Launch a secure, fully-loaded casino or sportsbook. Weeks, not years.

Last update: 23rd of March 2026

1. Introduction

1.1. Spinstudio Management Ltd (the “Company”, “we”, “us”, or “our”), operating under the licensing framework of the Tobique Gaming Commission (Tobique), is operating this website (or associated companies websites) and confirms the following terms of service (the “Terms of Service”).

1.2. By using, visiting and/or accessing any part of this website and or any sub-domain, website or mobile application that we own or operate (the “Website”) and/or registering an account on the Website you agree to be bound by these Terms of Service, Responsible Gaming and any other rules applicable to our betting or gaming products available on the Website.

1.3. Reference to “you”, “your”, “Customer”, “User” or “Player” shall mean any person using the Website or any services available thereon and/or any registered customer of the Website.

1.4. You should read the Terms of Service carefully, if you do not agree with them and/or cannot accept them, please do not use, visit or access the Website.

1.5. These Terms of Service may be changed by us from time to time for any reason (including compliance with applicable legislation or requirements of regulators). An up-to-date version of the Terms of Service will always available on the Website. If you continue to use the Website after such changes come into effect you are deemed to have accepted such changes to the Terms.

1.6. Reference to “Games” shall mean Casino and Sportsbook games as may from time to time become available on the Website. Company reserves the right to add and remove Games from the Website at its own discretion.

1.7. The abbreviations used in the Terms of Service should apply to all policies of the Company, if not indicated otherwise.

2. Your Account

2.1. Legal requirements:

2.1.1. Reference to the “Account” shall mean an account registered by you on the Website after accepting and agreeing to these Terms of Service. By registering an Account, you declare that you are over 18 years of age or of a higher minimum legal age as stipulated in the jurisdiction of your residence under the laws applicable to you. It is your sole responsibility to know whether the services available on the Website are legal in the country of your residence. People who are under age of 18 years are not allowed to use the Website and/or any services available on it.

2.1.2. You must not use the Website, if you reside in a country in which access to online gambling to its residents or to any person within such country is prohibited.

2.1.3. Players from the following jurisdictions are not permitted to register or use our services:

• Australia;

• Spain;

• Democratic People's Republic of Korea (DPRK);

• Iran;

• Myanmar;

• Austria

• France and it’s territories

• Germany

• Netherlands and it’s territories

• Union of Comoros

• United Kingdom

• USA and it’s territories

• All other high-risk or sanctioned jurisdictions, and/or any other jurisdictions deemed prohibited by the Company.

2.1.4. We reserve the right to refuse Customers from any other countries over and above the aforementioned jurisdictions at our own discretion.

2.1.5. You may not use a VPN, proxy, or similar services or devices that mask or manipulate the identification of your real location.

2.2. Registration of Account

2.2.1. In order to place bets, play Games and deposit virtual currency you need to register the Account on the Website.

2.2.2. To register the Account, you must provide complete and up-to-date information including a mobile number, e-mail address, username, password and other mandatory information requested on the registration form.

2.2.3. We reserve the right to refuse to accept a registration application from any applicant at our sole discretion and without any obligation to communicate a specific reason.

2.2.4. By registering the Account on the Website, you agree to specify your legal name. We may act to check the accuracy of the information you provide. You’re not allowed to change this data, but there are cases in which you can individually request for changing of data by contacting Website customer support, such as an honest mistake etc.

2.2.5. If you choose, or you are provided with a username, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We are not responsible for any abuse or misuse of your Account by third parties due to your disclosure, whether intentional or accidental, whether active or passive, of your login details to any third party. We will never ask you to reveal your password and will never initiate contact with you to ask you for the memory joggers associated with your password.

2.3. Account issues

2.3.1. If Customer forget password or think that somebody knows details of personal data, moreover if suspect that another User is taking an unfair advantage through cheating or collusion you must report the suspicion to us.

2.3.2. We reserve the right to declare any bet or transaction void partially or in full if we, at our own discretion, would deem it obvious that any of the following circumstances have occurred:

1) the Account holder or people associated with the Account holder may directly or indirectly influence the outcome of an event;

2) the Account holder and or people associated with the Account holder are directly or indirectly avoiding the rules of the Website;

3) the result of an event or the bet has been directly or indirectly affected by criminal activity;

4) the odds of an event have significantly been changed due to a public announcement in relation to the event;

5) bets have been placed that would not have been accepted otherwise, but they were accepted during periods when the Website have been affected by technical problems;

6) due to an error, such as a mistake, misprint, technical error, human error, force majeure or otherwise, bets have been offered, placed and or accepted due to this error.

2.3.3. When we close or suspend an Account for whatever reason, we reserve the right to close any future Accounts that may be registered by the same person, device, address, or that may use the same payment wallets or credit cards and void/cancel all bets and transactions of that Accounts.

2.4. By registering the Account on the Website, you undertake, declare and warrant that:

2.4.1. You are over 18 years of age or such higher minimum legal age of majority as stipulated in the laws of jurisdiction applicable to you and, under the laws applicable to you, you are allowed to participate in the Games offered on the Website.

2.4.2. You will use this Website and your Account solely and exclusively for the purpose of your genuine participation in the Games and not for any financial or other operations; your participation in the Games will be strictly in your personal non-professional capacity for recreational and entertainment reasons only.

2.4.3. You participate in the Games on your own behalf and not on behalf of any other person;

2.4.4. You are not a resident of the countries indicated in 2.1.3.

2.4.5. All information that you provide to Company is true, complete, and correct, and that you shall immediately notify us of any change of such information.

2.4.6. You are solely responsible for reporting and accounting for any taxes applicable to you under relevant laws for any winnings that you receive from Company.

2.4.7. All virtual currency that you deposit into your Account is not tainted with any illegality and, in particular, does not originate from any illegal activity or source.

2.4.8. You understand that by participating in the Games you take the risk of losing funds deposited into your Account.

2.4.9. You shall not be involved in any fraudulent, collusive, fixing or other unlawful activity in relation to your or third parties’ participation in any of the Games and shall not use any software-assisted methods or techniques or hardware devices for your participation in any of the Games. Company hereby reserves the right to invalidate or close your Account or invalidate your participation in a Game in the event of such behavior.

2.4.10. In relation to deposits and withdrawals of virtual currency into and from your Account, you shall use your virtual currency wallet or FIAT.

2.4.11. The computer software that we make available to you is owned by Company or other third parties and protected by copyright and other intellectual property laws. You may only use the software for your own personal, recreational uses in accordance with all rules, terms and conditions hereby established and in accordance with all applicable laws, rules and regulations.

2.4.12. Games played on the Website should be played in the same manner as games played in any other setting. You shall be courteous to other players and representatives of Company and shall avoid rude or obscene comments, including in chat rooms.

3. Multi Accounts

3.1. Customer can sign up (register) and use only one Account on the Website.

3.2. We may void all the bets that have been placed in the duplicate Accounts, block bonuses and gifts and void withdrawal requests. In addition, any returns, winnings, or bonuses have been gained or accrued during the duplicate account lifecycle will be forfeited from the Customer.

4. Processors

4.1. We reserve the right to use third party electronic payment processors to process payments made by you.

4.2. All transactions made on our site might be checked to prevent money laundering or terrorism financing activity. Suspicious transactions will be reported to the relevant authority.

5. Payments and Accepted Currencies

5.1. This website accepts deposits and withdrawals in both fiat and cryptocurrencies, including popular options such as Visa, Mastercard, Skrill, Neteller, Bitcoin (BTC), Ethereum (ETH), Tether (USDT), and other leading digital assets. All payments are processed through regulated financial institutions or licensed payment processors, and every transaction is subject to strict AML/KYC checks in accordance with applicable laws.

5.2. Users are responsible for ensuring that deposits are made from lawful sources. The Company does not offer credit under any circumstances. It is strictly prohibited to use third-party payment methods; all deposits must originate from an account or wallet registered in the Customer’s own name.

5.3. Withdrawals may be subject to additional identity verification procedures, transaction reviews or reasonable withdrawal limits to ensure compliance with regulatory obligations. The Company reserves the right to request further documentation at its discretion to complete these checks.

6. Payouts

6.1. Once the outcome of a Game or event is determined and settled, winnings will be credited to the Customer’s account balance. In the event of an error leading to the incorrect crediting of funds, the amount remains the property of the Company and must be returned. If such funds have already been withdrawn, the Customer agrees this amount constitutes a debt payable to the Company.

6.2. The Company retains the right to carry out additional verification procedures before processing withdrawals and reserves the right to refuse or delay withdrawals if there are concerns related to fraud, AML, or other compliance issues.

