Anti-Money Laundering (AML) Policy at Spinago Casino

Spinago Casino is committed to preventing money laundering, terrorist financing, and other forms of financial crime. This Anti-Money Laundering (AML) Policy outlines the measures implemented to ensure compliance with applicable laws and regulatory standards in Australia, including obligations aligned with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and reporting standards overseen by the Australian Transaction Reports and Analysis Centre (AUSTRAC).

The purpose of this policy is to safeguard the integrity of the platform, protect players, and maintain a transparent and legally compliant operating framework. AML and Know Your Customer (KYC) controls are integrated into account registration, payment processing, and ongoing transaction monitoring procedures.

Objectives of the AML Policy

The primary objective of this AML Policy is to prevent the use of Spinago Casino’s services for unlawful financial activity. This includes identifying and mitigating risks associated with money laundering, terrorist financing, fraud, and other prohibited transactions.

• Verifying the identity of all players before withdrawal activity is permitted
• Monitoring financial transactions for unusual or suspicious patterns
• Reporting suspicious matters to relevant authorities in accordance with Australian regulatory requirements
• Maintaining accurate records of customer identification and financial activity
• Restricting access from prohibited or high-risk jurisdictions

Spinago Casino applies a risk-based approach, meaning enhanced due diligence measures may be implemented where higher-risk activity is identified.

Customer Identification (KYC)

Spinago Casino applies comprehensive Know Your Customer (KYC) procedures to verify the identity of each player. Identity verification is mandatory prior to processing withdrawals and may also be triggered during registration or when specific transaction thresholds are reached.

The standard verification process requires submission of:

• Government-issued photo identification (such as a passport or driver’s licence)
• Proof of residential address dated within the last three months
• Verification of payment method ownership, where applicable

All documents must be clear, valid, and consistent with the personal details provided during account registration. Information submitted is reviewed by the compliance team and validated against internal and external verification systems.

Additional due diligence may be required in certain cases, including:

• High-value transaction activity
• Multiple payment method usage
• Inconsistencies in provided personal information
• Activity originating from higher-risk jurisdictions

Where enhanced due diligence is required, Spinago Casino may request additional documentation or supporting information before permitting continued account activity.

Accounts remain restricted from withdrawal processing until identity verification has been completed and approved.

Transaction Monitoring

Spinago Casino continuously monitors player transactions to detect unusual or potentially suspicious financial behaviour. Automated monitoring systems review deposit and withdrawal activity against predefined risk indicators.

• Detection of large or irregular transaction patterns
• Identification of rapid deposit and withdrawal cycles without meaningful gameplay
• Monitoring of multiple accounts associated with a single device or IP address
• Review of transactions inconsistent with a player’s established behaviour profile

Transactions are assessed in real time and flagged for manual review where necessary. If irregularities are identified, the account may be temporarily suspended pending further investigation.

Spinago Casino reserves the right to request additional documentation to clarify the source of funds used for deposits. Where required, proof of source of funds documentation may include bank statements or confirmation of income origin.

The platform does not accept anonymous transactions and does not process third-party payments.

Reporting and Record-Keeping

In accordance with applicable Australian regulations, Spinago Casino maintains detailed records of customer identification data and transaction history. Records are retained for the minimum period required by law and stored securely within encrypted systems.

Where suspicious activity is detected, Spinago Casino is obligated to submit a Suspicious Matter Report (SMR) to AUSTRAC in accordance with statutory requirements. Such reporting is conducted confidentially and without prior notice to the player involved, as required under AML legislation.

• Retention of identification documentation
• Storage of transaction histories
• Maintenance of internal compliance review logs
• Documentation of investigations and reporting decisions

All AML-related records are protected against unauthorised access and are accessible only to authorised compliance personnel.

Compliance and Cooperation

Spinago Casino operates in alignment with Australian AML and counter-terrorism financing regulations. Internal compliance controls are regularly reviewed to ensure ongoing adherence to legal requirements and evolving regulatory standards.

The compliance team is responsible for:

• Conducting risk assessments
• Implementing internal AML controls
• Training relevant staff on AML and KYC procedures
• Coordinating reporting obligations to regulatory authorities

Spinago Casino cooperates fully with AUSTRAC and other relevant law enforcement or regulatory agencies. Upon lawful request, information related to customer accounts or transactions may be disclosed in accordance with legal obligations.

The platform may restrict or terminate accounts where AML violations or unlawful activity are suspected.

Restricted Jurisdictions

Spinago Casino does not permit account registration or transaction activity from jurisdictions identified as high-risk or subject to international sanctions. Access restrictions are applied through IP monitoring, geolocation controls, and payment verification mechanisms.

If a player is found to be accessing the platform from a restricted jurisdiction, the account may be suspended and subject to compliance review.

The list of restricted jurisdictions is reviewed periodically in accordance with international regulatory guidance and sanctions frameworks.

Player Responsibilities

Players are required to provide accurate, complete, and truthful information during account registration and verification procedures. Submission of false documentation or misrepresentation of identity constitutes a violation of platform policies.

Players must use payment methods registered in their own name and may not conduct transactions on behalf of third parties. Any attempt to bypass AML controls, including the use of multiple accounts or false identity information, may result in account suspension and reporting to relevant authorities.

By maintaining an account with Spinago Casino, players acknowledge their obligation to comply with applicable AML and KYC requirements.

Spinago Casino maintains a zero-tolerance approach toward financial crime. Through identity verification, transaction monitoring, regulatory reporting, and cooperation with Australian authorities, the platform seeks to maintain a secure, transparent, and legally compliant operational framework.