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Anti-Money Laundering (AML) Policy

Last updated: 2026

This Anti-Money Laundering (AML) Policy explains how Spinzen Casino ("Spinzen Casino", "we", "us", "our") prevents, detects, and reports money laundering, predicate offences, fraud, and terrorist financing risks in connection with the services available at spinzen.co.nz (the “Website”).

This is a service (compliance) page intended to describe our internal controls, customer due diligence procedures, and the actions we may take to protect our players and our business. By creating an account, depositing, withdrawing, or otherwise using our services, you agree to comply with this AML Policy and to provide information and documents we may reasonably request.

1. Scope and objectives

Spinzen Casino maintains a risk-based AML and Counter-Terrorist Financing (CTF) program designed to:

  • verify customer identity (KYC) and, where relevant, beneficial ownership;
  • monitor deposits, withdrawals, and gameplay for unusual or suspicious patterns;
  • conduct Source of Funds (SOF) / Source of Wealth (SOW) checks where required;
  • identify and manage higher-risk customers, transactions, payment methods, and jurisdictions;
  • meet applicable legal and regulatory obligations, including those arising from our licensing requirements and generally accepted AML/CTF standards.

2. Who we are

  • Brand: Spinzen Casino
  • Domain: spinzen.co.nz
  • Operator/Company: Fionex Holding LTD
  • Licence: Comoros (AOFA)
  • Established: 2025

We may use third-party identity, fraud-prevention, and payment service providers to support our AML/CTF controls.

3. Definitions (plain-language)

  • Money laundering: any activity intended to conceal the origins of illegally obtained funds or to make them appear legitimate.
  • Terrorist financing: providing or collecting funds with the intention or knowledge they may be used to carry out terrorist acts.
  • KYC / Customer Due Diligence (CDD): checks we conduct to verify identity and assess risk.
  • Enhanced Due Diligence (EDD): additional checks applied to higher-risk situations.
  • SOF/SOW: evidence explaining where deposited funds come from and/or how a customer acquired their wealth.

4. Customer eligibility and general AML rules

To help prevent misuse of our services:

  • Players must provide accurate personal information and keep it up to date.
  • Each account must be used only by the registered individual. We may restrict or close accounts used by third parties.
  • We may refuse, suspend, or terminate services if we suspect fraud, money laundering, terrorist financing, or any other unlawful or prohibited activity.
  • We may restrict certain countries, regions, IP ranges, or payment instruments as part of our risk controls.

5. Know Your Customer (KYC) verification

We apply KYC checks to confirm identity and to meet AML/CTF requirements. Verification may be required:

  • during registration or at any time after account creation;
  • before processing withdrawals (including first withdrawal);
  • when deposit/withdrawal patterns or account activity trigger risk alerts;
  • when changes are made to key account details (e.g., name, address, email, phone);
  • when required by law, regulation, or our payment providers.

Typical documents we may request include:

  • Proof of identity: valid passport, national ID card, or driver licence.
  • Proof of address: utility bill, bank statement, or official government letter (generally recent).
  • Payment method verification: evidence that you own or control the payment method used (e.g., card proof, e-wallet ownership confirmation, wallet address checks).
  • Additional information: date of birth, occupation, expected activity, and other information required for risk assessment.

We may use electronic verification tools and/or manual review. We may request certified copies or additional documentation where necessary.

6. Enhanced Due Diligence (EDD)

EDD may be applied when a customer or transaction presents a higher level of AML/CTF risk. This can include (without limitation):

  • unusual transaction behaviour (e.g., rapid deposits and withdrawals with limited gameplay);
  • high-value deposits or withdrawals, or repeated large transactions;
  • use of certain payment methods or cryptocurrencies that raise risk indicators;
  • connections to higher-risk jurisdictions;
  • adverse media or other risk intelligence;
  • potential third-party funding indicators;
  • politically exposed persons (PEPs), their family members, or close associates.

EDD may include requesting additional SOF/SOW evidence, conducting more detailed checks, and applying account restrictions until verification is complete.

