AML-KYC Policy

Anti-Money Laundering (AML) and Know Your Customer (KYC) Statement


1. Introduction


ALLSTARCASINO, operated by Progress Path Co N.V. (registration no. 164185), is fully committed to ensuring that its platform, services, and operations are never misused for the purposes of money laundering, terrorist financing, or any other form of financial crime.

This public AML/KYC Statement sets out our commitment to compliance with:

• The National Ordinance on the Prevention and Combating of Money Laundering and Terrorist Financing (NOIS),
• The National Ordinance on the Reporting of Unusual Transactions (NORUT),
• Regulatory guidelines from the Financial Intelligence Unit (FIU) Curaçao,
• And international standards, including those of the Financial Action Task Force (FATF).

 


2. AML and KYC Measures


To meet our legal obligations and protect the integrity of our operations, ALLSTARCASINO has implemented a comprehensive AML/CTF framework that includes:

• Customer Identification and Verification (CDD): Identity verification is mandatory before conducting any financial transactions above the threshold of Cg. 4,000. We collect and verify name, date of birth, nationality, residential address, and government-issued ID.
• Enhanced Due Diligence (EDD): Applied to high-risk customers (e.g., PEPs, users from high-risk jurisdictions). This includes assessing source of funds and wealth, and approval by senior compliance staff.
• Sanctions and PEP Screening: We screen all clients during onboarding and daily thereafter against global sanctions lists and PEP databases.
• Ongoing Monitoring: Our system continuously monitors user behavior, transactions, and customer data. Unusual or suspicious activity triggers manual investigation and possible escalation.
• Reporting of Unusual Transactions (UTRs): When suspicion arises, reports are filed with FIU Curaçao promptly and confidentially, in line with NORUT.
• Record Keeping: All relevant data and documents are securely stored for at least five (5) years and made available to authorities upon lawful request.
• Training and Awareness: Staff receive ongoing training in AML/CTF procedures and red-flag indicators.
• Third-party Reliance and Oversight: Only authorized, FATF-compliant third-party service providers may be used for identity or documentation verification, under strict contracts and audit trails.

 


3. Risk-Based Approach


ALLSTARCASINO follows a risk-based approach, continuously evaluating potential exposure to money laundering and terrorist financing. Risk assessments are conducted at:

• The customer level (KYC, PEPs, geographic origin),
• The product and service level (online casino operations),
• And the transaction level (value, frequency, pattern).

Factors increasing risk include:

• Use of third-party payment instruments,
• Players from high-risk jurisdictions or using cryptocurrency (if accepted),
• Clients seeking anonymity or providing unclear source of funds.

Higher-risk users are subject to enhanced scrutiny, monitoring, and controls.

 


4. Client Obligations


By creating an account or using the platform, users agree to:

• Provide complete and truthful KYC documentation,
• Undergo verification at the Casino’s request,
• Disclose the source of funds and, when necessary, source of wealth,
• Re-verify their identity or risk level in the event of suspicious activity or regulatory triggers.

Failure to comply will result in account restrictions, suspension, or termination.

 


5. Termination and Freezing of Accounts


ALLSTARCASINO reserves the right to terminate the business relationship or freeze an account in cases where:

• Verification procedures are not completed,
• False or misleading information is provided,
• The customer is listed on a sanctions list or identified as a PEP without adequate risk mitigation,
• The customer’s behavior suggests potential ML/TF activity.

Frozen accounts may be reported to authorities, and funds may be withheld subject to legal obligations.

 


6. Confidentiality and No-Tipping-Off Rule


In accordance with Curacao law and AML guidelines:

• All suspicious activity reports (UTRs) are filed without notifying the customer.
• Internal reviews, decisions, and communications with FIU are handled confidentially.
• Customers are not informed of any investigation, report, or freeze action related to AML procedures.

 


7. Policy Availability


A condensed version of our AML/CTF Policy is available on this page for transparency and user awareness.

The full AML/CTF Policy of ALLSTARCASINO can be made available upon legitimate request by regulators, partners, or institutional stakeholders. Please contact our Compliance Department.

Email: [email protected]

 


8. Final Notes


ALLSTARCASINO takes its AML/CTF obligations seriously. Our systems, people, and procedures are aligned to detect, deter, and disrupt the misuse of our platform. We are committed to continuous improvement and cooperation with all competent authorities.

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