AML & KYC Policy

Spinman operates under gaming licenses issued by the Government of Anjouan and the Lao PDR. Both license regimes require us to maintain an anti-money-laundering ("AML") and counter-terrorist-financing ("CTF") program proportionate to the risk of our customer base. As a crypto-first casino we apply on-chain analytics in addition to the traditional customer-due-diligence ("CDD") workflow.

• Tier 0 — guest play. No CDD required. Demo balance only, no real-money deposit or withdrawal.
• Tier 1 — registered player. Verified email + on-chain deposit. No formal ID required for normal play and withdrawal volumes.
• Tier 2 — enhanced CDD. Triggered by cumulative deposit / withdrawal thresholds, high-risk geo signals, or pattern anomalies. Requires government ID, proof of address, and a source-of-funds declaration.
• Tier 3 — enhanced + EDD. Politically Exposed Person ("PEP"), adverse-media match, or large single transactions. Senior compliance approval required.

All registered players are screened against UN, OFAC SDN, EU consolidated, UK HMT, and relevant Asia-Pacific sanctions lists. On-chain deposits are screened against sanctions-tagged and stolen-funds clusters using a commercial blockchain analytics provider before being credited.

For Tier 2 and above we will request a brief written explanation of the source of deposited funds. Acceptable sources include salaried income, business income, investment returns (including crypto trading), inheritance, and gambling winnings from other licensed operators. We may request supporting evidence.

Automated monitoring flags include, but are not limited to:

• Rapid deposit-withdraw cycles with minimal play ("rinsing").
• Deposits from mixers, sanctioned addresses, or stolen-funds clusters.
• Withdrawals to an address that received the original deposit.
• Unusual time-of-day, geo-velocity, or device-fingerprint patterns.
• Bonus-abuse and multi-accounting patterns.

Flagged transactions are paused pending compliance review.

Suspicious-activity reports are filed with the competent financial-intelligence units in Anjouan and Lao PDR where required. CDD records and transaction logs are retained for a minimum of five (5) years from the end of the customer relationship.

We do not accept players resident or located in jurisdictions where online gambling is prohibited or where we cannot offer the service in compliance with our licenses. Spinman enforces a geo-IP gate on first load and reserves the right to void play and withhold winnings from players who circumvent it.

AML / compliance enquiries: compliance@spinman.com