Anti-Money Laundering (AML) Policy

General

1. We are limited liability company, Genius Touch B.V., duly incorporated and registered pursuant to the laws of Curaçao. To protect your funds and ensure our compliance with local and international standards, we operate exclusively in accordance with the law on combating money laundering and countering the financing of terrorism and criminal activities.
2. We, as an owner and operator of the spinwin365.com (“Website”) have developed this Anti-Money Laundering Policy ( “Policy”). The Policy is designated to prevent and mitigate all possible risks of us being involved in any kind of illegal activity. This Policy aims to comply with the rules and guidance’s contained in the following laws, namely the National Ordinance Penalization of Money Laundering (NOPML), the National Ordinance on the Reporting of Unusual Transactions (NORUTO), the National Ordinance on Identification of clients when Rendering Services (NOIS), Directive (EU) 2018/843 as amended and the FATF/CFATF recommendations. Subsequently, this Policy is a combination of the FATF, EU and local AML rules and regulations. This ensures a solid, internationally accepted basis regarding AML.
3. Money laundering and the financing of terrorism are significant threats for national and international economies throughout the world, forcing all vulnerable sectors to have measures in place for their prevention.
4. Money laundering means:
   • hiding or keeping privacy regarding the information about the real source, location, disposal, movement, ownership or other property rights related to property obtained as a result of illegal activity;
   • conversion, moving, obtaining, possession or use of property which was got as the result of criminal activity for the purpose of concealing the illicit source of such property or assisting persons involved in crime to avoid legal consequences of their actions;
   • a situation in which the property was obtained as a result of criminal activity committed on the territory of another state.

Your Consent and Representations

1. When you use the Website and open an account, you agree to undertake the following obligations and make the following representations:
   • You have read and accept conditions of this Policy.
   • You are obliged to comply with all applicable laws and regulations on combating money laundering and terrorism financing, including this Policy;
   • You confirm that you have no information or any suspicions about the fact that funds used for depositing in the past, present or future, are received from any illegal source, or have any relation to legalization of income obtained illegally, or other unlawful activity prohibited by applicable law or the instructions of any international organizations;
   • You agree to provide any information we think fit to require according to applicable laws and regulatory requirements in respect of combating the legalization of funds obtained illegally.
   • You acknowledge that you may deposit money into your account only in order to play and use the services offered on the Website.
   • We are obliged to share information about you with financial institutions and law enforcement agencies, as required by the applicable laws, and has the right to do so without obtaining prior consent. By using the Website, you give us a consent to perform these actions.

Our AML-driven Actions and Procedures

1. We have established a compliance department that develops AML policies, which are obligatory for all our employees. The department also determines the policy of engagement with those registered and holding accounts.
2. The compliance department ensures that all the operations are consistent with the international standards for combating money laundering and that all the documents provided by you are up to date and comply with the relevant legal requirements.
3. In an effort to be compliant with the applicable rules, regulations and international standards, we have procedures which we apply to you when you are using the Website. These procedures are:
   • risk management;
   • know your customer (KYC) which includes identification and verification. Using this procedure, we make sure that you are who you say you are. Please read our KYC Policy to learn more about it;
   • ongoing monitoring of your activity and actions;
   • reporting;
   • record-keeping.
4. Below we describe these procedures in more details.

Risk Management

1. Due to the fact that money laundering and terrorist financing are evolving each year, while we are limited in our resources, we use risk-based approach which is a methodology allowing to concentrate the most of our AML measures in the places/sections where the risks are the highest.
2. Each player is evaluated on its risk level during the establishment of business relationship and on ongoing basis during the business relationship. The risk factor of the customers can be changed anytime based on his activity.
3. For the purpose of the risk assessment, we consider the following factors:
   • geographical factor: you may be ascribed with a higher risk if you reside in certain jurisdiction (for example, if you are from so-called high-risk jurisdiction, we are obliged to exercise extensive scrutiny on you);
   • personal factor: you may be ascribed with a higher risk if you have some personal circumstances, for example if you qualify as a politically exposed person;
   • behavioral factor: you may be ascribed with a higher risk if your behavior on the Website seems unusual on suspicious for us. It could be the case when you use different payment instruments within a short term or we detect mismatch of the geolocation’s key elements (citizenship/residency, mobile carrier provider, IP address geolocation, BIN number of the card etc.).