7. Deposits

7.1. To place bets or participate in games, you must deposit FIAT or cryptocurrencies into your Account. All deposits are processed in the currency selected on the platform. If required, payments will be converted at prevailing exchange rates.

7.2. The Company reserves the right to use additional procedures and means to verify your identity (KYC) when effecting deposits into an Account and to close an Account if you fail to send these documents to the chat widget on the website.

7.3. By depositing you confirm that all deposits are authorized and you won’t try to decline them or take any action which will cause such payment to be reversed by the third party, in order to avoid any legitimate liability.

7.4. Withdrawals are subject to AML compliance checks, including reasonable wagering activity where applicable, to ensure transactions originate from lawful gaming participation.

7.5. The Company does not grant any credit and does not permit deposits made by third parties. All payments must originate from accounts or wallets registered in the Customer’s own name.

8. Account Closure

8.1. You may close your Account at any time and request a withdrawal of the balance of the Account, subject to the deduction of relevant withdrawal charges. The effective closure of the Account will correspond to the termination of the Company. In case the reason behind the closure of the Account is related to concerns about possible gambling addiction you shall inform the Company’s representatives via the chat widget on the website and request immediate assistance.

8.2. The method of repayment will be at our absolute discretion.

8.3. The Company reserves the right to close your Account and refund the available balance, subject to standard compliance checks.

8.4. The Company reserves the right to refuse a withdrawal claim in case of fraud, in which case an Account will be suspended and the payment not processed.

9. Personal Information

9.1. We will comply with applicable data protection laws in respect of the personal information you supply to us. Your personal information is processed in accordance with our Privacy Policy.

10. System

10.1. The Company utilizes third-party gaming systems that are fully licensed, certified and equipped with Random Number Generator (RNG) guarantees to ensure fair play and compliance with industry standards. These systems have undergone rigorous testing and have received all necessary certifications from relevant regulatory bodies to guarantee their reliability and integrity. Additionally, our system is regularly tested to ensure ongoing compliance with all regulatory requirements, maintaining the highest levels of security, fairness, and transparency. We are committed to providing a safe and trustworthy gaming environment for all Users.

11. Crashed & Aborted Games

11.1. Criminal Activity

In the case when any irregularity (including a suspicion of attempted money-laundering or fraud) has been noticed, the Company reserves the right to close Accounts and/or report about criminal or other suspicious activities provided through one or multi-Accounts to the relevant existing regulatory or law enforcement authorities. All offenders’ Account balances will be blocked, withdrawals will be void, deposits and winnings will be forfeited.

11.2. Collusion and cheating

The Company is eligible to disable users Accounts and forfeit their Account balances (including deposits and winnings) if they will be noticed of gaining, attempting to gain an advantage of trading information of their cards or establishing a collusive agreement with other users to take an unfair advantage. Company provides the rigorous examination of play by both manual and automated ways and investigates all related User complaints. In addition, Company provides proactively and randomly examining gameplays and Accounts.

11.3. Fraudulent activity

Once Company noticed a fraudulent, unlawful, dishonest or improper activity (including using the VPN, proxy or similar service that masks or manipulates the identification of your real location, or making bets, wagers or poker play through a third party or on behalf of a third party) on the Website, we are eligible to block User’s Account with forfeiting of all Account balances without prior notification. In such cases, Company reserves the right to report fraudulent activity to existing regulatory and law enforcement authorities including but not limited to virtual asset service providers, banks, credit card companies and/or any person or entity that has the legal right to such information, and/or taking legal action against such User.

12. Crashed & Aborted Games

12.1. The Company is not liable for any downtime, server disruptions, lagging, or any technical or political disturbance to the gameplay. Refunds may be given solely at the discretion of the Company.

12.2. The Company shall accept no liability for any damages or losses which are deemed or alleged to have arisen out of or in connection with Website or its content, including without limitation, delays or interruptions in operation or transmission, loss or corruption of data, communication or lines failure, any person’s misuse of the Website or its content or any errors or omissions in content.

12.3. In the event of a casino system malfunction, all wagers are void.

12.4. In the event a Game is started but miscarried because of a failure of the system, the Company shall refund the amount wagered in the Game to you by crediting it to your Account or, if an Account no longer exists, by paying it to you in an approved manner; and if you have an accrued credit at the time the Game miscarried, credit to your Account the monetary value of the credit or, if an Account no longer exists, pay it to you in an approved manner.

13. Duties

13.1. The Company reserves the right to assign or otherwise lawfully transfer its rights and obligations under the Terms of Service. You shall not assign or otherwise transfer your rights and obligations under these Terms.

14. Complaints

14.1. If you have a complaint, you can email to the Website customer support at the chat widget on the website. The Company will use best efforts to resolve a reported matter promptly.

14.2. If you have a query about any transaction, you may contact the Company’s support team at the chat widget on the website with details of the query. We will review any queried or disputed transactions. Our judgment is final.

15. Agreement & Admissibility

15.1. These Terms of Service and any document expressly referred to in them and any guidelines or rules posted on the Website constitute the entire agreement and understanding between you and the Company with respect to this Website and save in the case of fraud it supersedes all prior or contemporaneous communications and proposals, whether electronic, oral or written, between you and the Company with respect to this Website.

15.2. A printed version of these Terms of Service and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relate to these Terms of Service to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

15.3. If any provision of these Terms of Service is held to be illegal or unenforceable, such provision shall be severed from these Terms of Service and all other provisions shall remain in force unaffected by such severance.

15.4. In case of inconsistency of textual content between language versions, the English version of the Website shall prevail.

15.5. These Terms of Service are governed by the laws of the jurisdiction in which the Company is incorporated, and the parties agree to the jurisdiction of the competent courts of that jurisdiction and to the rules of arbitration in accordance with applicable law.

1. Introduction

This site is operated by Spinstudio Management Ltd ("Company", "we", "us"), operating under the licensing framework of the Tobique Gaming Commission (Tobique), which operates an online gaming platform ("Platform") offering various games of chance and skill. This Privacy Policy ("Policy") explains how we collect, use, store, and share your personal information when you use our Platform. We are committed to protecting your privacy and ensuring your data is treated with respect.

2. Information We Collect

We collect two types of information from users:

Personal Information

This includes information that identifies you directly or indirectly, such as:

Full legal name

Country of citizenship

Permanent Address

Identification Document

Source of Funds and Source of Wealth

Email Address

IP Address

Geolocation data (for age verification and restricted territories)

Transaction history

Non-Personal Information

This information does not identify you directly, but may include:

Device information (type, operating system, language)

Browsing data (pages visited, time spent, click-throughs)

Game activity data (games played, bets placed, wins/losses)

3. How We Use Your Information

We use your information for several purposes:

Provide and operate the Platform

Verifying your identity

Processing transactions

Fulfilling game requests

Managing your account

Delivering customer support

Personalize your experience

Recommending games

Providing bonus offers

Displaying relevant content

Prevent fraud and illegal activity

Detecting and preventing fraud, money laundering, and other illegal activities

Comply with legal obligations

Disclosing information as required by law or legal processes

Analyze and improve our services

Understanding user behavior

Improving the Platform

Developing new features and services

4. Information Sharing

We may share your information with third-party service providers who help us operate the Platform and perform related services, such as:

Payment processors

Data analytics providers

Customer support providers

Legal and regulatory authorities

We only share your information with trusted partners who have agreed to protect your privacy and comply with applicable data protection laws. We will not share your personal information with marketing or advertising companies without your consent.

5. Data Security

We take the security of your information seriously and implement various security measures to protect it from unauthorized access, disclosure, alteration, or destruction. These measures include:

Secure servers with encryption

Access controls and restrictions

Data breach notification procedures

6. Your Data Rights

You have the right to:

Access, correct, or delete your personal information

Object to the processing of your data

Withdraw your consent at any time

To exercise these rights, please contact us at the chat widget on the site.

7. Cookies and Tracking Technologies

We use cookies and other tracking technologies to collect information about your activity on our Platform. These technologies help us:

Analyze user behavior

Improve the Platform

Personalize your experience

You can manage your cookie preferences through your browser settings.

8. Data Retention

We will retain your personal information for as long as necessary to:

Provide you with the Platform

Fulfill our legal obligations

We may also retain your information for a longer period for statistical purposes or to resolve disputes.

9. Children's Privacy

Our Platform is not intended for children under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us immediately.

10. Changes to this Policy

We may update this Policy from time to time. We will notify you of any changes by posting the updated Policy on our Platform. Please review the Policy regularly for the latest information.

11. Contact Us

If you have any questions about this Policy, please contact us at the chat widget on the site.

