This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Stegi Limitada Sociedad De Responsabilidad Limitada ("the Operator"), the company behind spinalto, operating through the website spin-alto-casinos.nl, to detect, prevent and report financial crime, and to verify the identity of every customer before processing deposits, withdrawals or bonus activations. All players are required to read and comply with this Policy as a condition of using spinalto.

1. Legal Framework and Regulatory Basis

spinalto is owned and operated by Stegi Limitada Sociedad De Responsabilidad Limitada, a company incorporated in Costa Rica and holding a Costa Rica gaming licence. Although Costa Rica does not impose a domestic AML regime equivalent to that of the EU's Anti-Money Laundering Directives, the Operator voluntarily adopts standards consistent with the Financial Action Task Force (FATF) Recommendations and international best practice in order to protect players, safeguard the integrity of the platform, and fulfil its obligations as a responsible gaming operator.

This Policy applies to all natural persons who register an account on spin-alto-casinos.nl, regardless of their country of residence, the currency they deposit, or the payment method they use. By registering an account, every player accepts the obligations described in this Policy in full.

2. Purpose and Scope

The purposes of this Policy are to:

• Prevent spinalto from being used, knowingly or unknowingly, as a vehicle for money laundering, terrorist financing, or any other financial crime.
• Establish clear procedures for verifying the identity, age, address and source of funds of every customer.
• Define the circumstances in which the Operator will request enhanced due diligence documentation.
• Set out the Operator's approach to transaction monitoring and suspicious activity reporting.
• Ensure that all staff involved in customer onboarding, payments processing and account management understand their responsibilities under this Policy.

This Policy covers all products offered through spin-alto-casinos.nl, including the casino lobby (1,000+ titles from 51 studios), the live casino floor, the BetBy-powered sportsbook, and all associated promotional activities.

3. Definitions

• AML — Anti-Money Laundering: the set of procedures, laws and regulations designed to stop the practice of generating income through illegal actions.
• KYC — Know Your Customer: the process by which the Operator verifies the identity and legitimacy of a player before and during their relationship with spinalto.
• CDD — Customer Due Diligence: standard identity and address verification applied to all players.
• EDD — Enhanced Due Diligence: additional verification required for higher-risk players, including Politically Exposed Persons or those transacting at high volumes.
• PEP — Politically Exposed Person: an individual who holds or has held a prominent public function, or who is a close family member or known associate of such a person.
• SAR — Suspicious Activity Report: an internal report raised when a transaction or pattern of behaviour gives rise to suspicion of financial crime.
• FATF — Financial Action Task Force: the inter-governmental body that sets international standards for combating money laundering and terrorist financing.
• Source of Funds (SoF) — the origin of the money used by a player to fund their account.
• Source of Wealth (SoW) — the origin of the total wealth or net worth of a player.

4. Money Laundering — Overview

Money laundering is the process by which criminals attempt to conceal the true origin of illegally obtained funds by passing them through a series of transactions so that the money appears to have come from a legitimate source. The process typically proceeds through three stages:

• Placement — introducing illegal funds into the financial system, for example by depositing cash or funding an online gaming account.
• Layering — disguising the trail of the funds through complex layers of transactions, such as multiple deposits, withdrawals and currency conversions.
• Integration — reintroducing the laundered funds into the legitimate economy, at which point they appear clean.

Online casinos can be misused at any of these three stages. The Operator's controls are designed to detect and disrupt attempts at each stage.

5. The Operator's AML Commitment

The Operator maintains a zero-tolerance approach to money laundering and terrorist financing. Specifically, spinalto commits to:

• Verifying the identity of every player before allowing withdrawals and, in certain circumstances, before accepting deposits above defined thresholds.
• Monitoring all transactions on an ongoing basis for patterns or amounts that are inconsistent with a player's stated profile or normal gambling behaviour.
• Refusing to process withdrawals to any payment method, bank account or wallet that is different from the one used to make the original deposit.
• Maintaining records of all KYC documentation and transaction data for a minimum of five (5) years from the end of the customer relationship.
• Training all relevant staff to recognise the signs of money laundering and to follow the internal escalation procedure.
• Appointing a nominated Money Laundering Reporting Officer (MLRO) who is responsible for receiving internal SARs and deciding whether to file external reports with the competent authorities.

6. Know Your Customer (KYC) — Verification Process

6.1 When Verification Is Required

KYC verification is mandatory for all players on spin-alto-casinos.nl. The Operator reserves the right to request verification documents at any point during the customer relationship, including:

• Before processing any withdrawal request, regardless of amount.
• Before activating welcome bonus deposits or other promotional rewards where the Operator deems it appropriate.
• When cumulative deposits exceed internal thresholds defined by the Operator's risk-based approach.
• When a player's account activity raises flags through the Operator's automated transaction monitoring system.
• When a player is identified, or suspected, to be a PEP.
• At any time the Operator considers it necessary or appropriate to fulfil its AML obligations.

