Introduction

1.1 This Anti-Money Laundering Policy is issued by Clarity Castle S.R.L. (the "Company", "We", "Us", "Our", "Website", “Spinvoyage”), a company registered and established under the laws of Costa Rica, with registration number 3-102-931758, and a registered address at PROVINCIA 01 SAN JOSE, CANTON 15 MONTES DE OCA, SAN PEDRO, LOS YOSES, AVENIDAS OCHO Y DIEZ, CALLE TREINTA Y NUEVE, SEGUNDA OFICINA A MANO DERECHA, LY CENTER.

1.2 We, as an Online Casino Operator, a potentially vulnerable industry to the threats of Money Laundering (the “ML”) and Terrorist Financing (the “TF”), understand and recognize the threat of the ML and TF to national and international security around the world.

1.3 The Company is fully committed to complying with all applicable Anti-Money Laundering (the “AML”) laws and regulations. We are committed to establish procedures to prevent and combat Money Laundering, Terrorist Financing, Fraud or any other criminal purpose through the misuse of Our Services.

1.4 This AML Policy is developed in alignment with international standards established by the Financial Action Task Force (the “FATF”) and applicable national legislation on Anti-Money Laundering. The Policy is designed to effectively prevent money laundering, terrorist financing, and other fraudulent activities by adhering to the highest legal and regulatory requirements.

1.5 The standards outlined in this AML Policy are based on the following legal frameworks, providing a robust and internationally recognized foundation for the procedures implemented to prevent the misuse of services offered by the Company:

EU AML Directive: Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for money laundering or terrorist financing.
Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006 (Text with EEA relevance).
Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash (Anti-Money Laundering Law).
Various Regulations: Imposing sanctions or restrictive measures against persons, embargoes on certain goods and technology, including dual-use goods.

The Company’s AML program, including the procedures maintained for the prevention of the misuse of its services, is fully compliant with these regulations.1.6 To comply with Anti-Money Laundering regulations, the Company has appointed a Compliance Officer to ensure compliance with this AML Policy, procedures and relevant AML legislation within the Company and the provision of the Services. The Compliance Officer works directly under the supervision of the Management.

1.7 Company has also put in place Know Your Customer (KYC) programs as an essential element for service, risk management and control procedures.

Such programs include:

Customer Registration/Acceptance;
Customer Identification/Verification;
On-going Monitoring of Client’ activity;
Risk Management;
Reporting of suspicious activities to respective authorities.

1.8 All Company Clients will acknowledge, undertake and agree to the following terms regarding their use of the Website, entering into trading activities with Company as a Company Client:

1.8.1 The Client will comply (throughout the time as a Company client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities;

1.8.2. The Company will operate under certain obligations known as “know-your-customer” obligations which grant Company the right to implement anti-money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity;

1.8.3. The Client agrees to lend full cooperation to the Company with respect to anti-money laundering efforts. This involves providing information that Company requests regarding Player Account, Website usage etc. to help Company perform its duties as dictated by applicable laws, regardless of jurisdiction;

1.8.4. The Company reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices;

1.8.5. The Company reserves the right to suspend or terminate any trading activity if there is reason to believe that services are used for activities that are deemed unlawful or fraudulent;

1.8.6. The Company has the right to use Client information for the investigation and/or prevention of fraudulent or otherwise illegal activities;

1.8.7. The Company has the right to share Client information with:
Investigative agencies or any authorized officers who are helping Company to comply with applicable law, including anti-money laundering laws and know-your-customer obligations;
Organizations that help Company provide the services it offers to its Clients;
Government, law enforcement agencies and courts;
Regulatory bodies and financial institutions.

Know Your Customer Procedure

2.1 The Company undertakes to monitor the Clients' activities in their Player Accounts to detect transactions that deviate from normal or expected Client behavior or to identify other suspicious activity.

2.2 To ensure safety and security in these areas, the Company has implemented the Client Activity Monitoring Measures:

2.2.1 Preventing the creation of multiple accounts - the Company has created a system for monitoring the Client's activity designed to detect attempts to create multiple accounts. Every time a Client requests a withdrawal, the system checks for duplicate accounts and determines whether the Client has used a fake proxy server. If duplicate accounts are found, all such accounts will be closed and the Client will be prohibited from opening any new accounts.

2.2.2 Monitoring of unusual transactions - if the Client makes unusual deposits that trigger system alerts, the Company will contact the Client to obtain an explanation for the unusual activity. If the Client fails to provide a satisfactory explanation or the required documentation, the Company will suspend the Player Account until the required information is provided. If the Client fails to provide the requested information within the individually determined period of time, the Player Account will be permanently closed. In addition, the Compliance Officerr may report a suspicious transaction to the relevant authorities.