This Privacy Policy is effective as of 01.01.2026

1. Introduction

Spinstudio Management Ltd, the owner of this site ("Company", "we", "us"), operating under the licensing framework of the Tobique Gaming Commission (Tobique), is committed to preventing its Platform from being used for money laundering, terrorist financing, breaches of sanctions, fraud, bribery, corruption or any other form of financial crime. We are dedicated to protecting our users, our business partners and the integrity of the gaming industry.

These AML and Financial Crime Policies set out the principles, controls and procedures through which the Company identifies, assesses, mitigates and reports financial crime risk. They consist of two parts:

• Part A – Financial Crime Policies: the Anti-Money Laundering (AML) Policy, the Sanctions Policy, the Anti-Fraud Policy and the Anti-Bribery and Corruption Policy; and

• Part B – Financial Crime Procedures: the operational procedures for Customer Onboarding, Ongoing Monitoring and Transaction Monitoring.

These policies apply to all users of the Platform, to the Company’s directors, employees and contractors, and, where relevant, to B2B Clients, White Label Operators (WLOs), affiliates, payment and other service providers, and any other third party acting for or on behalf of the Company.

2. Governance and Responsibilities

The Director of the Company has overall responsibility for the financial crime framework and for ensuring that adequate resources are allocated to its effective implementation. The Director approves these policies and any material changes to them.

The Compliance / AML Officer acts as the Money Laundering Reporting Officer (MLRO). The MLRO is responsible for the day-to-day oversight of the framework, including customer due diligence standards, sanctions screening, monitoring, investigations, the decision whether to file Suspicious Activity Reports (SARs), liaison with the Tobique Gaming Commission and other competent authorities, and reporting to the Director on the effectiveness of the framework at least annually.

The Compliance team performs onboarding reviews, screening, alert handling and investigations under the supervision of the MLRO. All directors, employees and contractors are responsible for complying with these policies and for promptly reporting any knowledge or suspicion of financial crime to the MLRO.

The Company applies a risk-based approach. A business-wide financial crime risk assessment covering customers, products, payment methods, delivery channels, jurisdictions and business partners is carried out at least annually and whenever a material change occurs, such as the launch of a new product, payment method or market. The results of the risk assessment determine the intensity of the controls described in these policies.

PART A – FINANCIAL CRIME POLICIES

3. Anti-Money Laundering (AML) Policy

3.1 Policy Statement

The Company does not tolerate the use of its Platform for money laundering or terrorist financing. The Company will not knowingly accept, process or pay out funds that derive from criminal activity or that are intended to finance terrorism, and it will not establish or maintain a relationship with any user whose identity cannot be verified to the required standard.

To achieve this, the Company identifies and verifies its users, assesses the money laundering and terrorist financing risk each user presents, monitors activity on an ongoing basis, reports suspicious activity to the competent authorities, keeps appropriate records and trains its personnel. The operational detail of these measures is set out in Part B.

3.2 Customer Risk Rating

Every user is assigned a risk rating of low, medium or high based on factors including country of residence and nationality, PEP status, sanctions or adverse media findings, payment methods used, expected and actual deposit volumes, the consistency of gaming activity with financial activity, and the results of identity and source of funds verification. The risk rating determines the level of due diligence applied, the frequency of periodic reviews and the monitoring parameters assigned to the account.

3.3 Know Your Customer (KYC) Verification Levels

We employ a layered Know Your Customer (KYC) approach to verify the identity and legitimacy of our users. The level of verification required may vary depending on user activity and potential risk factors.

Level 1 (Basic Verification):

• Required for all users.

• Collects basic information such as full name, date of birth, residential address, country, and email address.

Level 2 (Enhanced Verification):

• Required for users exceeding specific deposit or withdrawal thresholds.

• Requires verification of identity through government-issued photo ID and proof of address documentation.

Level 3 (Optional Advanced Verification):

• For users engaging in high-risk activity or upon suspicion of potential money laundering.

• May involve additional verification measures such as source of funds documentation, bank statements, and tax returns.

The triggers for each verification level and the documents accepted are set out in the Customer Onboarding procedure (section 7).

3.4 Red Flag Indicators

The identification of red flags is a critical component of our AML framework. These indicators serve as early warning signs that a user may be attempting to engage in suspicious, high-risk, or illegal behavior. While not conclusive evidence of wrongdoing, the presence of one or more red flags warrants further scrutiny and often triggers enhanced due diligence, temporary transaction holds, or escalation to the Money Laundering Reporting Officer (MLRO).

Red flag indicators may emerge at various stages of the user lifecycle, including onboarding, deposit and withdrawal activity, gameplay behavior, or during periodic reviews. During onboarding, the Company pays close attention to inconsistencies in submitted documents, such as discrepancies between names and addresses across forms of ID, or the provision of altered or digitally manipulated documents. Any attempt to bypass KYC requirements—for example, by submitting documents that are expired, unverifiable, or in a language not officially recognized in the user's jurisdiction—will immediately be flagged and may result in account suspension pending resolution.

During the transactional phase, red flags often manifest in the form of activity inconsistent with a user’s known profile or declared source of income. A customer depositing significant funds shortly after opening an account, without any corresponding gaming activity, will raise concern. Similarly, frequent and structured transactions just below reporting thresholds (e.g., EUR 999 deposits over multiple days) may indicate an attempt to avoid detection and will result in a review of the user’s complete transaction history. Rapid withdrawal of deposited funds, especially when no gaming or minimal play has occurred, may also be indicative of layering activity—a known stage in the money laundering process—and will prompt further investigation.

Geographic behavior is also closely monitored. If a user registers an account with a residential address in one country but consistently transacts from IP addresses located in high-risk or sanctioned jurisdictions, this mismatch will trigger a red flag. Likewise, the use of VPNs or proxy servers to mask geographic origin may be a technique used to circumvent territorial restrictions and will be treated as potentially suspicious behavior. In such cases, the Compliance team may request a signed proof-of-residency declaration, utility bill, or a live verification call, depending on the circumstances.

Where a user demonstrates unexplained affluence—such as depositing large sums inconsistent with their stated employment or without prior high-volume behavior—the Company will request source of funds documentation. This typically involves bank statements showing salary payments, a recent tax declaration, or in some cases, a notarized affidavit if conventional evidence cannot be provided. Users who refuse to provide this documentation will be denied access to further services and may be reported to authorities where legally appropriate.

Additional behavioral indicators include the opening of multiple accounts under similar names, the use of third-party payment instruments (e.g., cards not matching the account holder’s name), and evasive responses to routine compliance queries. Users found attempting to manipulate the onboarding process—such as altering names, using alias email addresses, or providing different personal details in repeat submissions—will be considered high-risk, and their activities may be blocked pending a formal internal investigation.

Our platform integrates monitoring for both single-instance red flags and cumulative behavioral trends. Any red flag event leads to an immediate temporary hold on account transactions while the matter is reviewed by the Compliance team. A structured checklist is used to document the type, frequency, and severity of the observed indicators. In cases where red flags persist or are supported by additional risk factors—such as adverse media, PEP status, or high-risk country links—the file is escalated to the MLRO, and a decision is made on the need to file a Suspicious Activity Report (SAR) in line with applicable regulations.

Ultimately, red flag detection is not about rigid rules, but about context, patterns, and professional judgment. Our approach is designed to be adaptive, leveraging both automation and human oversight, and is continuously updated to reflect evolving money laundering typologies, regulatory expectations, and industry best practices.

Our most common Red Flags include, but are not limited to the following Red Flag Indicators:

• Inconsistencies or manipulation in KYC documents during onboarding.

• Transactions that are unusually large, structured, or inconsistent with user profile.

• Deposits followed by immediate withdrawals without gaming activity.

• Use of VPNs, proxies, or mismatched geographic information.

• Unexplained affluence triggering source of funds requests.

• Multiple accounts or third-party payment methods linked to one user.

• Evasive, incomplete, or misleading responses to compliance queries.

• Cumulative behavior patterns that indicate elevated risk.

• All red flags are documented, assessed by Compliance, and escalated to the MLRO where necessary.

3.5 Suspicious Activity Reporting

The Company maintains a clear, structured, and legally compliant procedure for reporting suspicious activity to the appropriate authorities. Our reporting framework ensures that any behavior potentially linked to money laundering, terrorist financing, fraud, or other financial crimes is promptly identified, documented, escalated, and, where applicable, formally reported in accordance with local and international regulations.

