Anti-Money Laundering & Counter-Terrorism Financing Policy

1.Introduction and scope

Spinago Casino ("Spinago", "we", "us", "the operator") is committed to preventing money laundering, terrorism financing, and other financial crimes. This Anti-Money Laundering and Counter-Terrorism Financing Policy ("AML Policy" or "the Policy") sets out the principles, procedures, and controls we apply to detect, deter, and report financial crime risks across our platform.

This Policy applies to every customer who registers, deposits, plays, or withdraws on Spinago, regardless of jurisdiction, transaction size, or payment method. By using our services you acknowledge that you have read and accept the obligations described here.

We operate under a Curaçao Gaming Authority (CGA) licence. Our AML framework is built to meet or exceed the Financial Action Task Force (FATF) Recommendations, the Curaçao National Ordinance on Identification when Rendering Services (LID), and the National Ordinance on the Reporting of Unusual Transactions (LMOT). Customers physically located in Australia are additionally subject to AUSTRAC (Australian Transaction Reports and Analysis Centre) obligations as they apply to gambling services.

This Policy is a public document. The internal procedures, scoring matrices, and detection rules that implement it are confidential and are not disclosed publicly to preserve their effectiveness.

2.Regulatory framework

Spinago’s AML/CTF programme is built on the following regulatory pillars:

3.Key definitions

Money laundering

The process of disguising the origin of funds derived from criminal activity to make them appear legitimate.

Terrorism financing

The provision or collection of funds with the intention or knowledge that they be used to commit terrorist acts.

CDD (Customer Due Diligence)

The process of identifying customers and assessing their risk profile, including identity verification, source of funds checks, and ongoing monitoring.

EDD (Enhanced Due Diligence)

Stricter CDD measures applied to higher-risk customers — PEPs, customers from high-risk jurisdictions, or customers with unusual transaction patterns.

PEP (Politically Exposed Person)

A person holding or having held a prominent public function, including their immediate family members and close associates.

Suspicious transaction

A transaction that, on reasonable grounds, appears connected to money laundering, terrorism financing, or other criminal activity.

FIU

Financial Intelligence Unit — the national authority that receives, analyses, and disseminates suspicious transaction reports. In Curaçao: FIU Curaçao. In Australia: AUSTRAC.

4.Risk-based approach

We apply a risk-based approach as required by FATF Recommendation 1 and the Curaçao National Ordinance LID. This means our AML/CFT measures are calibrated to the risk presented by each customer, transaction, and channel — not applied uniformly. Higher-risk situations receive proportionally stricter controls.

Our risk assessment framework considers four primary factors:

5.Customer Due Diligence (CDD)

CDD is the foundation of our AML programme. We apply CDD measures in three categories:

6.Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence to customers and transactions identified as higher risk. Triggers for EDD include:

• PEP status (self or close associates) confirmed at screening
• Country of residence on FATF grey or blacklist
• Cumulative deposits or withdrawals exceeding A$25,000 in any rolling 12-month period
• Single transactions exceeding A$10,000
• Unexplained inconsistencies between declared occupation and transaction patterns
• Any prior suspicious activity report related to the account

EDD measures may include source-of-funds and source-of-wealth evidence (bank statements, payslips, sale-of-asset records), senior management approval to continue the relationship, and intensified ongoing monitoring with a lower threshold for triggering review.

7.Ongoing monitoring of transactions

All accounts are subject to ongoing transaction monitoring. Our automated systems screen every deposit, wager, and withdrawal against a continuously updated risk model that looks for patterns indicative of money laundering or terrorism financing — including but not limited to:

• Structuring (smurfing) — deposits split below threshold to avoid CDD triggers
• Rapid deposit-then-withdrawal with minimal play
• Unusual deviation from a customer’s established pattern
• Use of multiple payment methods or wallet addresses without clear rationale
• Crypto deposits from addresses linked to mixers or sanctioned wallets
• Geographic anomalies — login from a new high-risk jurisdiction

Flagged activity is escalated to our Compliance Officer for human review. Where the activity warrants, an internal suspicious activity report is generated and the matter progressed under section 8 below.

