This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Stegi Limitada Sociedad De Responsabilidad Limitada ("the Operator", "we", "us", "our"), the company behind spinalto, operated at spinaltoscasino.nl, to detect, prevent and report financial crime. All players, whether using the casino, live casino, sportsbook or any other product available at spinaltoscasino.nl, are subject to this Policy as a condition of holding an account and transacting on the platform.

1. Introduction and Purpose

Money laundering is the process by which funds derived from criminal activity are introduced into the legitimate financial system and made to appear lawful. Terrorist financing involves the provision or collection of funds intended to support terrorist acts or organisations. Both represent serious threats to the integrity of online gaming and to wider society.

spinalto is committed to operating in full compliance with applicable anti-money laundering ("AML") and counter-terrorist financing ("CTF") legislation and standards. This Policy exists to:

• establish clear internal controls and procedures to prevent the platform from being used to launder money or finance terrorism;
• define the customer due diligence ("CDD") and enhanced due diligence ("EDD") requirements that apply at account registration and throughout the customer lifecycle;
• ensure that all suspicious activity is identified, recorded and reported to the appropriate authorities without delay;
• set out the training and record-keeping obligations that apply to all staff involved in the operation of spinaltoscasino.nl.

This Policy applies to every account opened at spinaltoscasino.nl regardless of the player's country of residence, the payment method used, or the currency in which the account is denominated.

2. Regulatory Framework

spinalto is operated by Stegi Limitada Sociedad De Responsabilidad Limitada, a company incorporated in Costa Rica and operating under a Costa Rica gaming licence. While the Operator acknowledges that its primary licence is issued by Costa Rica, it takes a risk-based approach to AML and CTF compliance that reflects the standards set by the Financial Action Task Force ("FATF") and best practice across the international iGaming sector. Accordingly, this Policy incorporates principles drawn from leading AML/CTF frameworks and applies them consistently across all markets served by spinaltoscasino.nl.

3. The Money Laundering Risk in Online Gaming

Online casinos present specific money laundering typologies that differ from those encountered in traditional financial services. Common risk indicators in the online gaming environment include, but are not limited to:

• deposits made across multiple payment instruments in rapid succession with little or no subsequent play;
• patterns of play designed to generate a withdrawal rather than to seek genuine entertainment;
• large deposits funded by sources that are inconsistent with the player's known financial profile;
• use of cryptocurrencies — including Bitcoin, USDT and Ethereum, all of which are accepted at spinaltoscasino.nl — without adequate explanation of the origin of funds;
• requests to withdraw to a payment method different from the one used to deposit;
• involvement of politically exposed persons ("PEPs") or individuals subject to international sanctions;
• account activity consistent with third-party funding or collusion between multiple accounts.

Our risk-based approach means that the level of scrutiny applied to any player and any transaction is proportionate to the risk that player or transaction presents.

4. Know Your Customer (KYC) Policy

4.1 General Principles

spinalto operates a mandatory KYC programme. No withdrawal will be processed, and no bonus (including the five-stage welcome pack worth up to €6,000 + 300 Free Spins) will be released to a player's real-money balance, until all applicable identity verification requirements have been satisfied. We reserve the right to request KYC documentation at any point during the account lifecycle, including at registration, before processing any withdrawal, upon reaching defined deposit or activity thresholds, or whenever a change in player behaviour triggers an AML risk flag.

4.2 Standard Customer Due Diligence (CDD)

Standard CDD is required of all players. To complete standard CDD, a player must provide documents sufficient to verify the following:

• Identity: a valid government-issued photo identity document such as a passport, national identity card, or driving licence showing the player's full legal name and date of birth;
• Address: a proof of residential address issued within the preceding three months, such as a utility bill, bank statement, or official government correspondence, showing the player's full name and current address;
• Age: confirmation that the player is at least 18 years of age, as evidenced by the identity document submitted.

Documents must be clear, legible, and unaltered. Digital copies, scans and photographs are accepted provided they show all four corners of the document and all security features are visible. Documents that are expired, cropped, or otherwise unclear will not be accepted and the player will be asked to resubmit.

4.3 Payment Method Verification

In addition to identity and address documentation, spinalto requires verification of all payment methods linked to an account. This is to confirm that the player is the legitimate owner of the payment instrument and to prevent fraudulent chargebacks and third-party funding. Depending on the method used, verification may include:

• Visa / Mastercard: a copy of the card showing the cardholder name, expiry date, and last four digits (the middle eight digits and the CVV must be obscured);
• Apple Pay / Google Pay / Revolut: confirmation that the digital wallet or e-money account is registered in the same name as the spinalto account;
• Bitcoin / USDT / Ethereum: wallet ownership verification; the Operator may require a signed message from the originating wallet address or equivalent proof of ownership, together with information about the source of the cryptocurrency funds where the risk level warrants it.