When a transaction, user behavior, or pattern is deemed suspicious—whether through automated detection, staff observation, or customer reporting—it is immediately flagged within our internal case management system. Each suspicious activity alert is reviewed by a designated compliance analyst, who gathers all relevant contextual data including user history, KYC documentation, transaction records, communication logs, and any previous compliance interactions. This data is compiled into a preliminary internal report and passed to the MLRO (Money Laundering Reporting Officer) for further evaluation.

The MLRO acts as the central authority for all reporting decisions and conducts a detailed analysis to determine whether the activity warrants the filing of a Suspicious Activity Report (SAR) or equivalent under the laws of the relevant jurisdiction. If a SAR is deemed appropriate, the MLRO ensures that it contains all necessary supporting information, adheres to format and filing guidelines, and is submitted within the prescribed timeframe to the Financial Intelligence Unit (FIU) or other competent authority.

To maintain confidentiality and avoid tipping off the user, all reporting is conducted discreetly and securely. No indication of internal concerns or investigations is communicated to the user involved or to any third party not legally entitled to the information. Internally, access to SARs and related documentation is strictly limited to compliance personnel and senior management with a clear "need to know."

Beyond formal SAR filings, the MLRO also maintains a log of all internal suspicious activity reviews, including cases where a decision is made not to report externally. These logs are retained for a minimum of five years and are made available to regulatory authorities upon lawful request.

Where appropriate, we also share intelligence or cooperate with law enforcement, regulators, or financial institutions, particularly in cases involving cross-border activity or links to known criminal networks. Such cooperation is always conducted in accordance with applicable data protection and confidentiality laws.

4. Sanctions Policy

4.1 Policy Statement and Scope

The Company complies with all economic and financial sanctions applicable to it and will not provide services to, process transactions for, or otherwise make funds or economic resources available, directly or indirectly, to any person, entity or jurisdiction subject to sanctions. This policy applies to users, B2B Clients, WLOs, business partners, suppliers and payment counterparties.

4.2 Applicable Sanctions Regimes

The Company screens against, and operates in accordance with, the following sanctions regimes as a minimum:

• United Nations Security Council consolidated sanctions list;

• European Union consolidated list of persons, groups and entities subject to financial sanctions;

• United Kingdom consolidated list of financial sanctions targets (HM Treasury / OFSI);

• United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) and other lists;

• Canadian sanctions lists maintained under the Special Economic Measures Act and related legislation; and

• any other sanctions regime that applies to the Company, or that the Company’s banking, payment or technology partners require it to observe.

The Company also takes into account the high-risk and monitored jurisdiction lists published by the Financial Action Task Force (FATF).

4.3 Prohibited Persons and Jurisdictions

The Company will not onboard or maintain a relationship with any person or entity that is a designated sanctions target, or that is owned 50% or more, individually or in aggregate, or otherwise controlled by one or more designated persons. Users resident in, or accessing the Platform from, jurisdictions that are subject to comprehensive sanctions or that appear on the Company’s restricted jurisdictions list are not accepted. The restricted jurisdictions list is maintained by the MLRO and reflected in the Terms of Service, and registration and play from those jurisdictions are blocked through geolocation and IP controls.

4.4 Screening

Sanctions screening is carried out using a recognised screening provider with fuzzy-matching capability:

• at registration and before any account is activated;

• daily, by automatic re-screening of the full customer base against updated lists;

• before any withdrawal is processed;

• when a user changes their name, date of birth, nationality or country of residence; and

• for B2B Clients, WLOs, their beneficial owners and directors, and the Company’s suppliers and payment counterparties, at onboarding and on an ongoing basis.

For cryptocurrency transactions, wallet addresses are screened through blockchain analytics (KYT) tools to identify exposure to sanctioned addresses, entities or jurisdictions.

4.5 Handling of Potential Matches

Where screening produces a potential match, the account is immediately placed on hold and no deposits, gameplay or withdrawals are permitted until the alert has been reviewed by the Compliance team. False positives are discounted with a documented rationale. Where a match is confirmed or cannot be discounted, the matter is escalated to the MLRO, all funds and assets are frozen, no funds are returned to the user, and the MLRO notifies the competent authorities as required by the applicable regime. The user is not informed of the reason for the restriction where doing so would amount to tipping off.

4.6 Evasion and Circumvention

Any attempt to evade sanctions controls, including the use of VPNs, proxies or third-party accounts, the provision of false residency information, or the structuring of transactions to avoid screening, is treated as a serious breach. The account is suspended, the matter is investigated by the Compliance team and, where appropriate, reported to the competent authorities.

5. Anti-Fraud Policy

5.1 Policy Statement and Scope

The Company is committed to preventing, detecting and responding to fraud committed against the Company, its users or its business partners, whether by users, employees, contractors or third parties. Fraud means any intentional act of deception carried out to obtain an unfair or unlawful financial or other advantage.

5.2 Fraud Typologies

The fraud risks most relevant to the Company include:

• Identity fraud: use of stolen, forged or synthetic identities to open accounts;

• Account takeover: unauthorised access to a user’s account through compromised credentials;

• Payment fraud: use of stolen cards, compromised bank accounts or wallets, and fraudulent chargebacks ("friendly fraud");

• Multi-accounting and bonus abuse: opening multiple accounts or acting in concert to exploit promotions;

• Collusion and game manipulation: chip dumping, co-ordinated play, use of bots or automated software, and exploitation of software errors or malfunctions;

• Affiliate fraud: generation of fake or incentivised registrations or traffic; and

• Internal fraud: misappropriation of funds, manipulation of accounts or data, or abuse of system access by personnel.

5.3 Prevention Controls

The Company applies preventive controls proportionate to the risk, including:

• identity verification and liveness checks in accordance with the Customer Onboarding procedure;

• device fingerprinting, IP and geolocation analysis to detect duplicate, linked or masked accounts;

• strong authentication for user accounts and back-office access, including multi-factor authentication for staff;

• acceptance only of payment methods registered in the user’s own name, 3-D Secure authentication for card payments and, where possible, withdrawals to the same method used for deposit;

• velocity limits and rules on deposits, withdrawals, bonus claims and account changes;

• bonus terms and wagering requirements designed to deter abuse; and

• segregation of duties, role-based access, logging of all back-office actions and dual approval of manual balance adjustments and large withdrawals.

5.4 Detection and Investigation

Fraud indicators are detected through the transaction and behavioral monitoring described in Part B, through chargeback and payment provider notifications, and through reports from staff, users and partners. Suspected fraud is investigated by the Compliance team, which may restrict the account during the investigation and request additional information or documents from the user. All investigations, findings and decisions are documented. Where fraud also gives rise to a suspicion of money laundering, the matter is referred to the MLRO for consideration of a SAR.

5.5 Consequences

Where fraud is established, the Company may, in accordance with its Terms of Service, suspend or close the account, void bets and winnings obtained through the fraudulent conduct, recover losses, block linked accounts, devices and payment methods, report the matter to payment providers, law enforcement and the Tobique Gaming Commission, and take legal action. Internal fraud by personnel results in disciplinary action, which may include dismissal, termination of contract and referral to law enforcement.

6. Anti-Bribery and Corruption Policy

6.1 Policy Statement and Scope

The Company has zero tolerance for bribery and corruption in any form. This policy applies to the Company’s directors, employees and contractors, and to agents, affiliates, B2B Clients, WLOs, suppliers and any other person performing services for or on behalf of the Company. The Company conducts its business in line with internationally recognised anti-bribery standards, including the principles reflected in the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and the Canadian Corruption of Foreign Public Officials Act, as well as all anti-corruption laws applicable to it.

6.2 Prohibited Conduct

No person covered by this policy may, directly or indirectly:

• offer, promise, give or authorise any payment, gift or other advantage with the intention of improperly influencing any person, or rewarding them for improper conduct;

• request, agree to receive or accept any such advantage;

• offer or give any advantage to a public official, including officials of the Tobique Gaming Commission or any other regulator or government body, to obtain or retain business, a licence, an approval or any other advantage;

• make facilitation payments, being small unofficial payments to speed up routine government actions; or

• use agents, intermediaries or other third parties to do any of the above.

6.3 Gifts, Hospitality and Entertainment

Gifts, hospitality and entertainment may be given or accepted only where they are reasonable, proportionate, given openly, for a legitimate business purpose and not intended to influence a business decision. Cash or cash equivalents may never be given or accepted. No gifts or hospitality may be offered to or accepted from any person involved in a pending decision affecting the Company, such as a licence application, regulatory review or tender. Any gift, hospitality or entertainment with a value exceeding EUR 100 requires the prior approval of the Compliance / AML Officer and is recorded in the gifts and hospitality register.

