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Anti Money Laundering (AML) Policy

Committed to Preventing Financial Crime and Promoting a Safe Gaming Environment

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AML Policy

Our Anti-Money Laundering (AML) Policy is designed to ensure a safe and secure environment for all players. To protect our users and comply with legal requirements, we perform account verification in three steps to confirm your identity and verify that your payment method belongs to you.

These verification measures help prevent the use of stolen or unauthorized financial instruments and ensure compliance with international AML regulations.

Depending on your country, payment method, and withdrawal option, certain additional security checks may apply to reduce the risk of money laundering.

Our management and staff are fully committed to following strict AML guidelines and monitor all activities to prevent the misuse of our platform for illegal purposes.

Our AML program is developed in line with leading international standards, including:

  • EU Directive 2015/849 on preventing the use of the financial system for money laundering purposes.

  • EU Regulation 2015/847 on information accompanying fund transfers.

  • EU sanctions and trade restrictions related to high-risk goods and individuals.

  • Belgian Law of 18 September 2017 on the prevention of money laundering.

We continuously update our processes to maintain the highest level of compliance and player protection.

Money Laundering Definition

Money laundering refers to the process of disguising the source of funds obtained from criminal activities to make them appear legitimate. It includes:

  • Transferring or converting assets known to come from criminal activity to hide their illegal origin or help others avoid legal consequences.

  • Concealing or misrepresenting the true nature, source, location, ownership, or movement of assets obtained through crime.

  • Acquiring, possessing, or using property while knowing it was derived from criminal acts.

  • Assisting, facilitating, or attempting to carry out any of the actions listed above.

Money laundering is treated as an offence regardless of where the original crime took place—whether within another EU Member State or a third country.

At [Casino Name], we are fully committed to preventing our platform from being used for criminal, fraudulent, or money-laundering purposes. Our AML measures include strict identity verification, transaction monitoring, and compliance with international regulations to ensure a secure and transparent gaming environment.

 
 
Crime & Disorder and AML policy

Our AML policy is built on strong governance, accountability, and compliance with international standards. The following principles guide our approach:

  • We implement systems and controls designed to meet all legal and regulatory AML requirements relevant to our business operations.

  • We assess AML risks annually, adopting a risk-based approach that is flexible, effective, and proportionate to the scale of our activities.

  • Senior management takes full responsibility and provides ongoing commitment to ensure compliance with AML obligations.

  • We regularly review and improve our systems and controls to ensure they remain effective and up to date.

  • We maintain accurate transaction records to support potential law enforcement or regulatory investigations related to money laundering or terrorist financing.

  • We provide comprehensive AML training for all relevant employees, both during onboarding and on a continuous basis.

  • We ensure our nominated AML officer is given the necessary resources, authority, and independence to carry out their responsibilities objectively and effectively.

Organization of AML According to GemBet Casino

In accordance with Anti-Money Laundering (AML) legislation, online casinos must maintain the highest standards of prevention against money laundering and financial crime.

To ensure full compliance, a designated Anti-Money Laundering Compliance Officer (AMLCO) is appointed. The AMLCO is responsible for implementing, monitoring, and enforcing the AML Policy across all operations.

The AMLCO operates under the direct supervision of senior management, ensuring transparency, accountability, and strict adherence to regulatory requirements.

Requirements for AML Policy Changes

All major amendments to the Anti-Money Laundering (AML) Policy must be approved jointly by the General Management and the Anti-Money Laundering Compliance Officer (AMLCO).
This process ensures full transparency in all betting activities, account registrations, and player verification procedures.

Specific Regulations

The Company is fully committed to maintaining regulatory compliance across all areas of its operations. We operate under a valid Curaçao Gaming License, which authorizes us to provide and manage Games of Chance for the international market through approved online service channels.

Fiat and Crypto Withdrawal Policy

To ensure compliance and security, all withdrawals must follow the same method used for deposits:

  • If your last deposit was made using a fiat payment method, the withdrawal must also be processed in fiat.

  • If your last deposit was made using cryptocurrency, the withdrawal must also be made in cryptocurrency.

