This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Tekuno Technologies S.R.L., the company that operates RoyalSpinia Casino at royalspiniaapp.nl, to detect, prevent and report money laundering, terrorist financing and related financial crime. The Policy applies to every player account, every transaction and every member of staff who handles financial or compliance functions on behalf of RoyalSpinia. By registering an account and transacting on royalspiniaapp.nl, you confirm that you have read and understood the obligations described below.

1. Legal Basis and Regulatory Framework

RoyalSpinia is operated by Tekuno Technologies S.R.L. under a licence granted by the Tobique Gaming Commission. As a licensed gaming operator, Tekuno Technologies S.R.L. is required to maintain and enforce a robust AML/KYC framework that meets or exceeds the standards required by its licensing authority. This Policy is drafted in accordance with those requirements and reflects internationally recognised AML principles, including the Financial Action Task Force (FATF) Recommendations.

RoyalSpinia reserves the right to update this Policy at any time to remain compliant with changes in regulation, licence conditions or best-practice guidance. The current version is always published on royalspiniaapp.nl. Continued use of the platform following any update constitutes acceptance of the revised terms.

2. Purpose and Scope

Money laundering is the process by which funds derived from criminal activity are introduced into the legitimate financial system so that their illicit origin is concealed. Terrorist financing involves the provision of funds, whatever their source, in support of terrorist activity. Both represent serious criminal offences and a threat to the integrity of the regulated gambling industry.

The purpose of this Policy is to:

• Establish clear customer due-diligence procedures for all players on royalspiniaapp.nl;
• Define the circumstances in which enhanced due diligence is required;
• Set out the procedures for identifying, escalating and reporting suspicious activity;
• Ensure that RoyalSpinia is not used, knowingly or unknowingly, as a vehicle for money laundering or terrorist financing;
• Protect the business, its players and its licence from financial crime risk.

This Policy applies to all registered players, all payment methods accepted on royalspiniaapp.nl — including Visa, Mastercard, Skrill, Neteller, Bank Transfer, Bitcoin (BTC), Ethereum, Litecoin and TRON — and all currencies processed through the platform.

3. The Money Laundering Risk in Online Gaming

Online gambling can present financial crime risks because of the speed and volume of transactions, the cross-border nature of activity and the potential for anonymity. RoyalSpinia recognises the following risk vectors specific to its platform:

• Deposit cycling: depositing funds and withdrawing them with minimal gambling activity to give the appearance of legitimate winnings;
• Cryptocurrency layering: exploiting the pseudonymous nature of crypto assets such as BTC, Ethereum, Litecoin and TRON to obscure the source of funds;
• Multiple account usage: opening or controlling more than one account to circumvent limits or monitoring thresholds;
• Third-party funding: using payment credentials that do not belong to the registered account holder;
• Structuring: breaking large transactions into smaller amounts to avoid detection thresholds.

All of the above patterns are monitored through the platform's automated transaction-monitoring systems, which operate alongside TLS 1.3-encrypted connections and back-end threat monitoring to flag unusual behaviour before it escalates.

4. The Money Laundering Offences

RoyalSpinia staff and, where relevant, players should be aware that the following constitute criminal offences in most jurisdictions:

• Concealing, disguising, converting, transferring or removing criminal property;
• Entering into or becoming concerned in an arrangement which facilitates the acquisition, retention, use or control of criminal property;
• Acquiring, using or possessing criminal property;
• Tipping off a person who is under investigation for a money-laundering offence;
• Failing to disclose knowledge or suspicion of money laundering where a disclosure obligation exists.

5. Know Your Customer (KYC) — Customer Due Diligence

RoyalSpinia operates a risk-based approach to customer due diligence (CDD). All new player registrations are subject to Standard CDD before withdrawal requests are processed and before certain account thresholds are reached. Enhanced Due Diligence (EDD) applies to higher-risk profiles. Simplified Due Diligence may apply to lower-risk circumstances where the regulatory framework permits.

5.1 Standard Customer Due Diligence

Before a withdrawal is released — and in any event when cumulative deposits or account activity reach internal trigger thresholds — every player must successfully complete the following verification steps:

• Identity verification: a valid, unexpired government-issued photo identity document, such as a passport, national identity card or driving licence;
• Address verification: a document confirming the player's residential address, such as a utility bill or bank statement, dated within the last three months;
• Date of birth confirmation: to confirm the player is at least 18 years of age;
• Payment method verification: evidence that the deposit method is owned and controlled by the registered account holder — for example, a photograph of a bank card showing the last four digits, or confirmation of wallet ownership for cryptocurrency deposits.