6.4 Third Parties

Before engaging a third party that will act for or on behalf of the Company, including agents, affiliates, introducers, payment providers and B2B partners, the Company carries out risk-based due diligence on the third party’s ownership, reputation and business rationale. Contracts include anti-bribery and anti-corruption provisions and termination rights. Red flags, such as requests for unusually high commissions, payments in cash, payments to a third party or to an account in a different jurisdiction, or a lack of transparency about ownership, are escalated to the Compliance / AML Officer before any engagement or payment is made.

6.5 Political and Charitable Contributions

The Company does not make political contributions. Charitable donations and sponsorships may only be made with the prior approval of the Director, must be made to legitimate organisations, must not be linked to any business decision, and are recorded.

6.6 Conflicts of Interest

Directors, employees and contractors must avoid situations in which their personal interests conflict, or appear to conflict, with those of the Company, and must disclose any actual or potential conflict of interest to the Compliance / AML Officer without delay. Disclosed conflicts are recorded and managed, which may include removing the person concerned from the relevant decision.

6.7 Books, Records and Financial Controls

All payments, gifts, hospitality, commissions and other transactions are accurately recorded in the Company’s books and records. No undisclosed or unrecorded accounts or funds may be maintained. Payments are made only against appropriate supporting documentation and in accordance with the Company’s approval limits.

6.8 Reporting Concerns and Non-Retaliation

Any person who is offered or asked for a bribe, or who suspects that bribery or corruption has occurred or may occur, must report it promptly to the Compliance / AML Officer or, where that is not appropriate, directly to the Director. Reports may be made confidentially. The Company will not tolerate retaliation against anyone who raises a concern in good faith.

6.9 Breaches

Breach of this policy will result in disciplinary action, which may include dismissal, and may be reported to the competent authorities. Breach by a third party may lead to immediate termination of the business relationship.

PART B – FINANCIAL CRIME PROCEDURES

The procedures in this Part implement the policies in Part A. They describe how the Company onboards users and business counterparties, how it monitors relationships on an ongoing basis, and how it monitors transactions.

7. Customer Onboarding

7.1 Registration

At registration, the following steps are completed before an account is activated:

1. The user confirms that they are at least 18 years of age, or the higher minimum legal age in their jurisdiction, and accepts the Terms of Service and these policies.

2. Level 1 (Basic Verification) information is collected: full name, date of birth, residential address, country and email address.

3. Geolocation and IP checks confirm that the user is not accessing the Platform from a restricted jurisdiction or through a VPN or proxy.

4. Device fingerprinting and data matching check for duplicate or linked accounts.

5. The user is screened against sanctions, PEP and adverse media lists in accordance with section 4.4.

6. An initial customer risk rating is assigned in accordance with section 3.2.

7.2 Verification Triggers

Level 2 (Enhanced Verification) must be completed before the first withdrawal is processed and, in any event, when cumulative deposits reach EUR 2,000 or when the account is rated medium or high risk. Level 3 (Advanced Verification) is required where the account is rated high risk, where activity is inconsistent with the user’s profile, or where there is any suspicion of money laundering or fraud. Until the required verification is completed, deposits, gameplay or withdrawals may be restricted.

7.3 Identity and Address Verification

Identity is verified through a valid government-issued photo identity document (passport, national identity card or driving licence), supported by an automated document authenticity check and a selfie or liveness check carried out through the Company’s KYC provider. Address is verified through a utility bill, bank statement or official letter issued within the last three months and showing the user’s full name and address. Documents that are expired, illegible, altered or inconsistent with the registration data are rejected, and inconsistencies are treated as red flags under section 3.4.

7.4 Enhanced Due Diligence

Enhanced due diligence (EDD) is applied to high-risk users, including PEPs, their family members and close associates, users connected with high-risk jurisdictions identified by FATF or by the Company’s risk assessment, and users whose deposit levels or activity are significant or unusual. EDD includes:

• obtaining and verifying information and documents on source of funds and, where appropriate, source of wealth (for example payslips, bank statements, tax returns, proof of sale of assets or inheritance);

• approval by the MLRO before a relationship with a PEP is established or continued;

• lower monitoring thresholds and more frequent periodic reviews; and

• any additional measures the MLRO considers necessary in the circumstances.

7.5 Refusal of Onboarding

The Company refuses to open, or closes, an account where the user is under age, resides in or accesses the Platform from a restricted jurisdiction, is a confirmed sanctions match, fails to provide the required verification within the requested timeframe, provides false or manipulated information, or presents a risk that cannot be adequately mitigated. Where an account is closed, any remaining balance is returned to the originating payment method only after the required verification has been completed and only where this is lawful. Funds subject to a sanctions freeze or a pending SAR are dealt with in accordance with the instructions of the competent authorities.

7.6 Onboarding of B2B Clients, WLOs and Business Partners

Before a B2B Client, WLO, affiliate or other business partner is onboarded, the Company carries out Know Your Business (KYB) due diligence, which includes:

• verification of the corporate documents, registered address, directors and authorised signatories;

• identification and verification of all ultimate beneficial owners holding 25% or more, or otherwise exercising control;

• verification of gaming licences and regulatory status, where applicable;

• sanctions, PEP and adverse media screening of the entity, its beneficial owners and its directors;

• an assessment of the business model, target markets, source of funds and the expected volume of activity; and

• a documented risk rating and, for high-risk relationships and all WLOs, approval by the Director and the MLRO.

A WLO and its operating website may only go live after the required approval from the Tobique Gaming Commission has been obtained.

8. Ongoing Monitoring

8.1 Periodic Reviews

Each user relationship is reviewed periodically to confirm that the information held remains accurate and that the risk rating remains appropriate. The review frequency depends on the risk rating:

• High risk: at least every six months;

• Medium risk: at least every twelve months; and

• Low risk: at least every twenty-four months, or earlier where a trigger event occurs.

A periodic review covers the KYC file, the validity of identity documents, screening results, deposit, withdrawal and gaming activity against the expected profile, source of funds information and any previous alerts or investigations.

8.2 Ongoing Screening

The full customer base is re-screened daily against updated sanctions, PEP and adverse media lists. New hits are handled in accordance with section 4.5 and, for PEP and adverse media hits, by a re-assessment of the user’s risk rating.

8.3 Trigger Events

An immediate review of the user relationship is carried out when any of the following occurs:

• a change of name, address, nationality, country of residence or other key personal data;

• the addition or change of a payment method, or the use of a payment method in another person’s name;

• expiry of an identity document;

• a significant win, deposit or withdrawal, or a material change in activity levels;

• a sanctions, PEP or adverse media hit;

• a transaction monitoring alert that is escalated to Level 2 or Level 3 review;

• a chargeback, fraud report or request from a payment provider, regulator or law enforcement authority; or

• indicators of problem gambling, which are also handled under the Responsible Gaming Policy.

8.4 Outcome of Reviews

Following a review, the Compliance team updates the KYC file and the risk rating, and decides whether additional documents are required, whether monitoring parameters should be adjusted, whether account restrictions are needed and whether the matter should be escalated to the MLRO. The outcome and its rationale are recorded. Where a user fails to provide requested information within the specified period, the account is restricted and may be closed.

8.5 Ongoing Monitoring of Business Relationships

B2B Clients, WLOs, affiliates and key service providers are re-screened on an ongoing basis and reviewed at least annually, and immediately upon a change in ownership, management, licensing status or business model, or upon adverse information. The review confirms that licences remain valid, that the relationship remains within the scope of the Company’s authorisations and that the risk rating remains appropriate. Relationships whose risks can no longer be adequately mitigated are restricted, suspended or terminated.

9. Transaction Monitoring

We apply a robust and risk-based transaction monitoring framework to identify, evaluate, and respond to suspicious activities in real time and retrospectively. The purpose of this monitoring is to detect potential money laundering, fraud, or other financial crimes and to ensure that all user activity remains consistent with expected behavior based on the user's profile and source of funds.

9.1 Continuous Monitoring Protocol

All user activity on the platform is subject to ongoing surveillance through both real-time monitoring mechanisms and retrospective audits. Real-time monitoring is implemented to intercept and analyze user behavior as it occurs, focusing on financial transactions, login patterns, account changes, and interaction with payment instruments. This live oversight is crucial for preventing illicit funds from circulating through the platform and for identifying suspicious conduct before it escalates into criminal activity.

In parallel, post-transactional analytics are conducted on a daily and weekly basis. These reviews serve as a secondary layer of control, allowing the Compliance team to detect patterns that may not be apparent in isolated transactions. Retrospective monitoring involves batch analyses, profiling shifts, behavioral anomalies, and comparative trend analysis across user segments. These techniques are grounded in internationally recognised risk-based methodologies and are essential for ensuring sustained AML compliance.