2.2.3 Monitoring the Withdrawal of Funds - the Company allows withdrawing funds only to the original source - the Client's account from which the deposit was made. In individual cases, the Company may withdraw the Client's funds to another Client's account or to a third party account provided that the Client submits sufficient information and documentation at the Company's request to justify such withdrawal.

2.2.4 Usage of third-party services - The Company partners with the third-party service provider SumSub (https://sumsub.com/) to securely verify the identity of its Clients, ensuring compliance with regulatory requirements and safeguarding against fraud. SumSub offers a streamlined process for document verification, identity checks, and anti-money laundering (AML) compliance, allowing the Company to maintain a high level of trust and security while delivering a seamless user experience. This collaboration ensures that only legitimate players can access the platform, protecting both the Company and its Customers.

Risk Management

3.1 The Company has implemented a thorough verification and risk management strategy to ensure compliance with anti-money laundering and fraud prevention regulations. This policy integrates a comprehensive three-step verification process with continuous risk assessment procedures.

3.2 The Company applies continuous risk management measures throughout the entire period of its relations with Client. The Company checks the Сlient's identity against known databases of persons associated with criminal activity, prohibited persons, terrorism, politically exposed persons, etc. This risk assessment also includes an analysis of the Client's background, country of origin, source of funds and transaction patterns.

3.3 For Clients or transactions identified as high-risk - due to the size of the transaction, frequency of activity or unclear sources of funding - the Company applies enhanced due diligence. This may include more thorough checks or even a ban on deposits from high-risk regions. The decision to apply these measures is made at the Company's discretion.

3.4 The Company is obliged not only to establish the identity of its Clients, but also to monitor Player Account activity to determine those transactions that do not conform with the normal or expected transactions for that customer or type of account. Our Know Your Client (KYC) procedure constitutes a core feature of services’ risk management and control procedures. The intensity of KYC programs beyond these essential elements is tailored to the degree of risk.

Initial verification:

3.5 Every Client is required to complete an Initial Verification. This first step requires the Client to provide Personal Information such as full name, date of birth, citizenship, phone number and address of registration.

Verification for large transactions

3.6 When the Client's activity reaches certain financial thresholds - the turnover is equal to or exceeds EUR 2000 EUR (or equivalent in another currency) the enhanced verification shall be applied. The rule applies regardless of whether the deposit/withdrawal is made in a single transaction or in several transactions that seem to be related. At this step, the Client is required to provide a photo of their official identity document along with a document confirming the Client's residential address. The Company will verify the validity of the information provided during the initial verification via third party service SumSub. Funds related to the transaction will remain suspended until the verification is completed.

Verification of the source of funds for high volume transactions

3.7 For large volume transactions and for Clients, Clients are required to complete the third level of verification, which includes providing detailed documentation of the source of funds. This step is designed to ensure that the financial resources used in transactions are legitimate. Until the Client completes this verification, the Company suspends the transaction.

3.8 By integrating these stages of verification with risk management procedures, the Company ensures that all customer activity is monitored and controlled in accordance with the highest standards of compliance, thereby minimizing the risk of illegal activity.More details on the player verification process can be found in the KYC Policy.

Reporting

4.1 The Company monitors transactions in accordance with this AML Policy. Transactions that the Company considers suspicious, in particular those for which the Clients have not provided sufficient information and documentation to justify the transactions, may be referred to the Regulatory Authority.

4.2 When any member of staff either knows, suspects or has reasonable grounds for knowing or suspecting that a money laundering offence has been or is being committed they must make a Suspicious Activity Report (SAR).

4.3 Staff are not required to actively search for indications that money laundering offences are occurring. However if they become aware of, or suspect that, such offences are occurring during the course of their normal duties then they shall make a SAR.

4.4 The Company is obliged to keep records of all cases of suspicious transactions. In particular, the Company will keep records of all cases of reporting to the Regulatory Authority and all cases when the Company did not consider it required to notify the Regulatory Authority. All decisions to report or not to report must be sufficiently reasoned.

Recordkeeping

5.1 The Company is committed to maintaining comprehensive records in compliance with regulatory requirements.

Information and documents required to identify the Client;
Information and documentation provided by the Client during the Verification procedure;
Information about the Client's activity on the Website;
Information on incoming and outgoing transactions conducted by the Client.
Documentation of actions taken in relation to suspicious transactions, regardless of whether or not reports are submitted to the Regulatory Authority.

5.2 All records, including those related to the Client's Personal Information and transaction data, will be securely stored, with encryption to ensure their security. The Company informs that these records can be promptly provided upon request of the responsible Public Authorities.

Contact Us

6.1 Should You have any questions about this Anti-Money Laundering Policy, please contact Our Support Team: [email protected]. We are always happy to help.