AML & KYC Policy

Last Updated: 06/03/2023

Purpose of the AML Policy

At Spin24Star.com, we really care about making sure everyone who uses our platform is safe and properly verified. We have a system that’s basically three steps to check who you are, why you are depositing or withdrawing, and that the methods you use are actually yours. The whole point is to make sure that nobody uses our site in a way that can cause trouble, and also to follow the rules that are out there in Europe and other places.

Depending on where someone comes from and which method they use for deposit or withdrawal, different checks might apply. It’s a mix of automated systems, human checks, and some common sense to make things secure.

We take AML seriously. It’s a global thing, and our site wants to make sure we meet high standards. Our management team and everyone who works here must follow these rules strictly. Our AML system is designed to align with:

• EU: Directive 2015/849 on the prevention of misuse of financial systems for illegal activities.
• EU: Regulation 2015/847 regarding transfers of amounts and information.
• EU: Rules around sanctions and embargoes, including dual-use goods.
• BE: Law of 18 September 2017 on limiting credit use to prevent AML.

Basically, we want to know who is on our platform, how the credit flows, and what things are strange or suspicious.

Understanding AML 

AML can be defined as

• Moving or changing property (like credits) when you know it came from something illegal or shady.
• Hiding where things came from, who owns them, or how they are moved.
• Using property you know came from illegal stuff.
• Helping, trying, or advising anyone in doing these things.

Even if these actions happen outside our country, we treat them the same way.

Implementation of AML Guidelines at Spin24Star.com

The AML Compliance Officer, or in short AMLCO, is the main person who is responsible for making sure the rules of AML are followed within the system. AMLCO:

• Reports directly to general management.
• Approves any changes to the AML policy.

At Spin24Star.com, every change or update has to go through AMLCO before it goes live on the platform.

Verification Process

To identify the users and make the platform a secure playing environment, we follow the three-step verification process. 

First Step of Verification

Step one is the first basic check, where we ask for certain information about the users. Every user must complete this to be able to withdraw or make certain deposits. Step one is all about simple personal info, where a user has to fill out:

• First and last name
• Date of birth
• Country of residence
• Gender
• Full address

It’s just basic, but it’s important so that the system knows who is utilising it. This also helps prevent issues later if deposits or withdrawals seem unusual.

Second Step of Verification

Step two comes into play if someone deposits or withdraws larger amounts (over $2,000). Until step two is done, deposits or withdrawals are temporarily held.

This step involves sending a picture of an official ID with a handwritten 6-digit code next to it. Only government-issued IDs are accepted, but this might vary depending on the country.

Also, an electronic check is done to compare the Step One info with the ID. Two separate databases are used to make sure everything matches.

If the check fails or cannot be done electronically, users must provide proof of residence, such as:

• Government-issued certificate
• Utility bill, bank statement, or similar document

The goal is to confirm the person before he makes the deposit for the right transaction. 

Third Step of Verification

Step three verification is for very high deposits or withdrawals (over $5,000) or if sending larger amounts to another user (over $3,000). Until this step is completed, the transaction is on hold.

In this step, users need to provide information about the source of wealth. The idea is to make sure the origin of these larger deposits is legitimate. If there’s any doubt, our staff may ask for additional documents.

User Identity Verification (KYC)

Knowing the users properly is most important, both for AML reasons and for general security. Users are expected to provide:

• A copy of ID, passport, or driving license, shown with a handwritten note containing six random numbers.
• Another picture showing the user’s face.
• Users can also blur their ID to protect their privacy. However, key info can not be blurred, such as name, DOB, nationality, gender, photo, etc.

Some other information can also be asked by the staff if required, depending on the situation. 

Address Verification Documents

Address proof is first checked electronically using two databases. If that fails, users can manually send:

• The bills of daily service things or statements of the bank that have lasted for the last 3 months
• A government-issued document showing residence

Make sure all corners of the document are visible and readable for faster approval.

Source of Amount

For deposits over $5,000, we need to understand the source of the wealth (SOW). Examples:

• Business ownership
• Employment
• Inheritance
• Investments
• Family sources

If the source is unclear, staff may request extra documents. The profile of such users may be temporarily frozen until all the steps of verification are completed. 