Long story short, all user transactions on the platform are subject to continuous monitoring using a combination of automated systems and manual oversight. This includes:

• Real-time Monitoring: Applied for all deposits, withdrawals, transfers, and in-game transactions to detect red flag behavior as it occurs.

• Post-Transaction Analytics: Conducted daily and weekly to identify patterns, trends, or anomalies that may have been missed in real-time detection.

9.2 Criteria for Monitoring

Transactions are flagged for review based on several predefined risk parameters, including but not limited to:

• Transactions that exceed EUR 1,000 in a single instance or cumulatively within a 24-hour period.

• Frequent deposits or withdrawals inconsistent with declared income or known gaming behavior.

• Use of multiple payment methods or frequent changes to linked bank accounts or wallets.

• Transactions involving high-risk jurisdictions or users flagged in sanction/PEP screening.

• Transactions lacking economic rationale or tied to little or no gaming activity.

Find more criteria in the Red Flag Indicators section (section 3.4).

9.3 Transaction Risk Scoring

Each transaction is assigned a dynamic risk score, updated based on:

• User’s KYC level

• Geographic risk

• Payment method

• Gaming behavior vs. financial activity

• Frequency, volume, and velocity of transactions

If a transaction or series of transactions surpasses a threshold score, it is automatically queued for escalation.

9.4 Review and Escalation Procedure

When a transaction is flagged:

1. Level 1 Review – Automated Alerts: A compliance bot assigns the initial classification (e.g., low, moderate, high-risk).

2. Level 2 Review – Compliance Analyst Evaluation: A human reviewer assesses flagged transactions using enhanced data points, including previous activity history, KYC file, and source of funds (if applicable).

3. Level 3 Review – Escalation to MLRO: If suspicion persists or legal reporting thresholds are met, the case is escalated to the Money Laundering Reporting Officer (MLRO) for decision on whether to file a Suspicious Activity Report (SAR).

All reviews are documented, timestamped, and stored securely for at least 5 years post-termination of the user relationship.

Once a transaction is flagged through our monitoring system, a structured multi-tier review process is initiated. At the first level, an automated risk engine classifies the alert based on pre-configured rule sets and machine learning models, assigning a preliminary risk rating. This allows for prioritization based on severity and urgency. The automation stage is not determinative; it functions solely as a triage mechanism to ensure resource allocation is optimized.

Transactions escalated for manual review are then examined by a compliance analyst. This Level 2 review involves verifying whether the transaction in question aligns with user-submitted documentation, declared source of funds, and behavioral history. Analysts consult the internal KYC file, transaction ledger, IP and device data, and any existing compliance notes before reaching a determination. Where there is unresolved suspicion or where the pattern suggests wider abuse, the case is escalated to Level 3.

At Level 3, the matter is referred to the MLRO for final assessment. The MLRO is legally responsible under AML regulations to determine whether the activity meets the threshold for filing a Suspicious Activity Report (SAR) with the Financial Intelligence Unit. All escalations are logged, timestamped, and stored in accordance with the EU’s recordkeeping obligations under Article 40 of 5AMLD. Internal reporting chains and audit trails are designed to be regulator-accessible upon lawful request.

9.5 Timing of Checks

• Onboarding: Baseline transaction limits and monitoring parameters are assigned based on initial KYC tier.

• Daily: Transactions are reviewed in aggregate and per user to assess deviations from typical patterns.

• Event-Triggered: Enhanced monitoring is initiated immediately upon:

  • KYC level upgrades (e.g., reaching Level 2 or 3).

  • A failed transaction attempt.

  • An adverse media alert or PEP/sanction list hit.

  • Internal or external whistleblower reports.

9.6 Tools and Technology

Our AML program is supported by an integrated suite of compliance technologies designed to detect and mitigate financial crime risk efficiently and lawfully. The Company uses a central transaction monitoring platform that interfaces with its user database, KYC provider systems, and payment processors in real time. This integration allows for holistic user profiling and cross-referencing of financial activity with identity, location, and account metadata.

All transactions are screened against updated sanction and politically exposed person (PEP) lists using globally recognized databases. These checks are applied at onboarding, at regular intervals, and on a per-transaction basis for high-risk accounts. The system also performs behavioral pattern recognition using machine learning algorithms, which are trained to adapt to evolving typologies of money laundering, fraud, and collusion.

Manual overrides—such as risk rating downgrades or SAR deferrals—are strictly controlled and must be justified in writing by a senior compliance officer, then approved by the MLRO. All overrides are automatically logged, cryptographically time-stamped, and included in the next compliance audit. This layered technology stack ensures both regulatory alignment and operational efficiency.

Manual overrides by compliance staff are logged and require dual approval.

9.7 Ongoing Calibration

Transaction monitoring rules are reviewed and adjusted at least quarterly. The calibration considers:

• Changes in regulatory guidance.

• Emerging criminal typologies.

• Internal audit findings or data quality issues.

• Feedback from financial institutions or regulators.

9.8 Cryptocurrency Transactions

Cryptocurrency deposits and withdrawals are processed through the Company’s contracted crypto processor and are subject to blockchain transaction monitoring (KYT). Incoming and outgoing wallet addresses are risk-scored for exposure to sanctioned entities, darknet markets, mixers, scams and other illicit sources. High-risk transactions are held pending review by the Compliance team and handled in accordance with sections 4.5 and 9.4.

10. Training and Awareness

A strong culture of compliance begins with well-informed personnel. The Company has implemented a comprehensive AML training program that ensures all relevant employees possess the knowledge and tools necessary to detect, prevent, and respond to financial crime risks effectively. Training is mandatory for all staff with exposure to user accounts, financial operations, customer support, onboarding, or compliance functions.

Training covers all areas of these policies, including sanctions compliance, fraud prevention and anti-bribery and corruption, in addition to anti-money laundering and terrorist financing.

At the time of hire, all new employees undergo initial AML training as part of their onboarding process. This introductory session covers the fundamentals of money laundering and terrorist financing, the Company’s internal AML policies and procedures, KYC requirements, red flag indicators, and reporting obligations. Particular emphasis is placed on practical scenarios, common typologies, and case studies to promote real-world understanding.

Following onboarding, AML refresher training is delivered on at least an annual basis. This ensures employees remain up to date with regulatory changes, emerging risks, and updates to internal systems or protocols. Additional targeted training is provided whenever significant policy changes are introduced, or when new products, jurisdictions, or risk factors are integrated into the platform.

Staff in high-risk or decision-making roles, such as customer due diligence specialists or the MLRO, receive enhanced and role-specific training. This includes advanced modules on topics such as source of wealth verification, handling of politically exposed persons (PEPs), sanctions compliance, and the legal framework surrounding suspicious transaction reporting.

Training is delivered via a mix of e-learning modules, in-person sessions, compliance bulletins, and scenario-based workshops. Completion is tracked through a learning management system, and non-compliance with training requirements may result in disciplinary measures.

Beyond staff education, the Company is committed to promoting broader awareness of AML issues across its platform. Users are regularly reminded of the importance of honest disclosure, responsible gaming behavior, and the illegality of using the service for laundering purposes. Notices about KYC obligations, acceptable payment practices, and the consequences of suspicious activity are embedded within onboarding flows, FAQs, and Terms of Service.

This dual approach—internal training and external awareness—ensures a vigilant, well-prepared ecosystem that minimizes AML risk while supporting regulatory integrity and user trust.

11. Data Security, Confidentiality and Record Keeping

The Company takes data protection seriously and implements strict technical and organizational measures to ensure the confidentiality, integrity, and availability of all personal and financial information collected during AML and KYC processes. All user data is stored in secure, access-controlled environments, with encryption applied both at rest and in transit. Access to sensitive information is restricted to authorized personnel on a need-to-know basis and monitored through audit logs to prevent misuse or unauthorized access.

We maintain compliance with applicable data protection regulations and retain AML-related records—such as customer identification, transaction data, and internal reports—for a minimum of five years after the end of the business relationship or the completion of an occasional transaction, whichever is later. Information may only be disclosed to external parties where legally required, such as in response to regulatory audits, court orders, or formal requests from law enforcement.

12. Policy Review and Updates

These AML and Financial Crime Policies are reviewed at least annually to ensure it remains aligned with current legal requirements, regulatory expectations, and industry best practices. The review process is led by the Compliance team in coordination with the MLRO and includes assessment of recent case outcomes, risk assessment updates, internal audit findings, and any relevant legislative developments.

Interim updates may be made at any time if material changes occur, such as expansion into new jurisdictions, product modifications, or shifts in the risk landscape. All changes are documented, approved by senior management, and communicated to affected personnel through internal training or policy briefings. The latest version of these policies is always made publicly available on our website for transparency and accountability.