  • Cross-withdrawals between fiat and crypto are not permitted — you cannot deposit in fiat and withdraw in crypto, or vice versa.

  • Winnings accumulated from a specific deposit type (fiat or crypto) must be withdrawn using the same method used for that gameplay.

  • Any attempt to bypass this policy may result in account review, delay, or restriction.

Three Steps of Verification

To comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations, all users must complete the verification process in stages based on their transaction activity:

  • Step 1 – Basic Verification:
    Required for all users before making a withdrawal.
    This step includes self-identification and submission of basic personal details such as full name, address, and contact information.

  • Step 2 – Identity Verification:
    Required for any user who deposits or withdraws over USD 2,000.
    This step involves submitting a valid government-issued ID (e.g., passport, driver’s license, or national ID card) to confirm your identity.

  • Step 3 – Source of Funds Verification:
    Required for users who deposit or withdraw over USD 5,000.
    This step involves providing proof of source of funds (e.g., bank statements, income documentation, or employment proof) to verify that the funds originate from legitimate sources.

Customer Identification and Verification (KYC)

Formal customer identification is a key requirement under both Anti-Money Laundering (AML) regulations and our Know Your Customer (KYC) policy. This process ensures that all users are properly verified before entering into any financial or gaming relationship with the Company.

Identification is based on the following core principle:

  • Each customer must provide a valid copy of a government-issued document, such as a passport, national ID card, or driver’s license.

In certain cases, our compliance team may conduct additional verification checks if circumstances require further confirmation of identity or legitimacy.

Proof of Address

Proof of address is verified through electronic validation using two independent databases to ensure accuracy and authenticity.

If electronic verification cannot be completed successfully, the user will be required to submit valid proof of address manually (such as a recent utility bill, bank statement, or official government correspondence).

In certain cases, our compliance team may conduct additional checks if further verification is deemed necessary based on the situation.

Source of Wealth

When a customer deposits more than USD 5,000, a Source of Wealth (SOW) verification will be required to confirm the origin and legitimacy of the funds used. This step helps ensure compliance with international Anti-Money Laundering (AML) standards.

Acceptable examples of Source of Wealth include:

  • Business ownership or self-employment income

  • Salaried employment or professional earnings

  • Inheritance or estate distributions

  • Investment income, such as dividends or asset sales

  • Family funds or legitimate financial support

If deposits exceeding this threshold are made—either in a single transaction or cumulatively—the account will be temporarily frozen until verification is completed. The user will receive an email notification requesting documentation to support their Source of Wealth.

Essential Info for Step One

Players can access the registration form through the settings page on the casino website. During sign-up, every user is required to provide the following personal details:

  • First Name

  • Last Name

  • Nationality

  • Gender

  • Date of Birth

All submitted information is securely processed and stored using AI-based systems to ensure accuracy and data protection.
In certain cases, our compliance team may conduct additional manual verification checks to confirm the authenticity of the information provided.

Sanctions, Persons, and Entities of Special Interest, PEPs

To ensure full compliance with international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations, we conduct regular screenings using global Politically Exposed Persons (PEP) and Sanctions databases.

These databases are compiled from government and official public sources and may include:

  • International sanctions lists

  • Political and government official registries

  • Public procurement ban lists

  • Known terrorist and criminal watchlists

  • Other verified data sources relevant to compliance and investigative reporting

All screenings help identify and prevent business relationships with individuals or entities involved in high-risk, politically exposed, or sanctioned activities.

Risk Management

To effectively manage varying levels of financial and compliance risks, the casino classifies all countries into three distinct risk regions based on their regulatory standards, financial transparency, and economic conditions.

Region 1 – Low Risk

  • Standard three-step verification applies to all users from low-risk countries.

  • Verification thresholds follow the default deposit and withdrawal limits defined in our AML and KYC policies.

Region 2 – Medium Risk

  • Enhanced verification is required at lower transaction thresholds:

    • Step 1: Basic verification (upon account creation or withdrawal request).

    • Step 2: ID verification required when depositing or withdrawing USD 1,000 or more.

