Anti‑Money Laundering (AML) Policy

Last updated: 2026

This Anti‑Money Laundering and Counter‑Terrorist Financing (“AML/CTF”) Policy describes how Spinzen Casino (the “Casino”, “we”, “us”, “our”) prevents, detects, and reports suspected money laundering, terrorist financing, fraud, and other financial crime risks in connection with the use of spinzen.ca (the “Website”) and our gaming services.

This is a service (compliance) page intended to inform players and stakeholders about our internal controls and the verification measures we may apply. This Policy should be read together with our Terms and Conditions, Privacy Policy, and any other applicable rules posted on the Website.

1. Who we are

Brand: Spinzen Casino
Domain: spinzen.ca
Company: Fionex Holding LTD
Licence: Comoros (AOFA)
Established: 2025

We aim to operate a safe, fair, and compliant platform. We apply a risk‑based approach to AML/CTF and continuously improve our controls as risks evolve.

2. Purpose and scope

The purpose of this Policy is to:

help prevent the Casino from being used to launder proceeds of crime or finance terrorism;
set out our approach to customer identification and verification (KYC);
describe how we monitor transactions and player behaviour for suspicious activity;
explain when we may request Source of Funds (SoF) / Source of Wealth (SoW) information;
outline potential actions we may take, including account restrictions, refusal of transactions, and reporting to competent authorities.

This Policy applies to all customers, transactions, payments (including fiat and crypto where available), and interactions with our services.

3. Key definitions

Money laundering: the process of converting or transferring proceeds of crime to conceal their origin.
Terrorist financing: providing or collecting funds with the intention that they be used to carry out terrorist acts.
KYC (Know Your Customer): identity checks performed to verify that a customer is who they claim to be.
SoF/SoW: information and evidence showing the origin of funds used for gambling (SoF) and how a customer accumulated their wealth overall (SoW).

4. Our risk‑based approach

We apply a risk‑based approach, meaning the level of checks and monitoring depends on the level of risk we identify. Factors we may consider include:

customer profile, behaviour, and activity patterns;
transaction size, frequency, and unusual changes in play;
payment method risk (e.g., prepaid instruments, high‑risk processors, or certain crypto patterns);
geographic indicators and jurisdictional risk;
negative media, sanctions exposure, and other third‑party risk signals.

5. Customer due diligence (KYC)

We may perform KYC checks at registration and/or at any time during the customer relationship. Verification may be required before withdrawals and can be triggered by risk indicators. We may ask you to provide accurate and up‑to‑date personal information and supporting documents.

Typical KYC information/documents may include:

full name, date of birth, and residential address;
government‑issued photo ID (e.g., passport, driver’s licence, national ID);
proof of address (e.g., utility bill, bank statement) showing your name and address and dated within a reasonable period;
payment method verification (e.g., card ownership proof, e‑wallet screenshots, bank account details);
selfie/liveness check where appropriate to confirm identity.

We may use manual and/or electronic verification methods and may request additional information if documents are unclear, expired, inconsistent, or if enhanced checks are required.

6. Age and identity requirements

Our services are intended for adults only. If we suspect that a player is underage or has provided false identity information, we may restrict the account while we verify the information and take any actions required by our Terms and applicable rules.

7. Enhanced due diligence (EDD)

We apply Enhanced Due Diligence (“EDD”) in higher‑risk scenarios. EDD may include requesting additional documents and information, increased monitoring, and/or senior review.

EDD may be triggered by, for example:

large or frequent deposits/withdrawals that do not align with the customer’s profile;
unusual wagering patterns (e.g., low‑risk/low‑margin play designed to move funds rather than gamble);
attempts to bypass verification or provide inconsistent documents;
third‑party payment indicators or use of multiple accounts;
sanctions/PEP screening hits or adverse media.

8. Source of Funds (SoF) and Source of Wealth (SoW)

Where required by our risk assessment, we may ask you to explain and document the origin of funds used on the Website (SoF) and/or how you acquired your overall wealth (SoW). This helps us ensure that funds are not derived from criminal activity.

