Anti-Money Laundering Policy

Introduction

Slots Don is an online gaming platform operated by Igloo Ventures SRL, registration number 3-102-880024, registered at San José, Costa Rica (Cedula Juidica). The company holds a valid gaming license issued by the Government of the Autonomous Island of Anjouan, Union of Comoros, under License No. ALSI-1423 l 1005-FI2.

The gaming industry is subject to high scrutiny worldwide because of its exposure to financial transactions and the potential misuse of platforms for laundering funds. Online casinos are considered at risk because of their accessibility, the speed of transactions, and the ease of cross-border movement of digital funds. To address this risk, Slots Don adopts and implements a robust Anti-Money Laundering (AML) framework that meets European Union standards, complies with international good practices, and aligns with Dutch financial crime prevention requirements.

This AML Policy forms the cornerstone of the company’s compliance system. It outlines rules, preventive measures, responsibilities, and internal procedures. It also clarifies the rights and duties of players, so that every customer understands why verification is necessary and how the platform safeguards fairness and legality.

Purpose of the Policy

This study focuses on three key areas:

Conforming to EU legislation, Dutch anti-money-laundering laws, and worldwide standards.Building trust requires communicating with customers about data collection, usage, and protection rules..
Communicating with customers on data collection, use, and protection laws is crucial to building trust.
Identity fraud, money laundering, and terrorist financing are some of the threats this strategy will protect the group from.

Scope

This AML Policy applies to:

All directors and senior managers of Igloo Ventures SRL.
The appointed AML Compliance Officer (AMLCO) and their team.
All Slots Don employees, contractors, and service providers who handle customer data, payments, or verification procedures.
All registered players, who must comply with KYC and verification requirements before using the service fully.

The scope covers every type of transaction: deposits, withdrawals, internal transfers between users, currency conversions, and any other financial operation on the platform.

Definition of Money Laundering

As used in this Policy, “money laundering” can refer to a variety of activities, including the following:

When one tries to hide or mask the source, ownership, or character of illegally acquired monies, they are engaging in the activity of money laundering.
The term “conversion” or “transfer” describes the multi-step process of hiding the criminal origin of money by moving it across gaming accounts.
The practice of purchasing or owning gaming items with counterfeit currency.
Getting involved, even indirectly, by providing resources that other people can use to launder money is called facilitation.

All of the aforementioned conditions are applicable according to EU Directive 2015/849, irrespective of whether the base offense happened in one EU member state, more than one EU member state, or outside of any one of those states.

Governance and Responsibility

The responsibility for enforcing AML standards rests at the highest level of Igloo Ventures SRL. Management retains direct oversight of AML compliance, which is considered a priority risk area.

AML Compliance Officer (AMLCO)

Slots Don has appointed an AML Compliance Officer with the authority to:

Create and execute anti-money-laundering protocols.
Make sure the Financial Intelligence Unit (FIU) gets the right reports when they need them.
Always keep an eye on the transactions and how the players are acting.
Keep employee training programs running.
Revise risk assessments as needed to account for new regulations or industry developments.

The AMLCO reports directly to senior management. Any major change to the AML framework requires joint approval of the AMLCO and the Board of Directors.

Three-Step Verification Process

Slots Don applies a tiered verification model to balance ease of use with regulatory safeguards.

Step One – Basic Information

Required for all customers prior to making withdrawals.

Information collected: first and last name, date of birth, gender, nationality, residential address.
Data must be entered directly by the customer.
Failure to complete Step One results in immediate account restrictions.

Step Two – Document Verification

Triggered when a customer deposits over €2,000 or requests any withdrawal.

A customer’s legitimate government-issued identification is required.
An additional piece of paper containing a distinct random code—provided by the platform—must be attached to the ID in order to verify its legitimacy.
Data is cross-checked against independent databases through an electronic verification procedure.
A government-issued certificate or utility bill can be used as proof of address in the event that electronic verification does not work.

Step Three – Source of Wealth Declaration

Customers deserve to know where their money originated from. Wages, investments, inheritance, and family support are acceptable revenue sources.

Income proof may include sales contracts, pay stubs, and bank records.
After verification, we will suspend the account and stop processing transactions.
This phased method balances checks and reduces friction, making it perfect for recreational players.