    • Step 3: Source of funds verification required when depositing or withdrawing USD 2,500 or more.

  • Users from low-risk regions who exchange cryptocurrency (e.g., BTC or ETH) for other currencies will be treated as medium-risk clients.

Region 3 – High Risk

  • Users from high-risk countries are prohibited from registering or participating on the platform.

Additional Measures

An AI-driven monitoring system, supervised by the Anti-Money Laundering Compliance Officer (AMLCO), continuously analyzes user activity to identify and flag any unusual or suspicious behavior.
Any detected irregularities are immediately reported to the GemBet Casino compliance team for review.

Based on the risk level and circumstances, our human compliance personnel will reassess and verify all checks previously conducted by the AI system or other staff. If necessary, additional manual investigations may be performed to ensure full compliance with AML regulations and internal security protocols.

Enterprise-Wide Risk Assessment

To identify and manage the specific money laundering and financial crime risks associated with online casino operations, the Company conducts an Enterprise-Wide Risk Assessment (EWRA).

This assessment evaluates and documents risks linked to:

  • The types of services offered on the website

  • The profiles and behaviors of clients using those services

  • The nature and volume of transactions conducted

  • The delivery channels through which services are accessed

  • The geographical regions where the Company operates

  • Other qualitative and emerging risks relevant to the business

The AML Risk Policy is developed based on these findings, aligning with regulatory requirements, industry standards, and supervisory expectations.

The EWRA is reviewed and updated annually to ensure that all controls remain effective and proportionate to evolving risks within the online gaming industry.

On-Going Transactions Monitoring

Our AML compliance team ensures continuous monitoring of transactions to detect any activity inconsistent with a customer’s usual behavior or risk profile.

First Line of Control

The GemBet operations team works only with trusted Payment Service Providers (PSPs) that maintain strong AML and KYC frameworks, ensuring that all deposits are properly verified and authorized.

Second Line of Control

Casino staff are trained to apply enhanced due diligence during all interactions with customers or their authorized representatives.
A three-step verification process, guided by risk management principles, provides complete visibility into all clients.

Transactions are reviewed by AML personnel under the supervision of the AML Compliance Officer (AMLCO), who reports to general management. Any transactions that cannot be clearly linked to a legitimate activity or source of funds are classified as atypical and escalated to the AML division for further investigation.

Third Line of Control

As a final safeguard, casino managers conduct manual reviews of all high-risk and suspicious accounts to prevent money laundering and ensure compliance with internal and legal standards.

Reporting Suspicious Transactions at Online Casino

Internal procedures define when and how suspicious activities must be reported.
Following internal review, the AML team:

Determines whether a report should be submitted to the Financial Intelligence Unit (FIU), as required by law (Law of 18 September 2017); and

Decides whether to terminate the business relationship with the customer if necessary.

Procedures

All AML and KYC procedures are integrated into the casino’s operational guidelines available on the gambling portal. These align with the applicable AML legislation and industry best practices.

Keeping Records

All customer identification data and transaction records are retained for a minimum of ten (10) years following the end of the business relationship or the completion of the transaction, whichever is later.

Training

GemBet uses AI and machine learning to strengthen AML detection systems.
All personnel receive specialized training to monitor, review, and validate AI-driven decisions. Training programs are regularly updated to reflect the employee’s role, business function, and regulatory developments.

Auditing

An internal audit function periodically reviews AML operations, ensuring that policies, controls, and reporting processes remain compliant and effective.

Protecting our equipment from internal crime and criminal misuse

The Company recognizes that preventing internal fraud begins with protecting key assets.
Comprehensive processes and controls are integrated into daily operations to prevent misuse or unauthorized access to financial and information systems.

Data Security

All user data is stored securely and never shared or sold to third parties, except where required by law or AML regulations.
Information may be disclosed to relevant AML authorities only for the purpose of complying with anti-money laundering legislation.

GemBet strictly adheres to international data protection standards, including the EU Data Protection Directive (Directive 95/46/EC), ensuring customer privacy and data integrity at all times.

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