Examples of SoF/SoW evidence may include:

payslips, employment contract, or employer letter;
bank statements showing income and relevant transactions;
tax returns or notices of assessment;
documents relating to sale of property or other assets;
company ownership documents and financial statements (for business income);
inheritance documentation or gift letter (where applicable).

If you fail to provide satisfactory SoF/SoW information when requested, we may restrict the account, refuse transactions, and/or decline withdrawals until verification is completed.

9. Payments, third‑party funding, and ownership of payment methods

All deposits and withdrawals must be made using payment methods that belong to the registered account holder. We generally do not accept third‑party funding (including deposits from friends/family or business accounts) unless we have explicitly approved it following additional checks.

To reduce fraud and AML risk, we may request proof of ownership of cards, e‑wallets, bank accounts, or crypto wallets used on the account, and we may apply limits or restrictions in line with our internal controls and applicable rules.

10. Crypto‑asset specific controls

Where crypto payments are available, we may apply additional controls such as:

blockchain transaction monitoring and risk scoring;
review of wallet provenance and links to sanctioned or high‑risk entities;
limitations on certain transactions or requests for additional verification where risk indicators are present.

If a crypto transaction is flagged as high‑risk, we may delay processing while we conduct further checks.

11. Transaction monitoring and suspicious activity detection

We monitor gameplay and financial transactions to identify patterns that may indicate money laundering, fraud, or abuse. Monitoring may include (without limitation):

rapid in/out movement of funds with minimal wagering;
multiple accounts linked by device, IP, payment instruments, or identity attributes;
unusual betting patterns inconsistent with entertainment play;
chargeback patterns or other fraud indicators;
attempts to circumvent limits, controls, or verification processes.

12. Sanctions, PEP, and adverse media screening

We may screen customers against relevant sanctions lists and other databases, and we may perform Politically Exposed Person (“PEP”) checks and adverse media screening as part of our AML controls. If a match is identified, we may apply EDD, restrict the account, and take any other actions required.

13. Record keeping

We maintain records related to customer identification, verification, transactions, communications, and AML reviews for a period required by our applicable obligations and legitimate business needs. Records may be retained after an account is closed where necessary for compliance, dispute resolution, or legal purposes.

14. Refusal of service, account restrictions, and funds handling

To protect the integrity of our platform and comply with legal and regulatory obligations, we may, at our discretion and in line with our Terms:

request additional verification at any time;
delay or refuse deposits/withdrawals pending checks;
limit account activity (e.g., deposits, withdrawals, gameplay) while an investigation is ongoing;
suspend or close an account where we identify unacceptable risk or breach of rules;
report suspicious activity to competent authorities where required.

Where verification is pending, withdrawals may be processed only after successful completion of checks and confirmation that the funds and activity are compliant.

15. Reporting of suspicious activity

Where we identify reasonable grounds to suspect money laundering, terrorist financing, or other financial crime, we may submit a report to relevant authorities in accordance with applicable requirements. We may be legally restricted from informing you that such a report has been made or is being considered.

16. Data protection

We process personal data for AML/CTF purposes, including identity verification, monitoring, and reporting. We aim to handle personal information securely and in accordance with our Privacy Policy and applicable data protection principles. You are responsible for providing accurate information and keeping it up to date.

17. Player responsibilities

By using the Website, you agree that:

you will provide truthful, accurate, and complete information;
you will not use another person’s identity or payment method;
you will cooperate with reasonable requests for KYC/SoF/SoW documentation;
you will not attempt to abuse promotions, limits, or controls for the purpose of moving funds.

18. Updates to this Policy

We may update this AML/CTF Policy from time to time to reflect operational changes, risk developments, or legal/regulatory updates. The “Last updated” date at the top of this page indicates when the latest version took effect. Continued use of the Website after changes are posted constitutes acceptance of the updated Policy.

19. Contact

If you have questions about this AML/CTF Policy or verification requests, please contact our customer support via the channels available on spinzen.ca.

Important: For security reasons, please do not send full card details or sensitive authentication data via email or chat. When documents are required, upload them only through the secure methods provided on the Website.