7. Source of Funds (SOF) and Source of Wealth (SOW)

To prevent the use of illicit funds, we may ask for reasonable evidence of the origin of funds used on the Website and/or the origin of your wealth. Examples include:

  • salary slips, employment contract, or employer confirmation;
  • bank statements showing income and relevant transactions;
  • proof of savings, inheritance, or gifts (including supporting documentation);
  • sale agreements (e.g., property/asset sale) and proof of proceeds;
  • company ownership documents and financial statements (for business income).

If requested, you must provide information that is accurate, complete, and sufficient for us to reasonably understand the origin of the funds. Failure to provide requested SOF/SOW information may result in withdrawal delays, restrictions, or account closure.

8. Transaction monitoring and suspicious activity

We conduct ongoing monitoring of accounts and transactions. We may review (automatically and/or manually):

  • deposit and withdrawal frequency, size, and patterns;
  • gameplay activity relative to deposits/withdrawals;
  • multiple accounts, collusion indicators, or shared device/IP/payment details;
  • chargeback behaviour and card testing indicators;
  • cryptocurrency deposits/withdrawals, wallet risk signals, and blockchain analytics indicators (where available).

Where appropriate, we may submit reports to competent authorities and/or cooperate with law enforcement and regulators. We may be prohibited from informing you that a report has been made or that an investigation is underway.

9. Payment methods, third-party payments, and wallet rules

To reduce AML risk, Spinzen Casino applies the following principles:

  • No third-party funding: deposits must be made from payment methods in the name of the account holder. We may request proof of ownership.
  • Withdrawals method: withdrawals are typically processed to the same payment method used for deposits where possible, subject to operational and compliance constraints.
  • Mixed payment methods: when multiple payment methods are used, we may apply additional checks and may prioritise refunds to original funding sources.
  • Crypto specific: for cryptocurrency transactions, we may request wallet ownership evidence and apply additional risk screening. We may decline transactions from high-risk addresses or services.

We support various payment options (availability may vary by region), including bank transfer, cards, e-wallets, and certain cryptocurrencies.

10. Withdrawals, review timelines, and compliance holds

Withdrawals are subject to security and compliance checks. We may place a temporary hold on withdrawals or account activity if:

  • KYC/EDD/SOF checks are pending or incomplete;
  • we suspect fraud, account takeover, collusion, bonus abuse, or prohibited activity;
  • we detect inconsistencies in the information provided;
  • payment processors request additional verification;
  • we are required to do so by law, regulation, or competent authorities.

Spinzen Casino may apply withdrawal limits in accordance with our terms. As a general account-level limit, withdrawals may be capped at €15,000 per month, subject to your account status, verification, and other applicable terms.

11. Record keeping

We retain KYC, transaction, and compliance records for the period required by applicable laws and regulatory obligations and/or as reasonably necessary for legitimate business purposes such as dispute handling, fraud prevention, and AML/CTF compliance.

12. Data protection and privacy

Personal data collected for AML/CTF purposes is handled in accordance with our Privacy Policy and applicable privacy requirements. We may share information with identity verification providers, payment processors, regulators, and law enforcement where lawful and necessary for compliance, fraud prevention, or risk management.

13. Staff training and internal controls

Spinzen Casino maintains internal controls intended to ensure effective AML/CTF compliance, including:

  • ongoing risk assessment and monitoring procedures;
  • staff training relevant to AML/CTF and fraud prevention;
  • escalation processes for suspicious activity reviews;
  • periodic updates to policies and procedures.

14. Breaches, enforcement, and account actions

If we believe that an account is associated with money laundering, terrorist financing, fraud, or other prohibited conduct, we may take one or more of the following actions (as permitted by law and our terms):

  • request additional information and documentation;
  • restrict deposits, gameplay, bonuses, or withdrawals;
  • freeze or suspend the account while we investigate;
  • void or withhold withdrawals and/or confiscate funds where required by law or where funds are linked to unlawful activity;
  • terminate the account and refuse future service;
  • report to relevant authorities and cooperate with investigations.

15. Policy updates

We may update this AML Policy from time to time to reflect changes in our risk approach, operational procedures, legal requirements, or regulatory guidance. The most recent version will be published on the Website with an updated “Last updated” date.

16. Contact

If you have questions about this AML Policy or a verification request, please contact our support team via the Website support channels. For compliance-related matters, you may request escalation to our compliance function through customer support.

Spinzen Casino
Website: https://spinzen.co.nz

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