Withdrawals are processed within two banking days of approval. Approval is contingent on the player's KYC being fully cleared. Incomplete or outstanding verification will result in withdrawal requests being held until all required documentation has been received, reviewed and accepted.

6.2 Standard CDD — Required Documents

All players must provide the following documentation to complete standard Customer Due Diligence:

Proof of Identity (one of the following)

• Valid government-issued passport (photo page)
• National identity card (front and back)
• Valid driving licence (front and back, where it includes date of birth and photograph)

Proof of Address (one of the following, dated within the last three months)

• Bank statement issued by a recognised financial institution
• Utility bill (gas, electricity, water, landline telephone)
• Official government correspondence addressed to the player at their registered address
• Council tax or equivalent municipal tax bill

Proof of Payment Method

• Visa / Mastercard — a photograph or scan of the card used, showing the cardholder's name, the card's last four digits, and the expiry date (the middle eight digits must be obscured).
• Apple Pay / Google Pay — a screenshot from the device's wallet application showing the linked card or account details.
• Revolut — a screenshot of the Revolut account screen confirming the account holder's name and account reference.
• Bitcoin (BTC), USDT, Ethereum (ETH) — confirmation of the wallet address used to fund the account; the Operator may require additional blockchain transaction references where the origin of funds is unclear.

Documents must be submitted in colour, must be legible in full, and must not be expired. The Operator reserves the right to reject documents that appear to have been altered, edited or digitally manipulated.

6.3 Document Submission

Players are invited to upload verification documents directly via the secure account portal on spin-alto-casinos.nl. Alternatively, documents may be sent to the dedicated KYC email address published in the Help section of the site. Submissions are processed by the Operator's compliance team in the order received. Players will be notified by email once their documents have been reviewed and either accepted or queried. Where further information is required, the compliance team will contact the player directly.

6.4 Age Verification

spinalto strictly prohibits the use of its platform by persons under the age of 18. Age verification is embedded within the standard identity verification process — the date of birth confirmed on the submitted photo ID must match the date of birth provided at registration. Where the Operator has reason to suspect that a player may be underage, the account will be immediately suspended pending verification, regardless of any outstanding balance. Any funds deposited by a player subsequently confirmed to be underage will be returned to the payment method used, net of any bonus funds.

7. Enhanced Due Diligence (EDD)

7.1 When EDD Applies

Enhanced Due Diligence is triggered when the Operator's risk assessment indicates that a player presents a higher-than-average risk profile. EDD will be applied in, but is not limited to, the following circumstances:

• The player is identified as a Politically Exposed Person or is a close associate or family member of a PEP.
• The player's cumulative deposit or withdrawal activity reaches levels that are disproportionate to the profile information provided at registration.
• The player activates the High Roller welcome offer (minimum deposit €500, bonus up to €3,000 plus 125 Free Spins) or consistently deposits at or near the maximum withdrawal limits (€10,000 per day, €20,000 per week, €50,000 per month).
• The player uses cryptocurrency payment methods (Bitcoin, USDT, Ethereum) and transaction volumes are material, given the additional anonymity risk associated with digital assets.
• The player's account activity includes unusual patterns, such as a high volume of deposits with minimal gameplay followed by withdrawal requests.
• The player's registered country or the origin of their funds is associated with elevated money laundering risk according to current FATF guidance.

7.2 EDD Documentation

When EDD is required, the Operator will request one or more of the following, depending on the specific risk factors identified:

• Source of Funds — recent bank statements (typically covering the preceding three to six months) demonstrating that the funds deposited at spinalto originated from a legitimate source.
• Source of Wealth — documentation evidencing the overall financial standing of the player, such as payslips, employment contracts, tax returns, business accounts, or evidence of inheritance, property sale or investment income.
• PEP Declaration — a signed declaration confirming whether the player holds or has held a prominent public function, together with supporting documentation as requested.
• Cryptocurrency wallet history — where deposits have been made using BTC, USDT or ETH, the Operator may request wallet transaction histories or third-party blockchain analysis reports to confirm the source of the digital assets.
• Additional identity documentation — a second form of government-issued photo ID in cases where the primary document cannot be verified to the Operator's satisfaction.

The account of any player who fails to provide EDD documentation within the timeframe specified by the Operator's compliance team may be restricted or permanently closed. Any pending withdrawals will be withheld until EDD is completed satisfactorily.

