Anti-Money Laundering Policy

SlotsDon Anti-Money Laundering Policy

Introduction

The government of the Autonomous Island of Anjouan, Union of Comoros, gave License No. ALSI-1423 l 1005-FI2 to Igloo Ventures SRL, a licensed online gaming platform based in San José, Costa Rica (registration number: 3-102-880024). Slots Don is run by this company.

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy is adopted by Slots Don in accordance with its licencing requirements and its obligation to uphold an environment that is transparent, accountable, and safe. This policy is in place to protect our services from being used for illegal financial activities and to make sure that all users may use our platform fairly, securely, and without interruptions.

Objective of the AML Policy

By implementing this policy, Slots Don seeks to:

Safeguard the platform against criminal infiltration.
Protect genuine customers from fraud and identity theft.
Uphold the reputation of the gaming industry and comply with both local and international AML/CTF standards.

Definition of Money Laundering

The term “money laundering” describes any method used to make illegally obtained funds look like they came from a lawful source.

The following actions are considered money laundering under Dutch and EU legislation and FATF standards:

Transacting in property with the intent to conceal its true origin by converting or transferring it while knowing that its acquisition was illicit.
The act of converting or transferring property with the knowledge that it is obtained through illegal means in order to hide its origin.
Keeping assets’ genuine characteristics, origin, whereabouts, or ownership a secret.
Knowingly acquiring, possessing, or using property that is acquired from unlawful behavior.
Taking part in, assisting with, or trying to carry out the aforementioned tasks.

Even if the criminal conduct that generated the monies took place elsewhere, laundering can still happen. Therefore, Slots Don needs to be on the lookout for any cross-border dangers, such as clients making deposits or withdrawals in countries with lax anti-money laundering regulations.

Stages of Money Laundering

Staff members can benefit from having the three traditional steps of money laundering outlined:

The introduction of illicit funds into the financial system is known as placement. In the gaming industry, this may happen if a player uses stolen vouchers or credit card money to buy in-game items.
Layering: By executing numerous transactions, the true source of the funds is concealed. Some examples of this behavior on the part of online casinos include using several payment accounts, converting currencies, or making multiple deposits and withdrawals.
The money that has been washed away is then reintroduced into the market as if it were a legitimate prize. As an example, a player might try to cash out their funds even though they haven’t played much, passing them off as winnings from gambling.

Recognizing these stages helps staff spot possible exploitation, but not all suspicious transactions follow them.

What Constitutes Suspicious Activity in Online Gaming?

Fast transactions, anonymized payment methods, and the idea that small-value bets are less likely to raise alarms make online gaming particularly attractive to money launderers, according to Slots Don.

Examples of suspicious activity include:

Repeated deposits and immediate withdrawals without substantial gameplay.
Use of multiple accounts under slightly different names or emails.
Sudden changes in deposit behavior (e.g., a player previously depositing €50 now sending €5,000).
Use of unusual payment instruments (prepaid cards, third-party wallets, or crypto-to-fiat conversions).
Collusion between players where funds are transferred under the guise of bets or tips.
Attempts to bypass verification by refusing to provide documents or submitting altered IDs.
Accounts accessed from multiple geographical locations within short timeframes.
Large deposits followed by betting on very low-risk outcomes, ensuring most of the money can be withdrawn as “clean winnings.”

Employees and automated monitoring systems are instructed to flag these patterns for further investigation.

Organization of AML at Slots Don

In the end, it’s the responsibility of our board of directors and top management to make sure that our organization follows anti-money-laundering standards.

Establishing and updating policies and processes to regulatory standards is the responsibility of the AML Compliance Officer (AMLCO), who acts as the primary interface with regulators.
Members of the operations team are educated to recognize, record, and communicate any suspicious behavior.
Automating Systems: Machine Learning Can Spot Patterns in Transactions, User Behavior, and Odd Bets. These are reviewed by human compliance officers prior to taking any action.
For the AMLCO to be effective, they require power, funding, and communication with higher-ups.

