Version 1.0. In force from 16 September 2026. This policy sets out how Cryptora N.V. (Cryptora) prevents, detects and reports money laundering, terrorist financing, sanctions evasion and related financial crime. It forms part of the General Terms and Conditions. Compliance contact: compliance@cryptora.gg.
1. Statement of policy
1.1 We do not tolerate the use of the Service for money laundering, terrorist financing, fraud, tax evasion, sanctions circumvention or the movement of criminal proceeds. We apply a risk-based approach proportionate to the nature, scale and complexity of our business.
1.2 Senior management is responsible for this policy. A nominated compliance officer is responsible for its implementation, for staff training, for the review of alerts and for making reports to the competent financial intelligence unit and other authorities.
2. Risk assessment
We maintain a written business risk assessment covering Player risk, product risk, geographic risk, delivery-channel risk and payment-method risk, including the specific risks of cryptocurrency funding such as pseudonymity, irreversibility, mixing services, privacy coins, chain-hopping and exposure to darknet or sanctioned addresses. The assessment is reviewed at least annually and after any material change.
3. Customer due diligence
3.1 Standard due diligence. Before or shortly after the establishment of the relationship, and in any event before a withdrawal, we verify the Player's identity, age and residence using documentary and electronic sources, and screen against sanctions, politically exposed person and adverse media lists.
3.2 Trigger-based verification. Verification is required, at the latest, on the occurrence of any of the following: cumulative deposits or withdrawals reaching the applicable regulatory threshold; a withdrawal request; a change of payment method, wallet or registered details; a mismatch between stated and observed location; the appearance of a risk alert; or where verification is otherwise required by law.
3.3 Enhanced due diligence. Applied where risk is higher, including politically exposed persons and their associates; Players connected to higher-risk jurisdictions; unusually rapid escalation of deposits; a pattern inconsistent with the stated profile; third-party funding indicators; or funding from addresses with adverse blockchain exposure. Enhanced measures include source-of-funds and source-of-wealth evidence, senior management approval, and closer ongoing monitoring.
3.4 Documents we may require. Government photographic identification; proof of address dated within three months; a selfie or liveness check; proof of ownership of a wallet, card or bank account; bank, exchange or wallet statements; payslips, tax returns, contracts of sale, dividend or inheritance documentation; and a signed declaration as to the origin of funds. Documents must be complete, legible, unedited and in date.
3.5 Where due diligence cannot be completed, we will not establish or continue the relationship, will not process the transaction, and will consider whether a suspicious activity report is required.
4. Prohibited funding and conduct
4.1 Prohibited without limitation: deposits from a source not owned by the Player; deposits on behalf of a third party; funding from mixers, tumblers, coin-join services, sanctioned addresses or addresses associated with ransomware, darknet markets, theft or scams; use of the Account to transfer value between persons; depositing and withdrawing with minimal or no gambling activity; structuring transactions to avoid thresholds; and providing false, altered or borrowed documents.
4.2 Any of the above is a material breach of the General Terms and Conditions and may result in immediate suspension, the freezing of the Balance, closure of the Account, forfeiture of funds to the extent permitted by law, and reporting to the authorities.
5. Sanctions and restricted persons
5.1 We screen Players and, where feasible, funding sources against applicable sanctions lists at onboarding and on an ongoing basis. We do not knowingly provide services to designated persons or entities, to persons acting on their behalf, or to persons resident in a comprehensively sanctioned territory.
5.2 Where a match is confirmed we will block the Account and the funds and make the disclosures required by law. Funds will not be returned where doing so would breach a sanctions measure.
6. Ongoing monitoring
We monitor transactions and gambling behaviour on an ongoing and, in part, automated basis for patterns inconsistent with the Player's profile, including velocity and value anomalies, low-risk or offsetting play, unusual win and loss patterns, linked-account indicators, device and IP anomalies, and rapid deposit-to-withdrawal cycling. Alerts are reviewed by the compliance function and may result in a request for information, a limit, a hold, or a report.
7. Reporting and tipping off
7.1 Where we know or suspect, or have reasonable grounds to know or suspect, money laundering or terrorist financing, we submit a report to the competent authority. We may be required to suspend the transaction or the Account while a report is pending.
7.2 We are prohibited by law from informing you that a report has been made or is being considered, and our staff will not discuss the subject matter of a report. A refusal to explain the reason for a hold may be the consequence of that prohibition.
8. Record keeping
We retain identification records, due diligence files, transaction records, monitoring alerts, internal reports and correspondence for at least 5 years after the end of the relationship or the date of the transaction, and longer where required by law or requested by an authority.
9. Training, audit and governance
All relevant staff receive AML, CTF, sanctions and fraud training on appointment and at least annually. The policy, its controls and their effectiveness are subject to periodic independent review, and findings are reported to senior management.
10. Cooperation with authorities
We cooperate fully with regulators, financial intelligence units, tax authorities and law enforcement, and will disclose Player data where lawfully required, without notice to the Player where notice is prohibited.
11. Contact
Compliance officer: compliance@cryptora.gg. Postal: Cryptora N.V., Abraham de Veerstraat 9, Willemstad, Curaçao.