8. Ongoing Monitoring

KYC is not a one-time event. The Operator conducts ongoing monitoring of all active accounts throughout the customer relationship. This includes:

• Automated transaction monitoring that flags deposits, withdrawals or patterns of play that fall outside the parameters consistent with a player's profile.
• Periodic review of high-value or high-frequency accounts, including those that regularly approach the published withdrawal limits of €10,000 per day, €20,000 per week and €50,000 per month.
• Monitoring of payment method changes — the Operator does not permit withdrawals to a payment method that was not used to make a deposit, and any attempt to withdraw via an unrecognised method will trigger an immediate account review.
• Screening of player names against international sanctions lists, PEP databases and adverse media sources at the time of registration and on an ongoing basis thereafter.
• Review of cryptocurrency transactions using blockchain analytics tools to assess the risk profile of digital asset movements into and out of player wallets.

Where ongoing monitoring reveals activity that is inconsistent with the player's stated profile or that is otherwise suspicious, the account will be flagged for review and may be restricted pending investigation.

9. Suspicious Activity — Identification and Reporting

9.1 Indicators of Suspicious Activity

The Operator has trained its compliance and customer support teams to recognise the following non-exhaustive indicators of potentially suspicious behaviour:

• Deposits made in rapid succession using multiple different payment methods, including a mix of fiat methods (Visa, Mastercard, Apple Pay, Google Pay, Revolut) and cryptocurrencies (Bitcoin, USDT, Ethereum), in a manner that appears designed to obscure the origin of funds.
• A pattern of depositing funds and requesting withdrawal of a similar amount without engaging in significant gameplay — commonly referred to as "pass-through" behaviour.
• Requests to withdraw winnings to a different payment method or bank account from those used to deposit.
• Sudden and unexplained increases in deposit volumes that are inconsistent with the player's previously established behaviour.
• A player expressing concern about whether the Operator reports to authorities, or attempting to provide explanations for their activity that are unsolicited and implausible.
• Consistent deposits at or just below the thresholds that trigger enhanced verification — a practice commonly referred to as "structuring."
• Third-party payments — any indication that funds have been deposited by, or are intended to be withdrawn on behalf of, a person other than the registered account holder.

9.2 Internal Reporting Procedure

Any member of the Operator's staff who identifies or suspects suspicious activity must raise an internal Suspicious Activity Report with the MLRO without delay. The MLRO will review the SAR and determine whether external reporting to the relevant competent authority is required. Staff are reminded that disclosure of the fact that a SAR has been raised to the player concerned — commonly referred to as "tipping off" — is strictly prohibited and may itself constitute a criminal offence.

9.3 Account Restrictions Pending Investigation

Where an account is under active investigation for suspected suspicious activity, the Operator reserves the right to:

• Suspend the account and prevent further deposits, gameplay or withdrawals.
• Withhold any pending withdrawal until the investigation is concluded.
• Permanently close the account if the investigation concludes that suspicious activity has taken place.
• Report the matter to, and cooperate fully with, the relevant law enforcement or regulatory authorities.

In such cases, the Operator is not obliged to explain the reasons for the account restriction to the player, as doing so could compromise an ongoing investigation.

10. Sanctions Screening

The Operator screens all players and beneficial owners against applicable international sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury, and His Majesty's Treasury in the United Kingdom. Players who appear on any sanctions list will be denied access to spinalto, and any funds held in their account will be dealt with in accordance with applicable law and the guidance of the relevant authority.

Sanctions screening is conducted at registration and is repeated on an ongoing basis to capture newly designated individuals and entities.

11. Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds or has held, within the preceding twelve months, a prominent public function — including but not limited to heads of state, senior politicians, senior government officials, judicial officers, senior military officers, senior executives of state-owned enterprises, and senior officials of international organisations — or who is a close family member or known close associate of such a person.

All players are asked to declare their PEP status at the point of registration. Where a player is identified as a PEP through screening or self-declaration, the following applies:

• The account will automatically be subject to EDD before any deposit is accepted or any withdrawal is processed.
• Senior management approval is required before establishing or continuing a customer relationship with a PEP.
• The PEP's account will be subject to enhanced ongoing monitoring for the duration of the customer relationship.
• Source of Wealth documentation will be required and must be refreshed periodically at the Operator's request.

PEP status does not automatically disqualify an individual from holding an account on spin-alto-casinos.nl, but the Operator may decline to accept or continue a relationship with a PEP where it cannot satisfy itself as to the legitimacy of that person's Source of Wealth.

12. Payment Methods and AML Controls

spinalto accepts deposits and processes withdrawals via a defined range of payment methods. The following AML controls apply to each method:

Third-party payments are strictly prohibited. Deposits must be made from a payment method that is registered in the player's own name. Withdrawals will only be returned to a payment method from which a deposit has previously been received. Any attempt to circumvent this rule will result in the transaction being declined and the account being flagged for review.

The minimum withdrawal amount is €40. The maximum withdrawal limits are €10,000 per day, €20,000 per week and €50,000 per month, as published in the Payment Policy. These limits apply regardless of the payment method used.