Legal Basis and Policy Updates

Slots Don commits to reviewing and updating this AML Policy at least once per year or whenever there are significant changes in law, regulation, or operational risk.

All changes must be approved by both:

The General Management of Igloo Ventures SRL.
The AML Compliance Officer (AMLCO).

Every updated version is published on the Slots Don website with a clear “last updated” date. Customers are encouraged to review the policy periodically.

Risk-Based Approach

Every time Slots Don is updated, the “last updated” date appears front and center on the website. Customers are recommended to examine the policy periodically.

Using a Risk-Based Approach Modern anti-money-laundering (AML) compliance relies on the risk-based approach (RBA). All customers and transactions are not created equal, and Slots Don is well-aware of that. So, we take the necessary precautions:
Customers from nations with strong anti-money laundering laws, those making modest deposits, and those using transparent payment methods (such as bank accounts in the European Union) are considered low-risk clients. As is customary, these clients undergo Know Your Customer procedures.
Customers with medium risk levels are those who deposit greater amounts, transact frequently, or utilize payment processors that aren’t as transparent. We require more stringent verification standards in addition to other enhanced procedures.
Customers at High Risk: Those that deal in cryptocurrency, are politically exposed individuals (PEPs), or hail from nations with weak anti-money-laundering laws. Customers in this category are either given the cold shoulder or put through extra checks and balances.

While the RBA keeps a careful eye on potentially dangerous users, it makes sure that legal users have things easy.

Politically Exposed Persons (PEPs)

A PEP is an individual who holds or has held a prominent public function (e.g., government officials, senior executives of state-owned enterprises). PEPs pose a higher risk due to potential involvement in corruption.

Slots Don applies enhanced due diligence to:

The PEP themselves.
Their immediate family members.
Close associates who may act on their behalf.

Where a PEP is identified, the AMLCO must approve the relationship before the account can remain active.

Importance of Verification

One of the most important aspects of anti-money laundering compliance is customer verification, which is sometimes called Know Your Customer (KYC). Slots Don cannot identify or stop illegal conduct unless it knows exactly who is using the platform.

There are various reasons to perform verification:

Verifying the identity of each account holder to make sure they are who they claim to be.
Determine if the client represents a potential anti-money-laundering or counter-terrorism-related danger from a risk assessment perspective.
Adherence to regulations – Fulfilling the requirements of the Dutch, EU, and international anti-money-laundering frameworks.
Consumer security – Blocking con artists from passing themselves off as real users.

The Three-Step Verification Framework

Slots Don applies a tiered verification model that combines standard KYC with enhanced due diligence (EDD) where necessary.

Step 1: Identity Verification

Documents accepted: Passport, national ID card, or driver’s license.
Requirements:
- Full name, date of birth, and photograph must be visible.
- Documents must be valid and unexpired.
- Copies must be high-quality and free from alterations.
Additional checks:
- Automated software to detect forgeries, Photoshop alterations, or pixel manipulation.
- Cross-checking against international watchlists and sanction databases (UN, EU, OFAC).

Step 2: Address Verification

Documents accepted: Utility bills, bank statements, or government letters no older than 3 months.
Requirements:
- A clear photo, full name, and birthdate are required.
- All paperwork needs to be current and not expired.
- Reproductions ought to be of the highest quality and unaltered.

Step 3: Source of Funds / Source of Wealth

This is required for high-value customers or in situations flagged as high risk.

Source of Funds: Proof of where the money deposited originates (e.g., bank statements, payslips).
Source of Wealth: Broader evidence of the customer’s overall financial situation (e.g., tax returns, company ownership documents).
These documents help determine whether a customer’s financial activity is consistent with their known profile.

Ongoing Customer Due Diligence (CDD)

KYC is not a one-time exercise. Slots Don applies ongoing monitoring to ensure that customer behavior remains consistent with their verified profile.