For low-risk, casual players, this phased technique avoids unneeded friction while ensuring balanced checks.

Know Your Customer (KYC) Procedures

KYC is a core requirement of the AML framework. Its goal is to establish true customer identity and prevent impersonation or fraudulent use of accounts.

Key principles include:

Identity proof: Only original, government-issued IDs are accepted. Copies must be clear, with all corners visible.
Proof of address: Must be dated within the past 3 months and display both the player’s name and registered address.
Cross-checks: All submitted data is verified against external databases and watchlists.
Privacy: Customers may blur out non-essential information on documents, provided key details remain visible.

Employees are trained to recognize false or tampered documents and escalate any concerns to the AMLCO.

Risk-Based Approach

Slots Don applies different measures depending on the customer’s risk profile.

Low-Risk Countries

Standard three-step verification.
Monitoring is proportionate to activity.

Medium-risk Countries

Step two verification for medium-risk countries is now €1,000, while Step three is €2,500.
More people are keeping an eye on Bitcoin to fiat currency exchanges.

Hight-risk Countries

People from nations that are deemed to have a high risk of fraud cannot open an account.
The list of states that are considered high-risk is updated regularly in line with FATF and EU classifications.

Transaction Monitoring

Monitoring takes place at three levels:

First line – Payment providers: Only licensed and trusted payment processors are used. They apply their own AML checks before funds reach Slots Don.
Second line – Automated monitoring: Algorithms detect suspicious behavior, such as repeated small deposits followed by immediate withdrawals, or use of multiple payment accounts.
Third line – Manual review: Compliance staff perform detailed investigations where risks are identified.

Any transaction that appears atypical or cannot be explained by the customer’s profile is escalated.

Suspicious Activity Reporting

Employees are obliged to report unusual activity to the AMLCO without delay. Reports are assessed using internal procedures, and where justified, a Suspicious Transaction Report (STR) is filed with the relevant FIU.

Examples of reportable behavior:

Large deposits inconsistent with declared occupation.
Use of third-party accounts or credit cards.
Attempts to bypass verification procedures.
Rapid movement of funds without significant gameplay.

Record-Keeping

Slots Don maintains comprehensive records:

KYC documents retained for 10 years after account closure.
Transaction data stored for 10 years after execution.
Logs are encrypted and stored securely both online and offline.

Records are made available to authorities upon lawful request but are never disclosed to third parties for commercial purposes.

Staff Training

Compliance is only effective when staff understand their responsibilities. Training includes:

Mandatory induction training for all new employees.
Regular refresher courses updated with regulatory changes.
Specialized modules for staff handling large-value transactions.
Case study workshops to develop practical skills in detecting suspicious activity.

Auditing and Testing

Internal audit teams review the AML framework annually. Audits check:

Whether procedures are correctly implemented.
Whether monitoring tools are effective.
Whether reporting obligations are being met.

Findings are reported to management with recommendations for improvement.

Data Protection

Protecting the privacy of our customers’ information is our top priority. When it comes to customer information, Slots Don follows both the GDPR and the 95/46/EC Data Protection Directive. To keep information safe, we use encryption, use secure storage, and only allow authorized staff to access it.

No personal information will ever be sold or shared, unless where legally required or in response to efforts to combat money laundering or the support of terrorism.

Enterprise-Wide Risk Assessment (EWRA)

Slots Don conducts an EWRA every year to evaluate risks across its business lines. The assessment considers:

Types of services offered.
Nature of customers and their geographic locations.
Channels used for transactions (cards, e-wallets, bank transfers, crypto).
Regulatory changes and emerging global risks.

Adjustments are made to the AML framework whenever risks increase or new threats are identified.

Ongoing Monitoring and Final Safeguards

We keep an eye on every single transaction. Automated algorithms can see trends, but only humans with proper training can make the ultimate call. The AMLCO may permit enhanced due diligence or block transactions as deemed necessary.

If fraud or laundering is confirmed:

The account is frozen.
Relevant documents are compiled.
Authorities are notified in compliance with the law.

Contact

Questions or complaints about this AML Policy may be directed to:

📧 support@slotsdon.com