1. Purpose of AML & KYC Policies

Our AML and KYC policies serve several key purposes:

• Preventing money laundering and other financial crimes: We aim to ensure that our platform is not used for illegal activities such as money laundering, terrorist financing, or tax evasion.
• Protecting our customers: By verifying our players’ identities, we create a safe environment where customers can enjoy gaming without fear of fraud or identity theft.
• Complying with New Zealand regulations: As a licensed operator in New Zealand, SpinBet adheres to the country’s strict AML/CFT (Counter Financing of Terrorism) laws, ensuring full regulatory compliance.

2. KYC (Know Your Customer) Procedures

To comply with New Zealand’s AML/CFT regulations, we must verify the identity of all our players. Our KYC process helps us confirm that every individual who registers on SpinBet is who they claim to be and meets the legal requirements to gamble in New Zealand.

2.1 Information We Collect

As part of our KYC process, we collect specific personal information from every player, including but not limited to:

• Full Name
• Date of Birth (to confirm you are at least 18 years old)
• Residential Address
• Contact Details (email address and phone number)
• Payment Information (such as bank account or card details)
• Proof of Identity and Address (such as a government-issued ID and a utility bill)

2.2 Verification Process

Upon registering, players will be prompted to submit the necessary documentation for verification. The documents required typically include:

• Government-issued photo ID: This could be a passport, driver’s license, or national ID card.
• Proof of address: A recent utility bill, bank statement, or any other official document that clearly shows your name and address (dated within the last 3 months).

We may also request additional documentation depending on the level of activity on your account or if we need to verify certain transactions.

2.3 Enhanced Due Diligence

For certain customers, particularly those involved in higher-value transactions or those flagged as potentially high-risk, we implement an additional layer of scrutiny known as Enhanced Due Diligence (EDD). EDD involves collecting further information, such as:

• The source of funds used for gaming transactions
• Further identification documents
• Additional financial details

These measures ensure we meet our obligations to prevent money laundering and comply with legal requirements.

3. Anti-Money Laundering (AML) Policy

SpinBet takes a proactive approach to prevent money laundering activities on our platform. We have developed robust systems and procedures to detect, monitor, and report any suspicious activities related to money laundering.

3.1 Monitoring Transactions

We closely monitor player transactions to identify any suspicious patterns or behaviors. This includes:

• Unusual deposit or withdrawal patterns: For example, a player making unusually large deposits or frequent withdrawals within a short period.
• Inconsistent account activity: If a player’s activity on the platform significantly deviates from the norm, it may trigger a review.
• Multiple accounts: We monitor the creation of multiple accounts under the same name or using the same payment method, which could be a red flag for fraudulent behavior.

Any activity that appears suspicious is investigated, and if necessary, reported to the appropriate authorities as required by New Zealand’s AML/CFT regulations.

3.2 Reporting Suspicious Activity

SpinBet is legally required to report any suspicious activities that may be linked to money laundering or terrorist financing to New Zealand’s Financial Intelligence Unit (FIU). These reports, known as Suspicious Transaction Reports (STRs), include details of the suspicious activity and the steps taken by SpinBet to address it.

3.3 Limits on Transactions

To minimize the risk of money laundering, we may impose certain limits on transactions, including:

• Deposit Limits: These ensure that deposits are within reasonable amounts based on the player’s usual activity.
• Withdrawal Limits: These help us monitor unusual withdrawal requests, particularly if the amount requested is significantly larger than the amount deposited.

Players may be required to provide additional documentation or verification if their transactions exceed certain thresholds or if their activity triggers an internal review.

4. Player Responsibilities

While SpinBet is committed to protecting our platform and users from money laundering and fraud, players also have certain responsibilities:

4.1 Accurate Information

Players must provide accurate, complete, and up-to-date information during the registration process and whenever requested as part of the KYC or AML procedures. Providing false or misleading information is a violation of our terms and may result in account suspension or closure.

4.2 Prompt Response to Verification Requests

To ensure compliance with AML and KYC regulations, we may request additional documentation from players at any time. It is the player’s responsibility to respond to these requests promptly.  Failure to provide the necessary information within a reasonable timeframe may result in account restrictions or closure.

4.3 Reporting Suspicious Activity

Players are encouraged to report any suspicious activity they encounter while using our platform. If you suspect another player is engaging in illegal activities, please notify our customer support team immediately.

5. Data Protection and Security

SpinBet takes the security and confidentiality of your personal information seriously. All data collected as part of the KYC and AML processes is securely stored and handled in accordance with our Privacy Policy. We use encryption and other advanced security measures to ensure that your data is protected from unauthorized access.

Only authorized personnel have access to player information, and all transactions are monitored to detect and prevent fraudulent activities.

6. Legal Compliance and Consequences

SpinBet complies with all applicable laws and regulations in New Zealand, including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. Failure to adhere to these legal obligations can result in severe consequences for both SpinBet and individual players.

6.1 Consequences for Non-Compliance

If a player is found to be violating AML or KYC regulations, SpinBet reserves the right to take immediate action, which may include:

• Account suspension or closure
• Freezing funds held in the player’s account
• Reporting the player to relevant legal authorities

These measures are taken to protect our platform and ensure compliance with New Zealand laws.

7. Changes to Our AML & KYC Policy

SpinBet reserves the right to update or modify this policy at any time in response to changes in the law or our business practices. Any updates will be communicated through our website, and it is the player’s responsibility to review the policy regularly.