or activities. Even while the behavior turns out to be perfectly legal most of the time, we proceed with care and take the necessary measures if it seems strange or suspect.

Every member of staff is instructed to remain alert and to report any issues immediately. We will reassess the risk level of a customer quickly if their behavior changes, such as a large increase in their transaction volumes, since this is required by Wwft and EU regulations that we constantly track customer activity and revise risk assessments over time. By assigning more resources to higher-risk customers and transactions and using standard controls for lower-risk activity, the risk-based approach allows us to concentrate our efforts where they will have the greatest impact. Our ability to comply with regulatory demands for ongoing due diligence is enhanced by this proactive monitoring, which allows us to detect suspected money laundering in real time.

Enhanced Due Diligence (EDD)

In cases when there is a higher likelihood of money laundering or when certain events occur that trigger it, we employ Enhanced Due Diligence (EDD), which entails doing additional investigations and verifications. Spinmills has an explicit policy that any player account whose transactions over €5,000 will be subject to increased due diligence procedures. Practically speaking, this implies that we will conduct extra checks to verify the origin and intended use of any significant transactions (either one or many transactions totaling €5,000 or more). As a precaution, we’ve intentionally set this threshold lower than the required reporting triggers; doing so allows us to detect and investigate possibly suspicious conduct at an early stage, before it could get worse.

Our team will contact the customer to gather more information when EDD is triggered, whether it’s the €5,000 level or other danger indications such as those described above. Additional paperwork or verification may be required, such as evidence of the origin of funds (such as pay stubs, bank records, or other relevant documents). We could inquire further about the customer’s business or occupation, the rationale for the substantial transactions, and any other relevant details regarding their financial history. Essentially, we do a more thorough review of the player’s profile to make sure everything lines up with legal gaming.

High transaction amounts are not the only ones that warrant enhanced due diligence. In additional high-risk situations, we implement EDD when a client is determined to be a PEP, hails from a high-risk jurisdiction, or exhibits suspicious behavior for any other reason. Both the legislation and our own policies demand that we give these matters our full attention.

One EDD measure is to set lower internal alert thresholds and another is to check the player’s account more frequently. We may also need upper-level management’s OK to keep doing business with that player in certain situations. Spinmills reserves the right to take appropriate measures in the event that a client fails to comply with our EDD demands or the legitimacy of their payments cannot be adequately verified. In order to safeguard the casino and fulfill our legal responsibilities, it may be necessary to freeze the account or even end the relationship. In order to meet regulatory standards while maintaining a pleasant experience for our customers, we have meticulously planned our EDD process to be as painless as possible.

Reporting Suspicious Activity

As a matter of legal obligation, Spinmills Casino must notify the relevant authorities, in this case the Dutch Financial Intelligence Unit, FIU-Nederland, of any questionable or irregular conduct. We will promptly file an official report with the FIU if our monitoring and investigations lead us to believe that a customer’s behavior or a transaction could be associated with money laundering or terrorism financing. According to the Wwft, this is a legal requirement for Dutch casinos and online gaming companies. Reportable activities include large transactions with no apparent economic purpose, suspicious patterns of deposits and withdrawals that raise suspicions of “layering” funds, the use of fraudulent identification documents, or any transaction that does not fit the customer’s profile or the origin of their funds.

All of the data is safely transmitted to FIU-Nederland when we submit a report. Notifying the client that a report has been filed could expose a possible criminal, so it is against the law for us to do so. In their review of the report and other intelligence, the FIU will determine whether the activity is indeed suspicious. If so, they will designate the transaction as suspicious and provide it to the appropriate authorities for additional inquiry. No matter how naive we may be, we have an obligation to report suspicious financial dealings so that the proper authorities can take appropriate action. An essential part of the Netherlands’ anti-money-laundering system, this reporting mechanism allows for the rapid identification and investigation of suspicious activities.

Spinmills will not only report suspicious activity proactively, but will also comply with any requests for information from authorities. To the extent permitted by law, we shall cooperate with the Federal Bureau of Investigations (FIU) or local law enforcement in any requests for further information regarding a customer’s account or transactions. We make sure to keep meticulous records and audit trails to efficiently react to these kinds of demands. We have implemented these precautions to ensure the security of our platform and the financial system as a whole. Spinmills aids in the battle against money laundering and terrorist funding on a global scale by promptly reporting and openly sharing information regarding questionable activity.

Record-Keeping and Data Protection

We must keep correct records and protect consumer data as part of our compliance procedure. Spinmills rigorously records transactions and customer due diligence in accordance with legal regulations. All correspondence or analysis of suspicious behaviors, identity documents, verification results, and transaction histories (deposits, bets, withdrawals) are included. We save these records securely in our databases. Dutch AML legislation require AML/KYC records to be kept for five years after a transaction or customer connection ends. This retention duration ensures that the information is immediately accessible if authorities need it to investigate past transactions or if we are audited for compliance. Even attempted suspicious transactions (flagged transactions) are logged. After the required retention duration, we securely erase personal data unless required by law.

We understand the obligation of collecting and protecting sensitive data like bank records and personal documents. Spinmills complies with Dutch and EU privacy laws. We shall only utilize personally identifiable information for anti-money laundering, know-your-customer, and legal compliance. Our strong security procedures protect data. All sensitive data is stored on encrypted servers with strict access limits, and we monitor for illicit access. Our personnel receive data protection and confidentiality training to protect our customers’ data.

By following GDPR requirements, we can be transparent with our users about data collection and use. AML regulation (such as the Wwft) allows us to utilize personal data for compliance purposes to obtain identity documents and track transactions to combat financial crime. Spinmills will never sell or share personal information to a third party unless required by law, such as when engaging with the FIU or regulators. To conclude, our data protection techniques protect your personal information and our record-keeping policies fulfill legislative criteria while protecting our players and business.