Risk Management & Monitoring

At spin24star.com, we understand that users come from everywhere, and obviously, some regions might need more attention than others. To deal with this, we categorize countries into three risk levels, which basically helps us decide how strict we need to be with verification and monitoring.

• Low-risk regions: Standard three-step verification applies, just like we described in the earlier section.
• Medium-risk regions: Verification kicks in at lower deposit, withdrawal, or transfer amounts. Step one stays the same, but step two may happen at around $1,000 deposit/withdrawal or $500 transfer. Step three can be triggered at $2,500 deposit/withdrawal or $1,000 transfer. Crypto users from low-risk areas exchanging into other currencies are treated like medium-risk users.
• High-risk regions: Access is restricted. These lists are updated regularly because, well, things change fast in the world.

Extra Safety Measures

We also have extra measures that are more about watching patterns and behaviour. For example, the system looks out for deposits or withdrawals without longer play sessions, using multiple accounts for depositing and withdrawing, sudden currency changes, or changes in user activity patterns. 

This is backed by human staff who double-check anything unusual and ensure that the account is being used by the original owner. Plus, users must maintain the same deposit and withdrawal methods for the same amounts to prevent any suspicious use.

Enterprise-Wide Risk Review

Every year, spin24star.com does a kind of global check called an Enterprise-Wide Risk Assessment (EWRA). This is basically our way of figuring out:

• Who our users are and how they interact with the platform
• What types of transactions happen most often
• Geographic patterns of activity
• Any emerging risks or unusual trends

The results let us put extra safeguards in place, fine-tune verification thresholds, and generally make sure that everything stays safe and above board.

Ongoing Transaction Checks

At spin24star.com, AML checks continuously monitor user activity to spot anything unusual compared to their normal behaviour, using 3 layers of review to ensure nothing suspicious is missed.

1. First-Level Supervision

At spin24star.com, the first layer of control relies on trusted Payment Service Providers who already have strong AML measures. This ensures that most unusual deposits are flagged before reaching the platform and that KYC procedures are properly followed for new users.

2. Second-Level Supervision

The second layer involves the platform’s own network. Any contact with users or their representatives triggers a careful review of account activity. This includes requests for deposits, withdrawals, or changes in transfer methods. 

The three-step verification process on the platform, which is combined with risk-based adjustments, helps to maintain the real community. All the transfers are monitored here thoroughly, where everything is observed by the AML compliance officer and reported to general management. 

Automated systems perform initial checks, and employees cross-check them for extra security. Any transaction that is hard to justify or doesn’t match the user’s usual behaviour is considered atypical, and staff must report such activity to the AML division if the source of funds or activity cannot be confirmed.

3. Third-Level Supervision:

As the last line of defence, spin24star.com conducts manual reviews of high-risk or suspicious users. All these checks ensure that no irregular activity can take place on the platform, and they are fully investigated. If any fraud is found related to AML, then the relevant authorities are immediately notified by the platform.

Reporting Suspicious Activity

Staff must report anything that looks unusual or atypical. The AML team will:

• Decide if authorities need to be informed 
• The AML team will assess the situation and determine if a report needs to be sent to the FIU, following the legal requirements set out in the Law of 18 September 2017.
• Determine if the account relationship should be terminated

All reports follow internal procedures to make sure the right steps are taken.

Operational Procedures

The AML and KYC rules are translated into clear internal guidelines accessible on Spin24Star’s intranet.

Record Keeping

• Identification and verification data are stored for 10 years after the account is closed.
• Transaction records are kept for 10 years after completion.
• All data is encrypted and stored securely offline and online.

Staff Training & Audits

Employees handling finance or verification get special training. Here is what they are trained in:

• Mandatory AML training aligned with the latest rules
• Special sessions for new employees
• Guidance from AML specialists within the team

Audits

Internal audits happen regularly to check that AML activities and processes are working properly.

Data Security

All user information is kept safe and never sold or shared with third parties. Exceptions are only:

• If legally required
• To report suspicious activity to AML authorities

We follow all the EU data protection guidelines (Directive 95/46/EC), which are required to keep our platform safe and secure. 

Contact & Questions

If users have any questions or complaints about AML/KYC processes:

• Email: compliance@spin24star.com

We are here to help if you need clarification on verification, deposits, withdrawals, or any checks regarding this policy and other concerns.