13. Contact Us

If you have any questions or concerns about these AML and Financial Crime Policies, please contact our Compliance Officer at the chat widget on the site.

These AML and Financial Crime Policies are effective as of 06.10.2026.

Providing a fair and responsible gaming environment for our customers is one of the key objectives of Spinstudio Management Ltd, the company operating this website under the licensing framework of the Tobique Gaming Commission (Tobique) (“Company”). We strive to ensure that our players do not suffer from gambling addiction and gamble responsibly with real money. On our part, the Company maintains the highest level of safety and protects customers from the possible risk of gambling addiction.

Unfortunately, gambling as a recreational hobby can be a problem for some players.

We fully support and uphold the internationally accepted policy of responsible gambling and do our best to ensure that our customers can enjoy safe and exciting gaming without losing control.

THE MAIN POINTS ABOUT RESPONSIBLE GAMING ON THIS SITE

The Company has always promoted and promoted a responsible attitude towards betting on sports for real money. We always state that sports betting is not a way to make money, but one of the many ways to have fun. However, despite this, some gamblers have problems with self-control and betting addiction.

The most important thing every bettor should remember is that gambling should not be seen as a stable source of income. Results often depend on luck, and predicting the outcome using any betting strategy does not guarantee a win.

If you forget this, you may lose control of your betting and your budget, which can lead to problems in the well-being of you and your family.

MAINTAINING CONTROL

When spending your free time watching matches and gambling, you should, however, remember to be cautious. You should not indulge in excessive gambling and make rash bets.

In order to prevent this from happening, remember the following points:

• Betting on sports and casino games is a way to have fun and relax, not a way to make money;

• If you lose a bet, do not give in to the excitement and desire to win back, do not bet on emotions;

• Don’t make a deposit if you need the money to live and losing it can lead to bad consequences;

• Always pay attention to how much time and money you have spent on the game;

• Keep track of how often you bet, how much money you deposit and withdraw from The Company.

Most of our players have the proper approach to gambling. They take it seriously and understand that it is an interesting pastime rather than a way to make money.

SIGNS OF GAMBLING ADDICTION

To find out if you have a gambling addiction, answer the following questions for yourself:

• Do you view gambling as a way to make money quickly and easily?

• Do you borrow money to bet on sports and play casino games?

• Do you have an emotional compulsion to win back immediately after losing a bet?

• Do you lose control of your time when you bet and play in the casino?

• Do you feel dissatisfied if you do not have the opportunity to bet and play in the casino?

• Does gambling cause financial hardship for you and your family?

If the answer to the majority of these queries is yes, then you are probably suffering from a genuine gambling addiction. Try to take your mind off it, take a break from gambling and seek help from support services to avoid making the situation getting worse.

TIPS FOR GAMBLING CONTROL

The risk of becoming an addict, follow these basic tips:

• Do not treat betting on sports and casino games as a source of income;

• Don’t borrow money to make bets;

• When you make a deposit, you should understand in advance that you can lose it, so choose the amount rationally;

• Keep track of your gambling income and expenses;

• Gamble for a limited amount of time, which you decide for yourself.

If at any point you realize you have a gambling problem, don’t hesitate to write to the Company support team. We will give you the addresses and contacts of specialist agencies who can help you rehabilitate your gambling addiction. You can also freeze your account at any time via your personal account if you realize you need to take a break.

1. Payment Service Providers

1.1 By using this website, you agree that all deposits and withdrawals are processed through third-party payment processors, cryptocurrency service providers and/or financial institutions (together, "Payment Service Providers").

1.2 You authorize the company operating this website ("Company", "we", "us"), whose identity and licence details are set out in our Terms and Conditions, to instruct Payment Service Providers on your behalf to process deposits to and withdrawals from your account.

1.3 You agree to be bound by the terms and conditions of the applicable Payment Service Providers. In the event of any conflict between their terms and ours, our Terms and Conditions and this Payment Policy prevail.

1.4 For security and anti-money laundering (AML) purposes, we may withhold or delay any financial transaction involving an account that is frozen, closed, self-excluded or under investigation.

2. Account Information

2.1 You must register an account before making any deposit or withdrawal, and provide complete, accurate and up-to-date information. You must inform us of any change to your details without delay.

2.2 Before you deposit or withdraw, we may ask you for additional personal information, such as your full name, residential address, date of birth and phone number.

2.3 We may suspend or close any account suspected of fraud, collusion, abuse, money laundering or any other prohibited activity described in our Terms and Conditions. Such action may include the forfeiture of funds obtained through prohibited activity, the voiding of related winnings, and enhanced due diligence.

3. Deposits

3.1 The payment methods available in your region are displayed on the deposit page of the website.

3.2 Minimum and maximum deposit amounts depend on the payment method and may be updated at our discretion.

3.3 Deposits must be made for the sole purpose of gaming and must come from payment sources and wallets that belong to you. Third-party payments are not accepted.

3.4 When depositing with cryptocurrency, it is your responsibility to follow the payment instructions exactly, including the wallet address, the currency and the blockchain network. We are not liable for funds sent to an incorrect address, in an unsupported currency or over an incorrect network.

4. Withdrawals

4.1 Deposited funds must be wagered before they can be withdrawn, in accordance with the wagering requirements set out in our Terms and Conditions and any applicable bonus terms.

4.2 Withdrawals are subject to minimum amounts and to transaction and daily limits, which may vary by payment method, account level or verification status, and may be changed at our discretion.

4.3 Where applicable, withdrawals are returned to the payment method used to deposit. If this is not possible, they may be paid to another verified payment method in your name.

4.4 Cryptocurrency withdrawals are made at your own risk. You are solely responsible for providing a correct wallet address and selecting the correct network. Blockchain transactions are irreversible, and we cannot recover funds sent to an incorrect address.

4.5 You are solely responsible for declaring and paying any taxes that apply to your winnings. We may report or withhold funds where required by law.

5. Verification and Documentation

5.1 To process a withdrawal, we may ask you for one or more of the following documents:

• Photo identification: passport, national identity card or driving licence (front and back).

• Proof of address: a utility bill, bank statement or official document issued within the last 3 months.

• Proof of payment method ownership: for example a copy of your card showing only the first 6 and last 4 digits, or proof of control of your e-wallet or cryptocurrency wallet.

• Proof of source of funds or source of wealth, where required by our AML obligations.

5.2 Large withdrawals may require enhanced checks and take longer to process.

5.3 If the requested documents are not provided within 30 days, we may cancel the pending withdrawal and return the funds to your account balance.

6. Transfers Between Accounts

6.1 Transferring funds between player accounts is prohibited, except through features expressly provided on the website for that purpose and within their limits.

1. Introduction and Scope

Spinstudio Management Ltd ("Company", "we", "us"), operating under the licensing framework of the Tobique Gaming Commission (Tobique), accepts selected cryptocurrencies as a method of deposit and withdrawal on the websites it operates. This Cryptocurrency Policy sets out the rules and controls that apply to the acceptance, holding, monitoring and payout of cryptocurrencies, and the safeguards in place to protect players and to prevent money laundering, terrorist financing, sanctions breaches and fraud.

This policy applies to all players who deposit, wager or withdraw in cryptocurrency on websites operated under the Company’s licence, including websites of approved White Label Operators (WLOs). B2B Clients operating under their own gaming licences remain responsible for their own cryptocurrency controls but must apply standards at least equivalent to this policy when using the Company’s Platform.

This policy should be read together with the Company’s Terms of Service, AML and Financial Crime Policies, KYC and Privacy Policy and Responsible Gaming Policy. Where this policy is silent, those documents apply.

2. Regulatory Basis

The Tobique Gaming Commission, established under the Tobique Gaming Act 2023, permits licensees to accept cryptocurrencies as a payment method on condition that they apply effective anti-money laundering and know-your-customer controls, monitor transactions, keep player funds segregated from operational funds, and apply the same responsible gaming protections as for fiat payments. This policy implements those conditions.

The Company accepts cryptocurrency only as a means of payment for gaming services. The Company does not operate a cryptocurrency exchange, does not offer custody or wallet services to the public, does not offer cryptocurrency trading, lending or staking, and does not issue its own tokens. Conversion and settlement services are performed by the regulated third-party providers described in section 4.

3. Accepted Cryptocurrencies

The Company accepts Bitcoin (BTC), Ether (ETH), Tether (USDT) and USD Coin (USDC), on the networks displayed on the cashier page, together with any other digital asset that has been approved under this section. The current list of accepted assets and networks is always shown on the website.