Monitoring tools include:

Algorithms examine the kind, magnitude, and frequency of transactions in transaction analysis.
Monitoring a user’s geolocation allows us to identify potentially dangerous account access locations through IP and device checks.
Keep an eye out for any changes in behavior when it comes to gaming, such a casual gamer suddenly betting a lot of money.
Customers with an extended amount of time will need to renew their identification documents on a regular basis.

If any inconsistency arises, Slots Don may request updated documents or suspend account activity pending review.

Enhanced Due Diligence (EDD)

Where higher risks are detected, EDD measures are applied:

Added layer of identification verification via biometric confirmation or video calls.
Enhanced monetary paperwork (such as verified statements or audited company records).
Prior to authorizing substantial deposits or withdrawals, senior management must give their consent.
Reducing withdrawal thresholds and closely monitoring transactions.

EDD is mandatory for:

People Vulnerable to Political Pressure (PEPs).
Countries that are included on the FATF’s “grey list” or “blacklist” are not eligible to place orders.
Customers dealing in crypto-assets or other high-risk financial instruments.

Account Restrictions During Verification

Slots Don enforces strict rules to prevent unverified or partially verified accounts from being abused.

Deposits: Limited until verification is complete.
Withdrawals: Absolutely no withdrawals are permitted until full KYC is completed.
Bonuses: Cannot be claimed until the user’s identity has been confirmed.
Multiple Accounts: Prohibited. If detected, related accounts may be frozen and funds withheld pending investigation.

Case Studies: How Verification Works in Practice

To make this policy clear for staff and customers, below are practical scenarios:

Case 1: Casual Player from the Netherlands

Deposits €50 monthly using a verified Dutch bank account.
Provides ID card and utility bill.
Low risk. Account fully verified at Step 1 and Step 2. No further checks required.

Case 2: High-Roller from Germany

Deposits €10,000 in one transaction.
Identity verified, but address proof is outdated.
Additional documents requested. Customer must also provide source of funds (bank statement showing transaction history).
EDD applied, AMLCO approval required before withdrawal.

Case 3: Customer Using Cryptocurrency

Registers from an IP address located in Eastern Europe.
Deposits €5,000 in Bitcoin.
Identity documents appear valid, but funds are traced to a high-risk crypto exchange.
Account suspended pending enhanced due diligence. Funds withheld until origin of crypto can be verified.

Case 4: PEP Scenario

Customer is identified as a relative of a parliament member.
Even though deposits are moderate (€200), PEP status triggers EDD.
AMLCO informed, senior management approval required.
Extra monitoring applied to transactions for as long as the account remains active.

Handling False or Forged Documents

Slots Don has zero tolerance for fraudulent documents.

Detection: Trained staff and automated systems review metadata, fonts, and image integrity.
Outcome:
- If forgery is detected → account is terminated immediately.
- If suspected → account suspended until authenticity is confirmed.
Reporting: All attempts to provide forged documents are reported to competent authorities.

Customer Risk Scoring

Each player is assigned a dynamic risk score, which determines the level of monitoring required.

Scoring factors include:

Place of residence jurisdiction.
My profession and where I get my money.
Frequency and volume of deposits and withdrawals.
Currency and payment system uncertainty (e.g., regulated cryptocurrency vs. EU bank transfer)
Links to known high-risk individuals or entities.

Risk scores are continuously updated. If a low-risk customer begins displaying unusual behavior, their score is raised and additional measures are applied.

Confidentiality & Data Protection

While AML procedures require the collection of sensitive documents, Slots Don guarantees that:

In accordance with the General Data Protection Regulation (GDPR), all client data is kept securely.
Only authorized personnel from the AML and compliance departments have access.
No marketing or AML/CTF reasons whatsoever are ever considered when data is utilized.
In line with their rights under GDPR, customers have the right to seek access to their stored personal data.