13. Bonuses, Promotions and AML Risk

The Operator's promotional structure — including the five-deposit welcome package (up to €6,000 plus 300 Free Spins), the Live Casino welcome bonus (up to €1,000), the High Roller offer, and ongoing rewards such as daily cashback, rakeback, the Weekend Live Bonus and the Midweek Slot Bonus — is subject to the same AML controls as all other account activity.

The following principles apply to bonuses in the context of this Policy:

• No bonus will be activated on any account that has not provided at minimum a valid email address and agreed to the Terms and Conditions. Full KYC verification will be required before any bonus winnings are withdrawn.
• Bonus abuse — including but not limited to the use of multiple accounts, the use of third-party funds, or the manipulation of wagering requirements through artificial gameplay patterns — is treated as a form of fraud and will result in forfeiture of all bonus funds, reversal of associated winnings, and permanent closure of the account.
• The x40 wagering requirement applicable to the slot welcome bonuses, the x15 requirement applicable to the Live Casino welcome bonus, and all other wagering conditions exist in part to ensure that bonus funds are genuinely played through the gaming platform rather than simply withdrawn. This structure supports the Operator's AML obligations by ensuring that bonus funds cannot be used as a straightforward deposit-and-withdraw mechanism.
• Where a player's wagering history across bonus-active rounds is found to be inconsistent with genuine gameplay — for example, placing minimum qualifying bets on low-volatility titles solely to satisfy wagering requirements — the Operator reserves the right to void the bonus and associated winnings and to conduct a full account review.
• The No-Deposit Social Bonus (20 Free Spins or €5 FreeBet) is subject to verification of the player's social media account. Any evidence of duplicate accounts or fraudulent social media activity will result in the bonus being forfeited and the account being reviewed.

14. Responsible Gambling and AML

spinalto's responsible gambling framework and its AML obligations are closely linked. Vulnerability indicators — such as erratic deposit behaviour, rapid escalation of bet sizes, or a player exhibiting signs of chasing losses — may also be relevant from an AML perspective, as they can indicate that funds are not genuinely the player's own or that the account is being operated under duress.

Where the Operator's responsible gambling monitoring identifies behaviour of concern, the compliance team will be notified and an account review will be conducted. Players who wish to discuss responsible gambling tools, including deposit limits, cooling-off periods, or self-exclusion, may contact the spinalto support team via 24/7 live chat or email at any time.

15. Record Keeping

The Operator retains the following records for a minimum of five (5) years from the end of the customer relationship, or for such longer period as may be required by applicable law or the guidance of a competent authority:

• Copies of all KYC documentation submitted by the player, including proof of identity, proof of address and proof of payment method.
• A complete record of all deposits, withdrawals, bonus activations, wagers and game rounds conducted on the account.
• All correspondence between the player and the Operator, including live chat transcripts and email exchanges.
• Internal SARs and any associated investigation notes, regardless of whether the SAR resulted in an external report.
• Results of all sanctions and PEP screening checks.

Records are stored securely and are accessible only to authorised personnel. Data is processed in accordance with the Operator's Privacy Policy, which is published separately on spin-alto-casinos.nl.

16. Staff Training

The Operator ensures that all staff who interact with customers, process payments or handle compliance-related matters receive appropriate AML and KYC training. Training covers:

• The nature and consequences of money laundering and terrorist financing.
• The requirements of this Policy and the staff member's specific responsibilities under it.
• How to identify the indicators of suspicious activity listed in Section 9.1.
• The internal SAR escalation procedure and the prohibition on tipping off.
• The Operator's customer due diligence and enhanced due diligence procedures.

Training is conducted upon induction and refreshed at least annually, or sooner where there is a material change in AML risk, applicable law or this Policy.

17. Policy Review

This Policy is reviewed at least annually by the MLRO and senior management. It will also be reviewed following any material change in the Operator's business model, the range of payment methods offered, the jurisdictions served, or applicable legal or regulatory requirements. The current version of this Policy is published on spin-alto-casinos.nl and supersedes all previous versions. Players will be notified of material changes via the email address registered to their account.

18. Contact and Escalation

Players with questions about the KYC verification process or this Policy may contact the spinalto compliance and support team through the following channels:

• Live Chat — available 24 hours a day, 7 days a week via the chat widget on spin-alto-casinos.nl.
• Email — the dedicated support and compliance email address published in the Help section of the site.

Please note that the Operator is not able to provide legal advice. Players who believe that they have been the victim of financial crime or fraud are encouraged to contact the relevant law enforcement authority in their jurisdiction.

Last reviewed: 2026. This Policy is published by Stegi Limitada Sociedad De Responsabilidad Limitada on behalf of spinalto at spin-alto-casinos.nl.