This Anti-Money Laundering and Know Your Customer Policy ("Policy") applies to all players who register and conduct transactions at Betspino Casino, operated at betspino-casino.bet by Cashbit Group N.V. under Curaçao eGaming licence #157923. Betspino is committed to preventing money laundering, terrorist financing, and all other forms of financial crime, and to meeting the obligations imposed by its licence and applicable international standards. By opening an account and using the services at betspino-casino.bet, you accept and agree to comply fully with this Policy.

1. Legal Framework and Regulatory Basis

Cashbit Group N.V. holds a gaming licence issued by Curaçao eGaming (licence #157923) and operates betspino-casino.bet in accordance with that licence's conditions. This Policy is designed to satisfy the anti-money laundering and counter-terrorist-financing ("AML/CTF") requirements established under that regulatory framework, as well as internationally recognised standards including the Financial Action Task Force ("FATF") Recommendations.

Betspino will not knowingly facilitate, permit, or ignore any activity that may constitute money laundering, fraud, identity theft, or the financing of terrorism. Any suspected or confirmed breach of this Policy may be reported to the relevant authorities without prior notice to the account holder.

2. Definitions

• Money Laundering: The process by which proceeds of crime are converted into apparently legitimate funds or assets.
• Terrorist Financing: The provision or collection of funds with the intention or knowledge that they will be used to carry out terrorist acts.
• KYC (Know Your Customer): The set of identification and verification procedures Betspino applies to confirm the identity, age, source of funds, and legitimacy of each player.
• CDD (Customer Due Diligence): The standard level of KYC checks applied to all players.
• EDD (Enhanced Due Diligence): A heightened level of verification applied to higher-risk players, including Politically Exposed Persons and high-volume transactors.
• PEP (Politically Exposed Person): An individual who holds or has held a prominent public position, or who is a close associate or family member of such a person.
• SAR (Suspicious Activity Report): An internal or external report filed when a transaction or pattern of activity is reasonably suspected to involve money laundering or other financial crime.
• MLRO (Money Laundering Reporting Officer): The designated compliance officer at Cashbit Group N.V. responsible for receiving, reviewing, and escalating SARs.

3. Scope of This Policy

This Policy applies to:

• All registered players at betspino-casino.bet;
• All deposits, withdrawals, and other financial transactions conducted through the platform;
• All payment methods accepted at Betspino, including iDEAL, Trustly, Visa, Mastercard, Skrill, Neteller, Apple Pay, Paysafecard, and cryptocurrency transactions in Bitcoin, ETH, LTC, USDT, DOGE, and XRP;
• All promotional transactions, including welcome bonuses, reload bonuses, cashback, and VIP rewards;
• All members of the Betspino VIP programme, who by virtue of higher cumulative play volumes are subject to ongoing enhanced monitoring.

4. Risk-Based Approach

Betspino adopts a risk-based approach to AML and KYC compliance. This means that the level of due diligence applied to any individual player is proportionate to the assessed risk that their account and transactions may be associated with financial crime. Risk is assessed across several dimensions:

• Player risk: Age, country of residence, PEP status, and adverse media screening results.
• Product and channel risk: Payment method used, volume and frequency of transactions, and the nature of gaming activity (e.g., use of high-limit live tables or high-volume crypto transactions).
• Geographic risk: Whether the player's country of residence or the origin of funds is associated with elevated money-laundering or corruption risk according to FATF or equivalent guidance.
• Behavioural risk: Patterns of play, deposit and withdrawal behaviour, and changes in transactional profile over time.

Players assessed as lower risk may have their identity verified on the basis of standard documentation. Players assessed as higher risk — including high-volume depositors and withdrawers, PEPs, or those exhibiting unusual transactional behaviour — will be subject to Enhanced Due Diligence and may be required to provide additional documentation before continued use of the platform is permitted.

5. Customer Due Diligence (CDD) — Standard Verification

5.1 When KYC Is Required

KYC checks are mandatory in the following circumstances:

• Before any withdrawal is processed. As stated in Betspino's terms, your first withdrawal requires completed KYC — once cleared, subsequent withdrawals follow the standard processing schedule.
• When cumulative deposits or withdrawals reach thresholds that trigger verification under Betspino's internal risk procedures.
• When Betspino's risk monitoring systems flag unusual or suspicious activity on an account at any time.
• When a player accesses higher-limit games or advances to a higher tier within the VIP programme.
• At any point that Betspino, in its reasonable discretion, determines that verification is required to satisfy its compliance obligations.

5.2 Identity Verification

To verify your identity, Betspino will request one or more of the following:

• A valid, government-issued photo identity document — passport, national identity card, or driving licence;
• A selfie or live photograph holding the identity document, as directed by Betspino's compliance team;
• Confirmation that the name, date of birth, and address on the document match the details registered on your betspino-casino.bet account.

5.3 Proof of Address

Betspino may request a proof-of-address document, which must:

• Be dated within the last three months;
• Display your full name and residential address as registered;
• Be issued by a recognised institution — for example, a utility bill, bank statement, or official government correspondence.

