Aml Policy

Introduction

Casilando's Anti-Money Laundering (AML) Policy outlines our commitment to preventing money laundering and the financing of terrorism in all gaming activities. It describes our risk-based framework, customer due diligence measures, ongoing monitoring, data handling, and cooperation with competent authorities to maintain a safe and compliant environment for players.

Scope and Objectives

This policy applies to all Casilando customers and applicants, including individual and corporate users, and to all channels through which Casilando services are accessed. It sets the standards for identity verification, ongoing monitoring, recordkeeping, reporting, and cooperation with supervisory authorities.

Regulatory Foundation

Casilando is licensed and regulated by a recognized regulatory authority and operates in accordance with applicable anti-money laundering, counter-terrorism financing, and sanctions laws. The policy aligns with regulatory expectations on customer due diligence, transaction monitoring, risk assessment, and retention of records.

Customer Due Diligence and KYC Triggers

  1. We apply a risk-based approach to customer due diligence. When a customer reaches specific activity thresholds or makes certain requests, a full KYC review is initiated.
  2. Trigger events include aggregate lifetime deposits of EUR 2000 or more (in the applicable currency equivalent) or the initiation of any withdrawal request. Either event prompts full verification requirements.
  3. Where the trigger is activated, the customer may be processed under a heightened verification protocol until the process is completed.

Identity Verification and Documentation

  • Required documents include:
    • Government-issued photo identification (front and back where applicable);
    • A live photograph or selfie of the customer holding the ID;
    • Proof of residential address, such as a bank statement or utility bill dated within the last three months.
  • All documents submitted remain the property of Casilando and are processed in accordance with data protection regulations.

KYC Status, Review Timelines and Restrictions

  • Upon submission, the customer account is assigned the status Temporarily Approved. The Compliance Team has up to 24 hours to review the submission and communicate the outcome.
  • Outcomes include: Approved, Rejected, or More information required.
  • During Temporarily Approved status, the customer may continue to use the platform but deposits are capped at EUR 500 in aggregate, and withdrawals are not permitted until final approval is granted.

Payment Methods Verification and Card Checks

  • If deposits are made via payment cards, Casilando may request a photo of the card (both sides) with the Card Verification Code (CVC) obscured to confirm card ownership. The CVC will not be retained beyond verification, and card data are handled under strict confidentiality.

Enhanced Verification and Interviews

  • Additional information or documents may be requested at any stage. A video or telephone interview may be conducted to complete identity and risk verification as part of the KYC process.

Prohibited Jurisdictions and Access Controls

  • Casilando prohibits access from jurisdictions subject to international sanctions or FATF blacklist concerns or otherwise restricted by applicable authorities. Geolocation and identity checks are used to enforce these restrictions and may result in account limitations or denial of service where applicable.

Ongoing Monitoring, Sanctions and PEP Screening

  • All customer activity and transactions are monitored on an ongoing basis using automated systems. The risk profile is updated in light of new information, and enhanced due diligence is applied to higher-risk customers or transactions.
  • Sanctions, watchlists, and politically exposed person (PEP) screening are performed at onboarding and on a rolling basis.

Data Retention, Privacy, and Information Security

  • Personal data collected in the course of AML due diligence is processed in compliance with applicable data protection laws and kept for a minimum period required by law or regulatory obligation. In general, records are retained for at least five years after the end of the customer relationship or last transaction, whichever is later.
  • Access to personal data is restricted to authorized personnel and protected through appropriate technical and organizational measures, including encryption and secure storage with third-party processors bound by data protection obligations.

Recordkeeping and Audit Trails

Casilando maintains comprehensive records of customer identity, verification results, risk assessments, transaction histories, and communications related to AML due diligence. Records are kept for the statutory retention period and are available to auditors and regulators as required by law.

Roles, Responsibilities and Internal Controls

Governance structures assign responsibility for AML compliance to the Compliance Team and senior management, with support from Information Security, Finance, and Customer Support. Controls include periodic risk assessments, policy reviews, access controls, and independent monitoring.

Suspicious Activity Reporting and Authority Cooperation

Casilando reports all suspicious or unusual activity to the competent regulatory authority in accordance with applicable law. The entity cooperates with investigations and preserves the confidentiality of reporting where permitted by law.

Training, Awareness and Red Flags

All staff undergo AML/CTF training on onboarding and at least annually, with ongoing updates on evolving money-laundering typologies and regulatory expectations. Employees must promptly escalate any red flags or uncertainties to the Compliance Team.

Self-Exclusion, Player Welfare and AML Alignment

In alignment with responsible gaming principles, Casilando offers self-exclusion options. When a customer self-excludes, access to the platform is restricted for the selected period and AML screening remains active to prevent circumvention. Reinstatement follows applicable internal procedures and cooling-off requirements.

Policy Updates, Communication and Effectivity

Casilando may amend this policy to reflect changes in laws, regulatory guidance, or risk factors. Material changes will be communicated through the standard customer notices, and changes take effect no sooner than the notice period specified in the communication. Continued use of Casilando services after the effective date constitutes acceptance of the updated policy.

Contact and Help

Customers may contact the Compliance Team through the standard Help/Support channels available on the Casilando platform for any questions or to initiate verification or reporting concerns related to AML compliance.