8.Suspicious activity reporting

Where activity meets the threshold for suspicion under the Curaçao LMOT or AUSTRAC AML/CTF Act, our Money Laundering Reporting Officer (MLRO) files a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit:

• For Curaçao-licensed activity: FIU Curaçao
• For activity involving Australian customers: AUSTRAC
• Where matters cross jurisdictions, both authorities may receive reports

We are prohibited by law from disclosing the existence, content, or fact of any SAR to the customer or third parties (the “tipping off” offence). This is a standard provision of AML legislation and applies regardless of whether the customer asks directly.

Where required by an FIU or law-enforcement order, we may freeze account funds, restrict withdrawals, or close the account. Affected customers are notified to the extent legally permitted.

9.Record keeping

We retain the following records for a minimum of five years after the customer relationship ends, in line with FATF Recommendation 11 and Curaçao LID requirements:

• Identity documents and verification records (CDD/EDD outputs)
• Transaction history (deposits, wagers, withdrawals)
• Communications relating to AML reviews and source-of-funds requests
• Internal suspicious activity reports and SAR filings
• Sanctions and PEP screening results
• Risk assessments and review notes

Records are stored in encrypted form with access restricted to compliance personnel. Retention may be extended where required by an ongoing investigation or court order.

10.Sanctions and PEP screening

All customers are screened at registration and on an ongoing basis against:

• UN Security Council Consolidated Sanctions List
• EU Consolidated Sanctions List
• OFAC (US Treasury) Specially Designated Nationals List
• UK HM Treasury Consolidated List
• Australian Department of Foreign Affairs and Trade (DFAT) Sanctions
• Politically Exposed Persons databases (commercial PEP lists)
• Adverse media databases (commercial)

A confirmed sanctions match results in immediate account suspension, fund freeze, and reporting to the relevant authorities. PEP matches result in EDD application and senior management approval to continue the relationship.

11.Staff training and compliance officer

Spinago has appointed a Money Laundering Reporting Officer (MLRO) — an independent compliance officer with responsibility for the AML/CTF programme, SAR filing, and regulatory liaison. The MLRO reports directly to senior management and has unrestricted access to all customer records.

All staff receive AML/CTF training at induction and annually thereafter. Training covers identification of red-flag indicators, escalation procedures, the “tipping off” prohibition, and updates to applicable laws. Staff in customer-facing or compliance roles receive role-specific advanced training. Records of completion are retained for audit.

12.Restricted and prohibited jurisdictions

We do not provide services to residents of:

• Curaçao (mandatory exclusion under our licence terms)
• The United States and its territories
• The United Kingdom
• France, Spain, Italy, Netherlands (regulated home-market exclusions)
• Countries on the FATF blacklist (currently North Korea, Iran, Myanmar)
• Countries subject to comprehensive UN, EU, or OFAC sanctions

Geo-blocking applies at IP and registration levels. Attempts to circumvent restrictions via VPN, proxy, or false location declaration are a Terms of Service violation and may result in account closure and forfeiture of funds where regulatory grounds exist. The full jurisdictional list is maintained in our internal compliance manual and is updated as regulations change.

13.Your rights and obligations as a player

You have the right to:

• Request a copy of personal data we hold about you (subject to applicable privacy law)
• Be informed when KYC documents are accepted, rejected, or further information is required
• Receive timely communication about withdrawal status, including reasons for delay
• Escalate disputes through our internal complaints process and, if unresolved, to the Curaçao Gaming Authority

You agree to:

• Provide truthful, current, and complete identification information
• Use only payment methods registered in your own name
• Refrain from depositing or playing on behalf of another person
• Provide source-of-funds documentation when requested
• Respond to compliance queries within reasonable timeframes (typically 7 days)
• Notify us promptly of material changes to your address, occupation, or beneficial ownership

14.Contact and reporting concerns

For AML/CTF queries or to report a concern about activity on Spinago:

External authorities for independent reporting of suspected financial crime:

This Policy is reviewed at least annually and whenever material regulatory changes occur. Revisions are dated and version-numbered above. The current version (v3.2 — April 2026) supersedes all previous versions.