5.4 Age Verification

Betspino operates a strict minimum-age policy. No player under the age of 18 may register or hold an account at betspino-casino.bet. Age is verified as part of the standard identity check. Where Betspino has reasonable grounds to believe a player may be under 18, the account will be suspended pending verification, and any funds held will be dealt with in accordance with applicable regulations and licence conditions.

5.5 Verification of Payment Methods

To confirm that payment methods belong to the registered account holder and to prevent third-party funding, Betspino may request:

• For card payments (Visa, Mastercard): a photograph or screenshot of the card used, showing the cardholder name and the first six and last four digits, with all other digits obscured;
• For e-wallets (Skrill, Neteller): confirmation of the registered email address and, where required, a screenshot of the e-wallet account showing the name;
• For bank transfers: a bank statement or screenshot confirming account holder details;
• For cryptocurrency deposits and withdrawals (Bitcoin, ETH, LTC, USDT, DOGE, XRP): confirmation of wallet ownership and, where EDD applies, evidence of the origin of the funds.

Betspino maintains a same-method withdrawal policy wherever operationally possible — withdrawals are returned to the same method used for the corresponding deposit. This reduces the risk of third-party fund transfers and supports transaction traceability.

6. Enhanced Due Diligence (EDD)

EDD is applied where a player or transaction presents an elevated risk profile. Circumstances that may trigger EDD include:

• The player is identified or self-declared as a Politically Exposed Person or a close associate or family member of a PEP;
• The player's deposit or withdrawal volumes are high relative to their stated profile — for context, Betspino imposes a withdrawal cap of €10,000 per week and €20,000 per month, and players regularly approaching these limits will be subject to ongoing review;
• The player is a high-tier VIP member whose cumulative play volume warrants a more detailed financial profile;
• The player's country of residence or the source of transferred funds carries an elevated risk rating;
• The player's transactional behaviour has changed materially without a clear explanation.

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

• Source of funds declaration and supporting documentation (e.g., payslips, employment contract, tax returns, business accounts, investment statements, inheritance records);
• Source of wealth declaration — an explanation of how the player's overall wealth was accumulated;
• Bank statements covering a defined period relevant to the transactions under review;
• Any additional information or documentation that Betspino's compliance function considers necessary to complete the risk assessment.

Until EDD requirements are satisfied, Betspino reserves the right to restrict the account, suspend withdrawals, and limit access to certain games or features.

7. Ongoing Monitoring

KYC is not a one-time event. Betspino conducts continuous monitoring of player accounts and transactions throughout the customer lifecycle. Monitoring activities include:

• Automated review of deposit and withdrawal patterns against each player's established profile;
• Screening against PEP, sanctions, and adverse media databases at registration and on an ongoing basis;
• Periodic re-verification of existing players where the risk assessment indicates that documentation on file may be outdated or insufficient;
• Review of game play patterns for behaviour inconsistent with genuine recreational gaming — for example, deliberate loss strategies, rapid cycling of funds through low-risk bets, or unusual bonus utilisation patterns;
• Monitoring of cryptocurrency transactions in light of their higher inherent anonymity risk, with particular attention to wallet provenance and transaction history where EDD applies.

Where monitoring identifies activity that cannot be adequately explained, Betspino will escalate the matter internally to the MLRO and, where appropriate, file a report with the relevant authorities.

8. Suspicious Activity Reporting

Betspino maintains internal procedures for the identification, escalation, and reporting of suspicious activity. All relevant staff are trained to recognise potential indicators of money laundering, including but not limited to:

• Deposits immediately followed by withdrawal requests with little or no gaming activity;
• Multiple small deposits made in rapid succession that, when aggregated, constitute a significant sum (structuring);
• Use of multiple payment methods or frequent changes to withdrawal methods without clear justification;
• Requests to withdraw to a different method or third party than the one used for deposit;
• Apparent disinterest in game outcomes combined with a pattern of recycling funds;
• Inconsistency between a player's stated occupation or financial profile and the volume of transactions processed;
• Use of cryptocurrency in a manner designed to obscure the origin or destination of funds.

Where suspicious activity is identified, the MLRO will review the matter and determine whether to file an external report with the competent authorities. Players will not be informed ("tipped off") that a report has been made or is under consideration.

9. Sanctions Screening

Betspino screens all new registrations and existing players against applicable international sanctions lists, including those maintained by the European Union, the United Nations, and OFAC. Players who are identified as sanctioned individuals or entities will have their accounts blocked immediately, and any funds held will be dealt with in accordance with applicable sanctions obligations and licence conditions. Betspino also refuses service to players in jurisdictions subject to comprehensive sanctions or otherwise excluded under its licence terms.

