AML-KYC Policy

Last updated: 06 January 2026

AML Anti-Money-Laundering policy of SpinDjinn.

Introduction:

SpinDjinn is operated by Fortuna Games N.V. with its registered address at 17 С Seru Loraweg, Curacao and its registration number 162413, which is licensed by the Curaçao Gaming Control Board since 24/Jun/2025 to offer games of chance under license number OGL/2024/112/0974 in accordance with the National Ordinance on Offshore Games of Hazard and has its subsidiary company Deltaprime Limited, which is a Billing agent of Fortuna Games N.V. with its registered address at Angelou Terzaki, 110B, Flat/Office 1, Egkomi, 2402, Nicosia, Cyprus and with its registration number HE 444864. Deltaprime Limited acts as an EEA Representative of the licensed entity Fortuna Games N.V. Customer support team is available at [email protected].

Objective of the AML Policy:

We seek to offer the highest security to all of our users and customers on SpinDjinn. For that a three step account verification is done in order to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into account that depending on the nationality and origin, the way of payment, and withdrawal different safety measurements must be taken.

SpinDjinn also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

SpinDjinn is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

Compliance Framework:

- EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”

- EU: “Regulation 2015/847 on information accompanying transfers of funds”

- EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

- BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash”

Definition of money laundering:

Money Laundering is understood as:

- The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;

- The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

- The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;

- Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for SpinDjinn:

In accordance with the AML legislation, SpinDjinn has appointed the “highest level” for the prevention of ML: The full management of Fortuna Games N.V are in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general Management.

AML policy changes and implementation requirements: Each major change of SpinDjinn AML policy is subject to approval by the general management of Fortuna Games N.V and the Anti Money Laundering Compliance Officer.

Three step Verification:

Step one verification:

Step one verification must be done by every user and customer to withdraw. Regardless of the choice of payment, the amount of payment, the amount of withdrawal, the choice of withdrawal and nationality of the user/customer, step one verification must be done first. Step one verification is a document that must be filled out by the user/customer. The following information must be provided:

- First name

- Second name

- Date of birth

- Country of usual residence

- Gender

- Full address

Step two verification:

Step two verification must be completed by every user who deposits over €2000 (two thousand Euro) or withdraws over €2000 (two thousand Euro). Until step two verification is completed, the withdrawal or deposit will be placed on hold.

Step two verification will direct the user/customer to a subpage where they must upload a picture of their ID. The user/customer must take a picture of the ID with a paperclip holding a six-digit randomly generated number next to it. Only an official ID may be used for verification. Depending on the country, the variety of accepted IDs may differ.

There will also be an electronic check to verify that the data entered during step one matches the information on the ID using two separate databases. If the electronic verification fails or is not possible, the user/customer must provide proof of current residence. A certificate of registration issued by the government or a similar official document is required.

Step three verification:

Step three verification must be completed by every user who deposits over €5000 (five thousand Euro) or withdraws over €5000 (five thousand Euro). Until step three verification is completed, the withdrawal or deposit will be placed on hold.

For step three, the user/customer will be asked to provide proof of source of wealth.

Customer identification and verification (KYC)

The formal identification of customers upon entering into commercial relations is a vital element both for anti-money laundering regulations and for the KYC policy. This identification relies on the following fundamental principles:

- A copy of your passport, ID card or driving license, shown alongside a handwritten note mentioning six randomly generated numbers.

- A second picture with the face of the user/customer is required.

- The user/customer may blur every piece of information except the date of birth, nationality, gender, first name, second name and photograph in order to protect their privacy.

Please note that all four corners of the ID must be visible in the same image and all details must be clearly readable except those specifically allowed to be hidden. We may request all details if necessary.

An employee may carry out additional checks if required, depending on the situation.

Proof of Address:

Proof of address will be completed using two different electronic verification checks based on two independent databases. If the electronic verification fails, the user/customer may provide proof manually.

- A recent utility bill sent to your registered address and issued within the last 3 months; or

- An official government-issued document proving your place of residence.

To make the approval process as fast as possible, please ensure that the document is submitted in high resolution, with all four corners visible and all text clearly readable.

For example:

- An electricity bill, water bill, bank statement or any governmental post addressed to you.

An employee may do additional checks if necessary, based on the situation.

If a player deposits over five thousand Euro there is a process of understanding the source of wealth (SOW).

Examples of SOW are:

- Ownership of business

- Employment

- Inheritance

- Investment

- Family

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or proof.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and information will also be displayed on the website itself.

SpinDjinn also asks for a bank wire/credit card to further ensure the identity of the user/customer. It also provides additional information about the financial situation of the user/customer.

Basic document for step one:

The basic document will be accessible via the settings page on SpinDjinn. Every user has to fill out the following information:

- First name

- Second name

- Nationality

- Gender

- Date of Birth

The document will be saved and created by an AI. An employee may perform additional checks if necessary based on the situation.

Risk management:

In order to deal with the different risks and different states of wealth in different regions of the world, SpinDjinn categorizes every nation into three different risk regions.