A new digital asset or network may only be added after an assessment by the Compliance / AML Officer and the Chief Technology Officer, approved by the Director, covering:

• support by the Company’s contracted crypto processor and blockchain analytics provider;

• the traceability of transactions on the relevant blockchain;

• liquidity, market stability and, for stablecoins, the quality of the issuer and its reserves;

• technical and security risks of the asset and network; and

• an update of the Company’s money laundering risk assessment.

The Company does not accept privacy-enhancing coins or tokens designed to conceal the origin, destination or amount of transactions, and does not accept funds sent through mixers, tumblers or other obfuscation services.

4. Payment Infrastructure and Third-Party Providers

Cryptocurrency transactions are processed by 3-102-941161 S.R.L., a Costa Rican company acting as the Company’s crypto processor, with settlement services provided by Piastra Pay Inc., a Canadian company acting as settlement agent. These providers supply deposit address generation, transaction processing, blockchain transaction monitoring (KYT) and crypto-to-fiat and fiat-to-crypto settlement.

Before engaging, and at least annually thereafter, the Company carries out due diligence on each provider covering its ownership, regulatory status, AML and sanctions controls, information security and financial standing, in accordance with section 8.5 of the AML and Financial Crime Policies. Contracts with providers require them to share transaction and screening data needed for the Company to meet its regulatory obligations and to notify the Company promptly of security incidents.

5. Player Verification

Players using cryptocurrency are subject to the same KYC requirements as all other players, as set out in the AML and Financial Crime Policies. No anonymous or pseudonymous accounts are permitted. In particular:

• Level 1 information is collected and sanctions and PEP screening is performed before the first deposit is accepted;

• Level 2 verification of identity and address must be completed before the first cryptocurrency withdrawal and, in any event, when cumulative deposits reach EUR 2,000 equivalent;

• source of funds and source of wealth evidence is requested in accordance with the enhanced due diligence procedure, including, where relevant, the history of the crypto assets deposited (for example exchange account statements showing purchase or receipt); and

• the Company may at any time require a player to demonstrate ownership or control of a wallet, for example by a signed message, a small verification transaction or a statement from the exchange account from which funds were sent.

Deposits from wallets or exchange accounts belonging to a third party are prohibited.

6. Wallet Screening and Blockchain Monitoring

Every incoming deposit and every outgoing withdrawal address is screened in real time using blockchain analytics (KYT). Each transaction receives a risk score based on its direct and indirect exposure to categories including sanctioned persons and jurisdictions, darknet markets, mixers, ransomware, scams, stolen funds, terrorist financing and unlicensed or high-risk exchanges.

Transactions are handled according to their risk score:

• Low risk: processed automatically;

• Medium risk: credited or paid out only after review by the Compliance team, which may request additional information from the player; and

• High risk or severe exposure: held and not credited or paid out, escalated to the MLRO and, where there is direct or significant exposure to sanctioned persons or addresses, frozen and dealt with in accordance with section 4.5 of the AML and Financial Crime Policies.

Where the Company sends or receives cryptocurrency to or from another virtual asset service provider, it cooperates with the exchange of originator and beneficiary information required under the FATF "Travel Rule" and applicable law. Screening results, risk scores and decisions are recorded in the player’s file.

7. Deposits

1. Each player is assigned a unique deposit address for each supported asset and network. Deposit addresses may not be shared.

2. A deposit is credited only after the number of network confirmations set for the relevant asset has been reached and the KYT screening described in section 6 has been completed.

3. Deposits sent in an unsupported asset, on an unsupported network or to an incorrect address may not be recoverable. The Company will make reasonable efforts to recover such funds but cannot guarantee recovery, and any recovery may be subject to network costs.

4. Deposits below the stated minimum amount may not be credited.

5. The Company does not accept deposits made by smart contracts or through decentralised exchange routing where the originating wallet cannot be identified.

8. Withdrawals

1. Withdrawals are paid only to a wallet owned and controlled by the player, in the same asset and on the same network used for deposit wherever possible ("closed loop").

2. Deposited funds must be wagered at least once before they can be withdrawn. Requests to withdraw unwagered deposits are reviewed as a potential money laundering indicator.

3. New withdrawal addresses are subject to a security check and a 24-hour cooling-off period before first use. Changes to withdrawal addresses are confirmed through the player’s registered email or two-factor authentication.

4. All withdrawals are screened in accordance with section 6. Withdrawals exceeding EUR 2,000 equivalent in a single transaction or within 24 hours are reviewed manually by the Compliance team before release.

5. Network fees are displayed to the player before confirmation. The Company is not responsible for losses caused by a player entering an incorrect withdrawal address.

9. Valuation and Exchange Rates

For each deposit, the value of the cryptocurrency received is recorded in EUR at the exchange rate supplied by the crypto processor at the time the deposit is credited. Players are informed on the cashier page whether their balance is held in the deposited cryptocurrency or in a fiat-equivalent currency. Where conversion takes place, the applicable rate, any conversion fee and the time of conversion are shown to the player before the transaction is confirmed.

All thresholds in this policy and in the AML and Financial Crime Policies, as well as deposit and loss limits under the Responsible Gaming Policy, are applied to the EUR equivalent of cryptocurrency transactions. Players are warned that the value of non-stablecoin cryptocurrencies can fluctuate significantly and that the Company does not compensate for changes in market value.

10. Segregation and Safeguarding of Player Funds

In accordance with Tobique requirements, player funds are kept strictly separate from the Company’s operational funds. Cryptocurrency belonging to players is held in dedicated player wallets that are not used for operating expenses, and fiat settlements of player funds are held in a separate segregated account.

Player liabilities are reconciled against the balances in the player wallets and segregated account at least daily, per asset. Liabilities in a given cryptocurrency are covered by holdings in that same cryptocurrency, or in an equivalent stablecoin or fiat amount where balances are held in a fiat-equivalent currency. Any shortfall is reported immediately to the Director and the Compliance / AML Officer and corrected without delay, and is reported to the Tobique Gaming Commission where required.

11. Wallet Security and Key Management

The Chief Technology Officer is responsible for the security of the Company’s wallets. The Company applies the following controls:

• the majority of player and operational funds are held in cold storage, with hot wallets limited to the amount needed to process expected withdrawals;

• multi-signature or equivalent controls, so that no single person can move funds from Company wallets;

• secure generation, storage and backup of private keys, with access restricted to authorised personnel and logged;

• regular review of wallet access rights, and immediate revocation when a person leaves the Company or changes role; and

• an incident response plan for loss, theft or compromise of keys or wallets, including notification of affected players and the Tobique Gaming Commission where required.

12. Reporting and Record Keeping

Deposits with a value of EUR 10,000 or more, in a single transaction or a series of linked transactions, are reviewed by the Compliance team and reported in accordance with Tobique reporting requirements. Suspicious transactions are reported by the MLRO in accordance with the AML and Financial Crime Policies. The Company provides the Tobique Gaming Commission with player account, transaction and compliance reports in the form and at the frequency it requires.

For every cryptocurrency transaction the Company retains the transaction hash, sending and receiving addresses, asset, network, amount, EUR value, time, KYT risk score and any review decisions. These records are retained for at least five years after the end of the player relationship.

13. Responsible Gaming

All responsible gaming tools, including deposit limits, loss limits, time-outs and self-exclusion, apply equally to cryptocurrency players and are calculated on the EUR equivalent of transactions. The Company does not promote cryptocurrency gambling as a means of investment or of making money, and does not offer bonuses that depend on movements in cryptocurrency prices.

14. Network Events and Errors

In the event of a hard fork, chain split, airdrop or similar network event, the Company may temporarily suspend deposits and withdrawals of the affected asset and is not obliged to support any new asset arising from the event. The Company may also suspend an asset where network congestion, security vulnerabilities, de-pegging of a stablecoin or regulatory developments create unacceptable risk. Players will be informed of any suspension and of the arrangements for withdrawing their balance.

15. Governance and Review

The Director has overall responsibility for this policy. The Compliance / AML Officer (MLRO) is responsible for the AML, sanctions and reporting controls, and the Chief Technology Officer for wallet security and technical integrations. All staff involved in payments, compliance and customer support receive training on this policy as part of the training described in the AML and Financial Crime Policies.

This policy is reviewed at least annually and whenever a new asset, network or provider is introduced, a material incident occurs, or the requirements of the Tobique Gaming Commission change. All changes are approved by the Director and published on the website.

16. Contact Us

If you have any questions about this Cryptocurrency Policy, please contact our Compliance Officer via the chat widget on the site.

This Cryptocurrency Policy is effective as of 06.10.2026.