RoyalSpinia may request these documents at registration, before the first withdrawal or at any point during the account lifecycle. Players who do not complete KYC verification within a reasonable timeframe will have withdrawals suspended until verification is successful. Account access may also be restricted.

5.2 Ongoing Monitoring

Customer due diligence is not a one-time exercise. RoyalSpinia monitors accounts on an ongoing basis for changes in behaviour, transaction patterns and risk profile. This includes:

• Monitoring deposit and withdrawal volumes against declared source of funds;
• Reviewing the frequency and size of transactions across all payment methods, including crypto;
• Checking for patterns consistent with structuring, cycling or collusion;
• Reviewing account activity when a player moves between VIP tiers on the Bronze–Silver–Gold–Platinum loyalty structure, particularly where withdrawal limits are renegotiated above the standard €3,000 weekly or €10,000 monthly caps;
• Reviewing account activity when bonus claims, cashback, rakeback or VIP promotions result in materially unusual financial flows.

5.3 Enhanced Due Diligence

Enhanced Due Diligence is applied where a player presents a higher risk of money laundering or terrorist financing. Circumstances that trigger EDD include, but are not limited to:

• The player is identified as a Politically Exposed Person (PEP) or a close associate or family member of a PEP;
• The player is a national of, or is resident in, a high-risk jurisdiction as designated by FATF or the player's licensing authority;
• Transaction volumes are inconsistent with the player's declared occupation, income or financial profile;
• A player requests a withdrawal limit above the standard weekly or monthly cap, including personalised VIP limits arranged with the support team;
• A player deposits or withdraws significant sums via cryptocurrency methods (BTC, Ethereum, Litecoin, TRON) without a satisfactory explanation of source of funds;
• The account has triggered one or more automated or manual suspicious-activity alerts;
• The player is the subject of adverse media coverage or sanctions-list hits.

Under EDD, RoyalSpinia may request one or more of the following in addition to the standard CDD documents:

• Proof of source of funds — for example, recent payslips, tax returns, business accounts or evidence of an inheritance;
• Proof of source of wealth — documentation demonstrating how the player accumulated their overall net worth;
• A statutory declaration or signed statement of source of funds;
• Blockchain analytics reports for cryptocurrency wallets used to fund the account;
• Enhanced ongoing monitoring at a higher frequency than standard accounts.

Accounts subject to EDD will remain under review until RoyalSpinia is satisfied that the risk has been adequately assessed and mitigated. Until that assessment is complete, withdrawals may be suspended and account activity may be restricted.

5.4 Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds, or has held within the past 12 months, a prominent public function, including heads of state or government, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned enterprises and important political-party officials. RoyalSpinia screens all new registrations and existing account holders against recognised PEP databases.

Where a player is identified as a PEP or a close associate or family member of a PEP, EDD applies automatically. Senior management approval is required before an account relationship with a PEP is established or continued, and the account is subject to ongoing enhanced monitoring for the duration of the relationship.

5.5 Sanctions Screening

RoyalSpinia screens all players against applicable international sanctions lists, including those published by the United Nations, the European Union, and other relevant authorities, at registration and on an ongoing basis. Where a match is identified, the account will be suspended immediately, funds will be frozen, and the matter will be reported to the appropriate authorities without delay. RoyalSpinia will not provide services to any individual or entity that is the subject of financial sanctions.

6. Identity Verification Procedures

All identity documents submitted to royalspiniaapp.nl are reviewed by the compliance team. RoyalSpinia may use automated identity-verification technology, third-party database checks or manual document review, or a combination of all three.

The following standards apply to submitted documents:

• All documents must be valid and unexpired at the time of submission;
• Images must be clear, unobstructed and in full colour — black-and-white copies or heavily compressed images may be rejected;
• Documents must not have been altered or tampered with in any way;
• The name, address and date of birth on submitted documents must match the details provided at registration;
• RoyalSpinia reserves the right to request certified copies, notarised translations or a live video-verification session for documents in languages other than English.

Players are responsible for ensuring that their account details remain accurate at all times. Any change of name, address or contact information must be notified to the compliance team promptly, and updated documentation may be required.