A minimum deposit of €20 applies across most methods, and a minimum withdrawal of €40 applies. Withdrawal limits are capped at €10,000 per day, €20,000 per week, and €50,000 per month. These limits remain in force even where a player has passed all KYC checks, and may be further restricted pending the completion of enhanced due diligence.

4.4 Enhanced Due Diligence (EDD)

Enhanced due diligence is applied when the standard risk assessment indicates that a player's activity presents a higher level of AML or CTF risk. EDD will be triggered automatically or on a discretionary basis in circumstances including, but not limited to:

• cumulative deposits or activity levels exceeding internal thresholds set by the Operator's compliance team;
• a player depositing €1,000 or more in a single transaction (including those seeking Instant VIP status);
• players reaching higher VIP tiers such as Volt Class, Noir Elite or Apex Glow, where significant cashback (up to 15%) or rakeback (up to 5%) benefits accrue;
• use of cryptocurrency payment methods for high-value transactions;
• inconsistency between a player's stated occupation or financial profile and the volume or frequency of their deposits;
• a player identified as a politically exposed person or a close associate or family member of a PEP;
• a player appearing on a national or international sanctions list;
• any transaction or pattern of activity flagged by our automated monitoring systems as suspicious.

Under EDD, the Operator may request one or more of the following in addition to standard CDD documents:

• a recent payslip, employment contract, or letter from an employer confirming salary;
• the most recent tax assessment or tax return;
• bank or investment account statements for the preceding three to six months;
• documentation evidencing a windfall, inheritance, business sale, or other non-employment source of funds;
• a signed source-of-funds declaration;
• for cryptocurrency deposits, blockchain transaction records and, where applicable, documentation of the original acquisition of the cryptocurrency.

A player who is unable or unwilling to provide EDD documentation will have their account suspended pending further review. Funds held in the account will not be released until compliance is satisfied or a determination is made in accordance with applicable law.

4.5 Ongoing Monitoring

KYC is not a one-time exercise. spinalto conducts ongoing monitoring of all active accounts throughout the customer relationship. This includes:

• automated transaction monitoring to detect deposits, withdrawals, and betting patterns that deviate significantly from a player's established profile;
• periodic review of player profiles, with the frequency of review proportionate to the risk rating assigned to each account;
• re-verification when a player updates their personal details, adds a new payment method, or their activity triggers a new risk flag;
• screening of all player names against up-to-date sanctions lists and PEP databases on an ongoing basis.

4.6 Timing of Verification

spinalto aims to process KYC submissions within two business days, consistent with the payout speed stated on the platform. Players are encouraged to submit their documents proactively after registration rather than waiting until a withdrawal request is made. Submitting documents early reduces delays and ensures that the payout processing timeline of within two banking days can be met without interruption. The Operator reserves the right to place a hold on withdrawals until all KYC and AML checks are complete, regardless of the stated processing timeframe.

5. Politically Exposed Persons (PEPs) and Sanctions Screening

A politically exposed person is an individual who holds or has held a prominent public function, including heads of state or government, senior politicians, senior government officials, senior judicial or military officials, senior executives of state-owned enterprises, and senior officials of major political parties. Immediate family members and known close associates of PEPs are treated on an equivalent basis for screening purposes.

All players are screened against PEP and sanctions databases at registration and on an ongoing basis. Where a player is identified as a PEP, their account will automatically be escalated for EDD. Business relationships with PEPs are not automatically refused, but they are subject to senior management approval, enhanced ongoing monitoring, and mandatory source-of-funds and source-of-wealth documentation.

Any player whose name appears on a national or international sanctions list — including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control ("OFAC"), or HM Treasury — will have their account suspended immediately and the matter referred to the Operator's Money Laundering Reporting Officer ("MLRO") without delay.

6. Suspicious Activity Reporting

spinalto maintains internal procedures for the identification, documentation, and reporting of suspicious activity. All members of staff with access to player accounts are trained to recognise suspicious activity indicators and are required to report any concerns to the MLRO without tipping off the player concerned.

The MLRO is responsible for:

• receiving and evaluating all internal suspicious activity reports;
• making a determination as to whether an external report to the relevant financial intelligence unit or regulatory authority is required;
• maintaining a register of all internal reports received and the decisions taken in respect of each;
• ensuring that no employee discloses to a player that they have been or may be the subject of a suspicious activity report (the "tipping-off" prohibition).

Where the MLRO determines that a suspicious activity report ("SAR") should be filed externally, this will be done as promptly as possible and in any event within the timescale required by applicable law. Processing of transactions relating to the account in question may be suspended while the SAR is under consideration.

