Scope and Purpose

Spin Palace maintains an Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) program to prevent the use of the platform for illicit activity, in compliance with applicable laws and regulations governing financial services and online gaming. This policy applies to all customers, prospective customers, and interactions within Spin Palace’s services. The program is reviewed and updated quarterly, and adherence is mandatory for all personnel and contractors.

Customer Identification and Verification (KYC)

On onboarding and on an ongoing basis, Spin Palace shall identify and verify the Customer. For individuals, the data collected includes full name, date of birth, country of residence, mobile number and email address. For legal entities, corporate name, registration number, registered address and details of Beneficial Owners are collected. Verification is conducted using reliable, independent sources and documents. Acceptable identity documents include a high‑resolution copy or photo of a passport, national identity card, or driving license, not older than three months, and proof of address such as a utility bill or bank reference issued within the last three months. For payment cards used in the account, the Customer may be required to provide a scanned copy or photo of the front and back; the front must show the cardholder’s name, expiry date, and the first six and last four digits of the card number; the back must show the cardholder’s signature, with the CVV/CVC2 code obscured. Spin Palace reserves the right to request additional information or documents to satisfy KYC/CFT obligations.

Account Registration and Data Integrity

The information provided at registration and during the term of the relationship must be accurate, complete and true. The name on the Account must match the Customer’s true legal name. Spin Palace may suspend activity or close the Account if verification is incomplete or if information changes are not promptly provided. Each Customer may open a single Account; duplicate Accounts are prohibited. Where a duplicate Account is established, Spin Palace may take actions including nullification of duplicate transactions, forfeiture of bonuses and winnings, and recovery of funds as permitted by applicable law. Anonymous or third‑party bank accounts are strictly prohibited in accordance with AML/CFT rules.

Payment Policies and Transactions

Spin Palace does not accept cash deposits or withdrawals. The platform reserves the right to refuse processing a transaction at any stage if there is a reasonable basis to suspect money laundering or terrorist financing. Funds deposited must be associated with the Customer’s name in Spin Palace’s records; third‑party payments are not accepted. Deposits and withdrawals must use the same payment method and the same account name as recorded. If a deposit is made via wire transfer, withdrawals shall be made via the same transfer method to the same bank account; if a deposit is made by a payment system, withdrawals shall be conducted through the same system to the same account. Withdrawals must be conducted in the same currency as the deposit. Spin Palace maintains transaction records for a minimum of five (5) years after termination of the business relationship, in accordance with applicable law and regulatory requirements.

Governance, Training and Reporting

Spin Palace appoints a designated AML Compliance Officer responsible for implementing and maintaining the AML program, reviewing transactions for suspicious activity, and ensuring ongoing employee training. All employees with client‑facing or AML‑related duties undergo AML/CFT training, including identification and reporting of suspicious transactions. Violations of this policy must be reported promptly to the AML Compliance Officer; if the violation concerns the AML Compliance Officer, the matter is escalated to the Chief Executive Officer or an equivalent senior officer.

Risk Assessment and Customer/Geographic Risk

Spin Palace adopts a risk‑based framework to identify, assess and mitigate money laundering and terrorism financing risks. The framework evaluates threats, vulnerabilities, and consequences across customer profiles and geographic exposure. Country risk is assessed in conjunction with cross‑border operations; Customer risk factors include, but are not limited to, politically exposed persons (PEPs) or related persons, high‑spending patterns inconsistent with known resources, and unusual or complex transactional activity. Mitigation steps are proportionate to risk, and are not treated as mere formality.

High‑Risk Jurisdictions

Spin Palace applies enhanced due diligence for customers connected to jurisdictions identified as high‑risk by official guidance. The list below is indicative and subject to update: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Democratic People’s Republic of Korea, Haiti, Iran, Jamaica, Jordan, Mali, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, Uganda, United Arab Emirates, Yemen. Spin Palace conducts additional checks and controls for cooperation with these jurisdictions in accordance with applicable AML/CFT laws and guidance.

Recordkeeping, Privacy and Data Protection

Spin Palace preserves identity verification records, transaction data, and related KYC information for a minimum of five (5) years after the termination of the customer relationship, or longer if required by applicable law. Personal data collection, processing and storage are conducted consistent with applicable data protection laws. Personal data is accessed solely by authorized personnel for AML/CFT compliance, account administration and regulatory reporting, and is safeguarded against unauthorized disclosure. Customers may exercise rights to access, rectify or erase personal data in accordance with applicable law and Spin Palace’s internal policies, subject to statutory exceptions and customary business needs.

Suspicious Activity Reporting and Cooperation

Spin Palace continuously monitors for unusual or potentially suspicious activity and shall report such activity to the competent authorities in accordance with applicable AML/CFT laws. The platform cooperates with regulatory and law enforcement authorities, providing information and documents as required within the scope of lawful requests and data protection constraints.

Governing Law and Disclosures

This AML policy constitutes an integral part of Spin Palace’s terms and conditions for use of the platform and services. In the event of a conflict between this policy and applicable law, the governing legal framework shall prevail. This policy binds Spin Palace personnel, contractors, agents, and partners operating under the Spin Palace brand.