7. Payment Method Matching

RoyalSpinia operates a strict policy of payment method matching. Deposits and withdrawals must be made to and from the same payment method and must be in the name of the registered account holder. The following apply:

• Third-party deposits and withdrawals are not permitted under any circumstances;
• Withdrawals will be returned to the original deposit method where possible — for example, a deposit made via Visa or Mastercard will be returned to the same card up to the deposited amount before any remaining balance is paid to an alternative method;
• Cryptocurrency withdrawals will be processed to a wallet address that the player can demonstrate ownership of — RoyalSpinia will not send crypto funds to an unverified or third-party wallet;
• Where a player uses multiple payment methods, each method must be separately verified before it can be used for withdrawals.

The minimum withdrawal across all methods is €50. The standard weekly withdrawal cap is €3,000 and the standard monthly cap is €10,000. VIP players on the Gold or Platinum tier may arrange higher personal limits directly with the RoyalSpinia support team, subject to satisfactory completion of any additional due diligence required.

8. Cryptocurrency Transactions

RoyalSpinia accepts deposits and processes withdrawals in Bitcoin (BTC), Ethereum, Litecoin and TRON. The minimum deposit via cryptocurrency is €10, and the minimum withdrawal is €50. Crypto withdrawals are processed instantly upon approval of the associated withdrawal request.

Because cryptocurrency transactions are pseudonymous, RoyalSpinia applies additional scrutiny to accounts that transact primarily or exclusively via crypto channels:

• Players using cryptocurrency must complete full identity verification in the same way as players using fiat payment methods;
• RoyalSpinia reserves the right to use blockchain analytics tools to assess the risk profile of cryptocurrency wallets associated with a player's account;
• Deposits from wallets identified as high-risk by blockchain analytics tools — for example, wallets connected to darknet markets, mixing services or sanctioned entities — will not be accepted and may trigger a suspicious-activity report;
• EDD, including proof of source of funds, will be requested where crypto deposit volumes are disproportionate to the player's stated financial profile.

9. Suspicious Activity — Identification and Reporting

9.1 Identifying Suspicious Activity

All members of the RoyalSpinia compliance and customer-support team are trained to identify indicators of suspicious activity. The automated transaction-monitoring system flags accounts and transactions for manual review based on configurable risk rules. Indicators of potential money laundering include, but are not limited to:

• Deposits and quick withdrawals with little or no gambling activity in between;
• Multiple failed deposit attempts across different payment methods followed by a large successful deposit;
• Attempts to deposit amounts that are just below internal monitoring thresholds (structuring);
• Requests to withdraw to a different payment method or account name than the one used to deposit;
• Unusual interest in the casino's AML procedures or questions about monitoring thresholds;
• Consistent losses at live tables without apparent concern, followed by large withdrawal requests;
• Use of cryptocurrency wallets that have passed through mixing or tumbling services;
• Inability or refusal to provide satisfactory documentation when requested;
• Inconsistency between declared occupation or income and actual transaction volumes;
• Sudden or unexplained changes in account behaviour, such as a dramatic increase in deposit frequency or amount.

9.2 Internal Escalation

Any member of staff who identifies, or reasonably suspects, that a player account is associated with money laundering or terrorist financing must escalate the matter immediately to the designated Money Laundering Reporting Officer (MLRO). Internal escalation must not be delayed pending collection of additional evidence — if there is a reasonable basis for suspicion, the matter is escalated.

The MLRO will review the escalated matter, determine whether a Suspicious Activity Report (SAR) or equivalent disclosure is required under applicable law and regulatory guidance, and take any necessary action with respect to the account, including suspension of withdrawal processing or account access pending investigation.

9.3 Tipping Off

It is a criminal offence to inform a player, or any third party, that a SAR has been filed or that a suspicious-activity investigation is underway. All staff are strictly prohibited from tipping off any person who is the subject of, or connected to, a money-laundering investigation. Where a player enquires about a delay in withdrawal processing that is related to a suspicious-activity investigation, staff will advise only that the account is under routine compliance review and will not disclose any further information.

