AML Policy of Curacao Co N.V.

1. For Cash Deposits and Cash Withdraws. is operated by Luther Communication B.V. having its office at Abraham de Veerstraat 9 Willemstad, Curacao. Company Registration number 166046

Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on for that a three step account verification is done in order to insure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken. also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means. is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of is designed to be compliant with :

EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”

EU : “Regulation 2015/847 on information accompanying transfers of funds”

EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash

2. Definition of Money Laundering

Money Laundering is understood as:

- The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;

- The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

- The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;

- Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

3. Organization of the AML for

In accordance with the AML legislation, has appointed the “highest level” for the prevention of ML: The full management of Luther Communication B.V. are in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general Management:

4. AML Policy Changes and Implementation Requirements

Each major change of AML policy is subject to be approval by the general management of Luther Communication B.V. and the Anti money laundering compliance officer.

5. Three-Step Verification

Step One Verification: Step one verification must be done by every user and customer to withdraw. Regardless of the choice of payment, the amount of payment, the amount of withdraw, the choice of withdraw, and nationality of the user/customer, step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender, and full address.

Step Two Verification: Step two verification must be done by every user who deposits over $2000 or withdraws over $2000. Until step two verification is done, the withdrawal, tip, or deposit will be held. Step two verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must take a picture of his ID with a paperclip containing a six-digit randomly generated number next to it. Only an official ID may be used for ID verification, and the variety of accepted IDs may vary depending on the country. An electronic check will also verify the filled-in data from the step one verification to ensure it matches the information on the ID. If the electronic check fails or is not possible, the user/customer is required to send in a confirmation of his current residence, such as a certificate of registration by the government or a similar document.

Step Three Verification: Step three verification must be done by every user who deposits over $5000, withdraws over $5000, or sends another user over $3000. Until step three verification is done, the withdrawal, tip, or deposit will be held. For step three, a user/customer will be asked for a source of wealth.

6. Customer Identification and Verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

- A copy of your passport, ID card, or driving license, each shown alongside a handwritten note mentioning six randomly generated numbers. Additionally, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name, and the picture, to secure their privacy.

- Please note that all four corners of the ID have to be visible in the same image and all details have to be clearly readable besides the named above. We might ask for all details if necessary.

- An employee may do additional checks if necessary, based on the situation.

7. Proof of Address

Proof of address will be done via two different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manual proof.

A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proves your state of residence.

To expedite the approval process, please ensure the document is sent with a clear resolution where all four corners of the document are visible, and all text is readable.

For example: An electricity bill, water bill, bank statement, or any governmental post addressed to you.

An employee may do additional checks if necessary, based on the situation.

8. Source of Funds

If a player deposits over five thousand euros, there is a process of understanding the source of wealth (SOW).

Examples of SOW are:

- Ownership of business

- Employment

- Inheritance

- Investment

- Family

It is critical that the origin and legitimacy of that wealth are clearly understood. If this is not possible, an employee may ask for additional documents or proof.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and information on the website itself. also asks for a bank wire/credit card to further ensure the identity of the user/customer. It also provides additional information about the financial situation of the user/customer.

9. Basic Document for Step One

The basic document will be accessible via the setting page on Every user has to fill out the following information:

- First name

- Second name

- Nationality

- Gender

- Date of Birth

The document will be saved and created by an AI. An employee may do additional checks if necessary based on the situation.

10. Risk Management

In order to deal with the different risks and different states of wealth in different regions on the earth will categorize every nation in three different regions of risk.

11. Region One: Low Risk

For every nation from Region One, the three-step verification is done as described earlier.

12. Region Two: Medium Risk

For every nation from Region Two, the three-step verification will be done at lower deposit, withdraw, and tip amounts. Step one will be done as usual. Step two will be done after depositing $1000, withdrawing $1000, or tipping another user/customer $500. Step three will be done after depositing $2500, withdrawing $2500, or tipping another user/customer $1000. Also, users from a low-risk region that change cryptocurrency into any other currency will be treated like users/customers from a medium-risk region.

13. Region Three: High Risk

Regions of high risk will be banned. High-risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.

14. Additional Measures

In addition, an AI overseen by the AML compliance officer will look for any unusual behavior and report it immediately to an employee of

According to a risk-based view and general experience, human employees will recheck all checks done before by the AI or other employees and may redo or perform additional checks according to the situation.

Furthermore, a data scientist supported by modern, electronic, analytic systems will look for unusual behavior such as:

- Depositing and withdrawing without longer betting sessions

- Attempts to use a different bank account for deposit and withdrawal

- Nationality changes

- Currency changes

- Behavior and activity changes

- Checks to ensure an account is used by its original owner.

Additionally, a user has to use the same method for withdrawal as he used for deposit, for the amount of the initial deposit, to prevent any money laundering.

15. Enterprise-wide Risk Assessment

As part of its risk-based approach, has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.

TThe identification of AML risk categories is based on understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.

The EWRA is yearly reassessed.

16. Ongoing Transaction Monitoring

AML-Compliance ensures that an 'ongoing transaction monitoring' is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

1) The first Line of Control:

- works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto from taking place without proper execution of KYC procedures onto the potential customer.

2) The second Line of Control:

- makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:

- Requests for the execution of financial transactions on the account;

- Requests in relation to means of payment or services on the account;

Also, the three-step verification with adjusted risk management should provide all necessary information’s about all costumers of at all time.

Also, all transaction must be overseen by employees over watched by the AML compliance officer who is over watched by the general management.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.

These checks will be done by an automated System, while an Employee crosschecks them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).

Any staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.

3) The third Line of Control:

- As a last line of defence against AML will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.

If fraud or Money Laundering is found the authorities will be informed.

17. Reporting of Suspicious Transactions on

In its internal procedures, describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, the AML team:

- Will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017.

- Will decide whether or not it is necessary to terminate the business relations with the customer.

18. Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Intranet site of

19. Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Intranet site of

20. Training human employees will conduct manual controls based on a risk-based approach for which they receive special training.

The training and awareness program is reflected by its usage:

- A mandatory AML training program in accordance with the latest regulatory evolutions, for all employees involved in financial activities.

- Academic AML learning sessions for all new employees.

- These sessions are given by an AML-specialist working in Luther Communication B.V. AML team.

21. Auditing

Internal audit regularly establishes missions and reports about AML activities.

22. Data Security

All data provided by any user/customer will be kept secure and will not be sold or shared with anyone else. Data may only be shared with the AML authority of the affected state if required by law or to prevent money laundering. will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

23. Contact Us

If you have any questions about our AML and KYC Policy, please contact us:

By email: [email protected]

If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us:

By email: [email protected]