Region one: Low risk:

For every nation from region one, the three-step verification is completed as described earlier.

Region two: Medium risk:

For every nation from region two, the three-step verification will be completed at lower deposit, withdrawal and transfer thresholds.

- Step one will be completed as usual.

- Step two will be completed after depositing €1000 (one thousand Euro) or withdrawing €1000 (one thousand Euro).

- Step three will be completed after depositing €2500 (two thousand five hundred Euro) or withdrawing €2500 (two thousand five hundred Euro).

Users from a low-risk region that exchange cryptocurrency into any other currency will also be treated as users/customers from a medium-risk region.

Region three: High risk:

Regions classified as high risk will be banned. The list of high-risk regions will be updated regularly to reflect changes in the global environment.

Additional measures.

In addition, an AI system supervised by the AML Compliance Officer monitors unusual behaviour and immediately reports it to a SpinDjinn employee.

According to a risk-based approach and general experience, human employees will review all checks previously completed by the AI or other employees and may repeat or perform additional checks depending on the situation.

A data scientist supported by modern analytical systems also monitors unusual behaviour such as:

- Depositing and withdrawing without meaningful betting activity.

- Attempts to use different bank accounts for deposits and withdrawals.

- Nationality changes.

- Currency changes.

- Behaviour and activity changes.

- Verification that an account is being used by its original owner.

A user must also use the same withdrawal method that was used for the initial deposit amount in order to prevent money laundering.

Enterprise-wide risk assessment

As part of its risk-based approach, SpinDjinn has conducted an AML Enterprise-wide Risk Assessment (EWRA) to identify and understand risks specific to SpinDjinn and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business, including the services offered, customer types, transaction patterns, delivery channels, geographic locations and other qualitative and emerging risks.

The identification of AML risk categories is based on SpinDjinn's understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are implemented to address the risks associated with operating online.

The EWRA is reassessed annually.

Ongoing transaction monitoring

AML Compliance ensures that ongoing transaction monitoring is conducted to detect unusual or suspicious transactions compared to the customer profile. This monitoring is conducted on three levels.

1) The first Line of Control:

SpinDjinn works only with trusted Payment Service Providers that maintain effective AML policies in order to prevent suspicious deposits before they reach the platform without proper KYC verification.

2) The second Line of Control:

SpinDjinn ensures that every interaction with a customer, player or authorised representative triggers appropriate transaction due diligence.

These include:

- Requests to execute financial transactions.

- Requests relating to payment methods or account services.

The three-step verification process together with the risk management framework provides the necessary information about all customers at all times.

All transactions are supervised by employees under the oversight of the AML Compliance Officer, who in turn reports to general management.

Transactions submitted to the Customer Support Manager, and where appropriate through the Compliance Manager, are also subject to due diligence.

The determination of whether one or more transactions are unusual depends on a risk-based assessment considering customer knowledge (KYC), financial behaviour and transaction counterparties.

These checks are performed by an automated system and independently verified by an employee for additional security.

Transactions for which it is difficult to determine the lawful source of funds or legitimate purpose will be considered atypical.

Every SpinDjinn staff member must report any atypical transaction that cannot reasonably be linked to a lawful activity or legitimate source of income to the AML division.

3) The third Line of Control:

As a final line of defence against money laundering, SpinDjinn performs manual reviews of all suspicious and high-risk users.

If fraud or money laundering is identified, the relevant authorities will be informed.

Reporting of suspicious transactions on SpinDjinn

SpinDjinn maintains internal procedures describing when suspicious activity must be reported and how such reporting must be carried out.

Reports of atypical transactions are analysed by the AML team according to internal procedures.

Based on the results of the investigation, the AML team will:

- Decide whether a report must be submitted to the Financial Intelligence Unit (FIU) in accordance with the Law of 18 September 2017.

- Decide whether the business relationship with the customer should be terminated.

Procedures

The AML rules, including minimum KYC standards, are translated into operational procedures available through the SpinDjinn internal systems.

Record keeping

Records obtained for customer identification purposes are retained for at least ten years after the business relationship ends.

Records of all transaction data are retained for at least ten years following the transaction or termination of the business relationship.

These records are securely encrypted and stored both offline and online.

Training

SpinDjinn employees perform manual AML controls using a risk-based approach and receive specialised AML training.

The training programme includes:

- Mandatory AML training in accordance with the latest regulatory developments for all employees involved in financial activities.

- Academic AML training sessions for all new employees.

- Training content tailored to employees' business functions and responsibilities, delivered by AML specialists from the Fortuna Games N.V. AML team.

Auditing

Internal audit regularly performs reviews and reports on AML activities.

Data Security

All data provided by users/customers is kept secure and will never be sold or shared with third parties. Information may only be disclosed where required by law or to prevent money laundering.

SpinDjinn follows all applicable requirements of the Data Protection Directive (Directive 95/46/EC).

Contact us:

If you have any questions about our AML and KYC Policy, please contact us by email: [email protected].

If you have any complaints regarding our AML and KYC Policy or the verification procedures applied to your Account, please contact us by email: [email protected].