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Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy Carlitta N.V.

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Effective Date: June 9, 2025
Operator: Carlitta N.V., License No. OGL/2024/1516/0841 (Curaçao)

1. Introduction

At pinco-casino.global, operated by Carlitta N.V., we uphold the highest standards of integrity, transparency, and compliance. We are fully committed to preventing financial crime by implementing robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) procedures, in line with:

  • Curaçao Gaming Authority (CGA) AML/CFT Regulations
  • National Ordinance on Reporting Unusual Transactions (NORUT)
  • National Ordinance on Identification (NOIS)
  • Kingdom Sanctions Act
  • Sanctions National Ordinance
  • FATF’s 40 Recommendations

This policy ensures that only legitimate, verified users access our platform and helps preserve a secure gaming environment.

2. Purpose of the Policy

Our AML/KYC Policy aims to:

  • Prevent use of our platform for money laundering, terrorism financing, or illegal arms proliferation.
  • Confirm that player funds come from legal sources.
  • Apply risk-based identity verification procedures.
  • Comply with Curaçao and global AML/CTF standards.
  • Safeguard our players, systems, and reputation from financial crime.

3. Key Definitions

  • Money Laundering (ML), Terrorist Financing (TF), and Proliferation Financing (FP): Crimes involving the illegal movement or funding of assets.
  • KYC: Identification and verification of players’ identities, including document checks and screening.
  • CDD (Customer Due Diligence): Procedures for verifying customer legitimacy based on risk.
  • PEP (Politically Exposed Person): Public officials or their close associates.
  • FIU: Curaçao’s Financial Intelligence Unit.

4. Who This Policy Applies To

This Policy applies to:

  • All players on pinco-casino.global
  • Internal KYC, customer service, and compliance teams
  • Third-party service providers involved in KYC or payments

5. Age & Jurisdictional Compliance

5.1. Minimum Age

Only individuals aged 18 or older may register. Age verification is mandatory. Underage accounts are closed, and funds may be forfeited.

5.2. Prohibited Jurisdictions

Access is denied to users from:

  • Countries under UN, EU, or OFAC sanctions
  • High-risk jurisdictions identified by FATF
  • Any region listed in Carlitta N.V.’s internal restricted list

Technical controls include geo-IP restrictions, VPN detection, and payment monitoring.

6. Account Registration

To register, players must provide:

  • Full legal name
  • Date/place of birth
  • Residential address
  • Nationality
  • Valid email and phone number
  • Identity number (if applicable)
  • Preferred currency and password

Access is only granted after successful email verification. We reserve the right to request further documentation to confirm accuracy.

7. Know Your Customer (KYC)

KYC verification is required to access full account functionality and complete transactions. Verification may be requested at registration or any time thereafter.

Required Documents:

1. Proof of Identity (Color Copy + Selfie):

  • Passport
  • National ID card
  • Driver’s license
  • Residency permit

2. Proof of Address (Issued within 6 months):

  • Utility bill
  • Bank statement
  • Lease agreement

Document Standards:
All documents must be legible, full-color, unaltered, and show all corners.

Additional Documentation May Include:

  • Proof of payment method ownership
  • Source of Funds/Wealth (SoF/SoW)
  • Certified copies (if required)

8. Payment Verification

Key Principles:

  • Personal Use Only: No third-party deposits or withdrawals.
  • Matching Methods: Withdrawals should match the method used for deposits, where possible.
  • No Cash Transactions: Only traceable online methods are accepted.
  • Documentation: May be required to confirm payment method ownership.

Non-compliance can lead to rejected transactions or account suspension.

9. Customer Due Diligence (CDD)

Carlitta N.V. applies risk-based CDD based on player activity and profile. Higher-risk accounts undergo enhanced procedures.

10. Politically Exposed Persons (PEPs)

PEPs undergo additional checks including:

  • Enhanced due diligence
  • Senior management approval
  • Periodic relationship reviews

We continuously monitor PEP status as part of our AML obligations.

11. Re-verification & Monitoring

Players may be asked to resubmit or update documents at any time. Until verification is complete, some services may be restricted.

12. Ongoing Monitoring

We maintain continuous oversight of player activity through:

  • Regular review of documentation
  • Risk reassessment
  • Behavior and transaction analysis

This ensures data accuracy and AML compliance over time.

13. Transaction Monitoring

We utilize automated systems and manual reviews to detect suspicious transactions that fall outside expected behavior or risk thresholds.

14. Sanctions Compliance

All users are screened against global watchlists:

  • UN Security Council
  • EU Sanctions
  • OFAC
  • Local authorities

Accounts linked to sanctioned individuals are restricted or closed as required by law.

15. Recordkeeping

We retain the following for 5–10 years, securely and in compliance with data protection regulations:

  • KYC records
  • Transaction logs
  • Risk assessments
  • Communications with regulators

16. Continuous Improvement

Our compliance framework is reviewed annually or more frequently in response to:

  • Regulatory changes
  • New technologies or customer behaviors
  • Risk assessment findings
  • Internal audits

This ensures our controls evolve with emerging threats and expectations.

17. Non-Compliance Sanctions

Players failing to comply with AML or KYC obligations may face:

  • Temporary or permanent account suspension
  • Blocked withdrawals
  • Relationship termination
  • Reporting to the FIU of Curaçao
  • Legal and administrative action

18. Withdrawal Conditions

Withdrawals are processed only after successful verification and must:

  • Use the same payment method as the deposit
  • Fulfill wagering or bonus requirements
  • Be traceable and consistent with fair use

Withdrawals to third-party accounts are prohibited.

19. Player Responsibilities

All players must:

  • Provide accurate and up-to-date information
  • Use only their own identity and financial accounts
  • Respond promptly to verification requests
  • Operate a single account
  • Avoid misuse of bonus or deposit systems

Violations may result in corrective measures, including account restrictions or closure.

20. Communication & Transparency

We notify players when verification is required and offer full support for documentation and compliance questions via our support team.

21. Data Protection & Security

All personal and financial data is:

  • Encrypted and securely stored
  • Accessible only to authorized personnel
  • Handled under a defined incident response plan

22. Regulatory Cooperation

Carlitta N.V. works closely with:

  • Financial Intelligence Unit (FIU) Curaçao
  • Law enforcement and licensing bodies

In lawful cases, we may disclose:

  • KYC documents
  • Transaction records
  • Risk and monitoring logs
  • Internal compliance findings

23. Compliance Officer

We appoint a dedicated Compliance Officer to:

  • Oversee AML/KYC implementation
  • Handle internal reporting
  • Liaise with FIU and regulators
  • Conduct internal training
  • Perform risk assessments

This role operates independently and reports directly to senior management.

24. Contact

For compliance or verification assistance:

📧 [email protected]

All inquiries are handled confidentially under applicable data protection laws.

Let me know if you’d like this AML/KYC Policy compiled into a downloadable Word or PDF document, or adapted for your website’s legal page.