7. Record Keeping

spinalto retains all KYC documentation, transaction records, account activity logs, and AML-related correspondence for a minimum of five years from the date of the relevant transaction or the closure of the relevant account, whichever is later. Records are stored securely and are accessible to the MLRO and senior compliance personnel at all times. All records will be made available to competent authorities upon lawful request.

Records retained include:

• copies of all identity and address documents collected during CDD and EDD;
• details of all deposits and withdrawals, including method, amount, currency, and timestamp;
• a complete log of all payment methods verified per account, including Visa, Mastercard, Apple Pay, Google Pay, Revolut, Bitcoin, USDT and Ethereum;
• all internal suspicious activity reports and the MLRO's determinations;
• copies of all external SARs filed;
• records of all PEP and sanctions screening results.

8. Staff Training

All members of staff who have responsibility for player-facing functions, account management, compliance monitoring, or financial operations at spinaltoscasino.nl receive AML and KYC training at induction and at regular intervals thereafter. Training covers:

• the legal and regulatory framework applicable to AML and CTF in the online gaming sector;
• the types of suspicious activity most commonly encountered in online casinos and sportsbooks;
• the internal procedures for reporting suspicious activity to the MLRO;
• the tipping-off prohibition and its practical implications;
• the specific risks associated with cryptocurrency payments, including Bitcoin, USDT and Ethereum;
• the identification of PEPs and sanctioned individuals.

Records of all training delivered are maintained by the Operator's compliance function.

9. Risk-Based Approach

spinalto adopts a formal risk-based approach to AML and KYC. This means that the resources, controls and intensity of scrutiny applied to any player or transaction are proportionate to the risk assessed. Risk factors considered include:

Risk ratings are assigned at registration and reviewed dynamically throughout the customer relationship. Players may be moved between risk categories at any time without prior notice where a change in their activity warrants it.

10. Responsible Gaming and AML

spinalto recognises that problem gambling and money laundering are distinct issues, but that the monitoring systems used to identify one can assist in detecting the other. Behavioural indicators associated with disordered gambling — such as rapid, repeated deposits, erratic changes in wagering amounts, or a sudden marked increase in session frequency — may also be consistent with AML risk indicators and will be assessed from both perspectives.

Where a player is identified as potentially vulnerable, the Operator's responsible gaming procedures will be applied in parallel with any applicable AML controls. Players who wish to set deposit limits, take a cooling-off period, or self-exclude may contact our 24/7 support team via live chat or email at spinaltoscasino.nl. Responsible gaming measures do not override AML obligations: any funds held pending an AML investigation will remain unavailable regardless of any responsible gaming election made by the player.

11. Player Obligations

By opening and maintaining an account at spinaltoscasino.nl, each player agrees to:

• provide accurate and truthful information at registration and throughout the account lifecycle;
• notify spinalto promptly of any change in their personal details, including name, address, or payment methods used;
• submit KYC and EDD documentation promptly when requested and ensure that all documents submitted are genuine and unaltered;
• only deposit and wager funds that belong to them and that originate from a lawful source;
• not use third-party payment methods or act as an agent for another person in depositing or withdrawing funds;
• not engage in any activity on the platform that is intended or likely to constitute money laundering, terrorist financing, or fraud.

Breach of any of the above obligations may result in immediate account suspension, permanent closure, forfeiture of any bonus balance, and the filing of a report with the relevant authorities. spinalto will cooperate fully with law enforcement agencies in any investigation arising from suspected financial crime on the platform.

12. Consequences of Non-Compliance

Where a player fails to complete KYC or EDD requirements within a reasonable timeframe, or where verification checks raise concerns that cannot be resolved, the Operator may take any or all of the following steps:

• suspend access to deposits, withdrawals, and bonus features pending resolution;
• restrict or close the player's account;
• withhold funds pending a determination by the MLRO or, where applicable, a direction from a competent authority;
• file an internal or external suspicious activity report;
• report the matter to law enforcement or a relevant regulatory body.

The Operator will not be liable for any losses suffered by a player as a result of an account suspension or withdrawal hold imposed in good faith pursuant to this Policy.

13. Policy Review

This AML/KYC Policy is reviewed at least annually, or sooner if there is a material change in the applicable legal or regulatory framework, a significant change in the Operator's business model, or a finding from an internal or external audit that requires a policy update. The current version of this Policy is published at spinaltoscasino.nl and supersedes all previous versions. Players are responsible for checking the Policy periodically. Continued use of spinaltoscasino.nl following any update constitutes acceptance of the revised terms.

14. Contact

Questions or concerns relating to this Policy, or requests to submit KYC documentation, may be directed to the spinalto compliance team via the 24/7 live chat facility at spinaltoscasino.nl or by email using the address provided in the support section of the site. We aim to acknowledge all compliance correspondence within one business day and to resolve matters as quickly as possible consistent with our AML obligations.