10. Record Keeping

RoyalSpinia maintains comprehensive records in connection with its AML/KYC obligations. Records are retained for a minimum period of five years from the date of the relevant transaction or the end of the customer relationship, whichever is later. Records maintained include:

• All KYC documentation collected from players, including identity documents and proof of address;
• Records of all transactions, including deposits, withdrawals, bonus credits, cashback and rakeback payments, and any adjustments made by the compliance team;
• Records of all CDD and EDD assessments, including the date of the assessment, the documents reviewed and the outcome;
• Records of all SARs or equivalent disclosures made to the relevant authorities;
• Records of all internal suspicious-activity escalations, whether or not they resulted in a formal SAR;
• Records of all staff AML training, including dates, content and attendance.

All records are stored securely using encryption appropriate to their sensitivity. Access is restricted to authorised personnel on a need-to-know basis.

11. Account Restrictions, Suspension and Closure

RoyalSpinia reserves the right to take the following actions at any stage of the compliance process:

• Request additional documentation before processing a withdrawal or bonus payout, regardless of the amount;
• Delay or suspend withdrawals pending completion of KYC verification or investigation of a suspicious-activity alert — the minimum withdrawal processing timelines stated on royalspiniaapp.nl (instant for crypto, up to 24 hours for e-wallets, 3–5 business days for cards) are subject to compliance requirements and are not guaranteed where an account is under review;
• Restrict account access — including restricting deposits, gameplay or bonus eligibility — pending resolution of a compliance matter;
• Close the account permanently where RoyalSpinia determines that the player has provided false or misleading information, has engaged in fraudulent or suspicious activity, or poses an unacceptable risk under this Policy;
• Freeze and report funds where there is a reasonable basis to believe that funds in a player account represent the proceeds of crime or are connected to terrorist financing;
• Void bonuses and winnings derived from activity that is found, on investigation, to be fraudulent or in breach of this Policy.

Where an account is closed for AML or fraud-related reasons, RoyalSpinia will return verified funds to the player's original payment method where it is lawful to do so. Where funds are subject to a freeze or a regulatory reporting obligation, RoyalSpinia may be prevented by law from returning those funds until the relevant authority gives clearance.

12. Responsible Gaming and Financial Safeguards

RoyalSpinia recognises that responsible gaming and financial crime prevention are complementary objectives. Players who are experiencing difficulties with their gambling activity are encouraged to use the responsible-gaming tools available on royalspiniaapp.nl, including deposit limits, session limits and self-exclusion. Responsible-gaming activity — such as frequent use of self-exclusion or erratic deposit-and-withdrawal patterns — may itself be a factor considered in a broader account review.

RoyalSpinia does not permit players under the age of 18 to register or transact on the platform. Age verification is a mandatory component of the KYC process, and any account found to belong to a minor will be closed immediately, with all funds returned to the verified payment method in accordance with applicable law.

13. Staff Training

All members of the RoyalSpinia compliance, support and payments teams receive AML/KYC training at induction and on a regular refresher basis thereafter. Training covers:

• The legal framework governing AML and KYC obligations under the Tobique Gaming Commission licence;
• How to recognise indicators of money laundering and suspicious activity;
• Internal escalation procedures and the role of the MLRO;
• The prohibition on tipping off;
• Record-keeping obligations;
• Updates to legislation, regulatory guidance or internal policy.

Training records are maintained in accordance with the record-keeping requirements set out in Section 10 above.

14. Non-Compliance by Players

Where a player fails or refuses to provide documentation requested under this Policy within a reasonable timeframe, RoyalSpinia will treat that failure as a risk indicator and may take one or more of the following steps:

• Suspend pending withdrawal requests;
• Restrict or suspend access to the player account;
• Close the account and return verified funds to the original deposit method, less any applicable charges;
• File a suspicious-activity report with the relevant authority.

Players are reminded that delays caused by incomplete or outstanding KYC documentation are not the responsibility of RoyalSpinia. Withdrawal processing timelines begin from the point at which all required documentation has been received, reviewed and approved by the compliance team.

15. Conflicts and Complaints

If you have a question or concern about how this Policy has been applied to your account, please contact the RoyalSpinia compliance team in the first instance via live chat (available 24/7) or by email. Full details are available in the Support section of royalspiniaapp.nl. RoyalSpinia is committed to resolving compliance-related disputes fairly and promptly, consistent with its obligations under the Tobique Gaming Commission licence.

16. Policy Governance

This Policy is owned by the Money Laundering Reporting Officer of Tekuno Technologies S.R.L. It is reviewed at least annually and updated whenever material changes in regulation, licence conditions or operational risk require revision. The version published on royalspiniaapp.nl at any given time is the version in force.