KYC

1. Within our KYC procedure, we will be required to carry out identification and verification.
2. Identification. Upon registration on the Website, you will be required to provide some information for the purposes of identification: name and surname, date of birth, address, email and telephone number.
3. Verification. In some cases (where you deposit determined amount or request withdrawal), we have the right to request documents which confirm your identity. Sometimes, when you are ascribed with a high-risk profile, we will apply more strict verification procedures.
4. Please read our KYC Policy to learn which obligations you have to fulfill and what are the consequences of incompliance.

Ongoing Monitoring And Actions

1. Our compliance department monitors of all your activities together with the related deposits and bets on the Website. We constantly invest in the best software of the industry in order to mitigate industry related risks such as money laundering, terrorism financing, fraud and other criminal activities.
2. Suspicious activity. We permanently check your behavior on the Website for the absence of suspicious activity. Your activity is considered as suspicious if, for example, we identify your unusual betting patterns or unusual deposit and withdrawal patterns. Indicators of the suspicious activity are set up based on our discretion and consider relevant applicable regulations. Upon identification of the suspicious activity, we will contact you to get a reasonable explanation of the abnormal behavior. In case we do not get satisfactory answer, your account might be suspended until necessary explanation and documents are provided. If the you do not provide requested information within 30 days, your account might me closed and your activity will be reported to the relevant authority. The same applies for cases where we reasonably suspect deposits from questionable sources or any actions with signs of fraud (such as, but not limited to, stolen credit cards, transfer of funds to other player accounts, forgery, collusion, the use of impermissible software tools, the provision of false data).
3. Multiply accounts. Any multi-account strategies are strictly prohibited on our Website. We can close your Account, if we believe that you have opened or are using multiple accounts or a duplicate account with the intent to defraud us and/or to abuse terms and conditions.
4. Withdrawal restrictions. The following restrictions apply to the withdrawals from the account:
   • we will not deposit withdrawn funds to another source from which it was originated unless sufficient information or documentation is provided. It means that if you deposit money from your bank account via card payment, withdrawal will be made on this account unless you substantiate other withdrawal method;
   • any withdrawals to a third-party account will not be effectuated.
5. Restriction of an account. We reserve the right to cancel any bets as well as winnings, block your account, exclude you from participating in games, retain payments and report you to the authorities in the following circumstances:
   • if you submit incorrect or incomplete information or documents about within our KYC procedure;
   • if your activity on the Website is considered suspicious and you don’t provide reasonable explanations of abnormal use of the Website;
   • if we suspect that you have violated any other regulation contained in this Policy or any other policies applicable to the Website the rules of the game and specific rules as applicable from time to time Any such decision is within our sole discretion and does not require any justification towards you and may not be contested;
   • if we consider that you use the products and services offered on the Website in an inappropriate or fraudulent manner or has deliberately cheated or taken unfair advantage of us or any of its other players or for illegal and/or unlawful or improper purposes;
   • if you use devices such as robots or other artificial assistants, external programs or mathematical techniques or any manipulative strategies that distort normal gameplay and gives you an unfair advantage and does not leave place for chance.

Reporting

1. Any suspicious transactions or circumstances for which we have has not received sufficient explanation may give rise to a report to the appropriate authority of Curaçao (Financial Intelligence Unit).
2. While assessing whether any suspicious activity shall be reported, we will proceed from objective and subjective indicators.
3. We will hold a list of all instances in which we have not considered it necessary to report. The decision not to report will need to be sufficiently justified.
4. In case we initiate any internal investigation or decide to report your activity to the relevant authority, you will not be notified on this as such information may be used by you in order to “normalize” your behavior or activity or mitigate/destroy evidence needed for investigation.

Record-keeping

1. We keep records of the following data for a period of 5 years from the date of your last transaction or the date when you have closed his/her account on the Websites:
   • the information, obtained in the process of the identification and verification;
   • the records of transactions (deposits, withdrawals) and their supporting evidence;
   • the history of communication with you.
2. All personal information about which is received based on this Policy is processed according to our Privacy & Management of Personal Data Policy.

Limitation of Liability

1. Any our actions driven by AML purposes (such as refusal to perform transactions which are considered suspicious, blocking or closing of your account) does not constitute a basis for civil liability of us for failure to fulfil obligations to you.