10. Prohibited Activities

The following activities are strictly prohibited on betspino-casino.bet and may result in immediate account suspension, withholding of funds, and referral to the relevant authorities:

• Depositing funds derived from illegal activity;
• Using the platform to launder money or finance terrorism;
• Providing false, incomplete, or misleading information during registration or at any point during KYC;
• Using a payment method registered in the name of a third party;
• Operating multiple accounts for the purpose of circumventing verification or withdrawal limits;
• Attempting to exploit promotional offers (including the three-deposit welcome package, cashback, and reload bonuses) in a manner inconsistent with genuine recreational play;
• Conducting transactions structured to avoid triggering verification thresholds.

11. Document Submission and Verification Timelines

When Betspino requests KYC documentation, players are expected to provide the requested materials promptly. The following applies:

• Betspino will notify players clearly of the documents required and the preferred method of submission;
• Verification is typically completed within 24–72 hours of receipt of a complete set of documents, subject to the complexity of the review;
• Where documents are incomplete, illegible, or insufficient, Betspino will request alternatives or additional materials — the timeline restarts upon receipt of the corrected submission;
• Withdrawals — including those requested via Skrill, Neteller, Visa, Mastercard, bank transfer, and supported cryptocurrencies — will not be processed until KYC is complete. Standard published payout speeds (same day for crypto, 1–24 hours for e-wallets, 3–5 business days for bank transfer) apply from the point of verification approval, not from the point of withdrawal request.

12. Withdrawal Limits and Transaction Monitoring

Betspino enforces published withdrawal limits that also serve an AML function by capping the volume of funds that can be extracted from the platform within any given period. These limits are:

Withdrawals exceeding €5,000 in value are automatically split across multiple transactions. Players who consistently approach weekly or monthly withdrawal caps are subject to enhanced transactional monitoring and may be required to provide source of funds documentation before further withdrawals are authorised.

13. Cryptocurrency Transactions

Betspino accepts deposits and processes withdrawals in Bitcoin, ETH, LTC, USDT, DOGE, and XRP. Whilst cryptocurrency transactions are processed with the same speed and no-fee commitment as other payment methods, they carry a higher inherent anonymity risk and are therefore subject to additional compliance considerations:

• All cryptocurrency wallets used for deposits or withdrawals are logged and associated with the player's verified account;
• Betspino may use blockchain analytics tools to assess the risk profile of wallets and transactions — including screening for addresses associated with known illicit activity;
• Players using cryptocurrency who are subject to EDD may be required to demonstrate ownership of the sending wallet and provide evidence of the legitimate origin of the funds;
• Withdrawals in cryptocurrency will be returned to the same wallet address used for the corresponding deposit wherever technically possible.

14. Responsible Gaming and AML Interaction

Betspino recognises that responsible gaming controls and AML monitoring are complementary. Unusual or compulsive patterns of play may simultaneously indicate a problem gambling situation and flag a potential financial crime concern. Where monitoring identifies behaviour consistent with disordered gambling, Betspino's responsible gaming procedures will be applied alongside any required compliance measures. Players can access responsible gaming tools — including deposit limits, session limits, self-exclusion, and cooling-off periods — directly through their account settings at betspino-casino.bet or by contacting the 24/7 support team via live chat or email.

15. Staff Training and Internal Controls

Cashbit Group N.V. maintains a programme of regular AML and KYC training for all relevant staff involved in player onboarding, payments processing, customer support, and compliance. Training covers recognition of suspicious activity indicators, escalation procedures, and the requirements of this Policy. Internal controls are reviewed periodically and updated in response to regulatory developments, emerging risk typologies, and any material changes to Betspino's product or player base.

16. Record Keeping

Betspino retains all KYC documentation, transaction records, and compliance-related communications for a minimum of five years from the date of the last transaction or account closure, whichever is later. Records are stored securely and are accessible to the MLRO and to competent regulatory or law enforcement authorities upon lawful request.

17. Player Cooperation

Players at betspino-casino.bet are required to cooperate fully with all KYC and AML procedures. This includes:

• Providing accurate and complete information at the point of registration;
• Responding promptly to any request for identity, address, or source of funds documentation;
• Notifying Betspino of any material change in personal circumstances that may affect the accuracy of information held on file;
• Refraining from any action designed to circumvent, delay, or frustrate the verification process.

Failure to cooperate may result in suspension of deposit and withdrawal functionality, cancellation of pending bonus credits, and — in cases where Betspino has reasonable grounds to suspect financial crime — referral to the appropriate authorities.

18. Updates to This Policy

Betspino reserves the right to amend this AML / KYC Policy at any time to reflect changes in applicable law, regulatory guidance, licence conditions, or internal risk assessments. Material changes will be communicated to players via the website at betspino-casino.bet. Continued use of the platform following the publication of an updated Policy constitutes acceptance of the revised terms.

19. Contact

If you have questions about this Policy or wish to submit KYC documentation, please contact the Betspino compliance team through any of the following channels:

• Live chat: Available 24/7 at betspino-casino.bet, with Dutch-language support available;
• Email: Via the contact address published on the betspino-casino.bet support page.

For responsible gaming support, the same contact channels apply. Betspino is committed to maintaining a safe, fair, and legally compliant environment for all players.