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Home › AML / KYC Policy

This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Winzoria Casino, operated at winzorria.com, and the duties of our players in relation to identity verification, source-of-funds assessment, transaction monitoring, and the prevention of financial crime. Winzoria operates under a Curaçao eGaming licence and is committed to maintaining the highest practicable standards of compliance with applicable anti-money laundering and counter-terrorist financing requirements.

1. Introduction and Purpose

Money laundering and the financing of terrorism represent serious criminal offences that cause harm to individuals, communities, and the integrity of the financial system. As a licensed online gaming operator, Winzoria Casino (hereinafter "Winzoria", "we", "us", or "our") recognises that gambling services can be misused as a vehicle for the placement, layering, or integration of illicit funds. This Policy exists to ensure that Winzoria is never knowingly used for such purposes.

The Policy applies to every player who registers an account at winzorria.com, every transaction processed through our cashier, and every member of the Winzoria team involved in account management, payments, or customer support. Compliance with this Policy is not optional — it is a condition of continued use of our platform.

2. Regulatory Framework

Winzoria Casino holds a Curaçao eGaming licence and conducts its operations in accordance with the anti-money laundering framework applicable under that jurisdiction, as well as relevant internationally recognised standards including the recommendations of the Financial Action Task Force (FATF). Our AML and KYC procedures are reviewed periodically and updated whenever regulatory guidance or operational circumstances require it.

All data collected during KYC and AML processes is handled in accordance with our Privacy Policy, which is available separately on winzorria.com. Information disclosed to us for compliance purposes will not be used for any purpose other than legal, regulatory, or security obligations.

3. Appointed Compliance Function

Winzoria has designated a Money Laundering Reporting Officer (MLRO) who holds overall responsibility for the implementation of this Policy, the review of suspicious activity reports, and liaison with relevant regulatory and law-enforcement authorities where required. All internal suspicion reports from staff are directed to the MLRO. The identity of the MLRO is maintained internally in accordance with operational security best practice.

4. Know Your Customer (KYC) Requirements

4.1 Why We Carry Out KYC

KYC verification allows Winzoria to confirm that the person operating an account is who they say they are, that they are of legal gambling age, that they are not subject to sanctions or other restrictions, and that the funds they use for gaming have a legitimate origin. As stated on our main platform page, KYC at Winzoria typically wraps up within 24 hours, and once completed, players are not routinely asked to repeat the process.

4.2 When Verification Is Required

We may request KYC documentation at any of the following points:

  • Upon registration of a new account at winzorria.com
  • Before processing any withdrawal request, regardless of amount
  • When a player's cumulative deposits, withdrawals, or wagering activity reaches internal thresholds that trigger enhanced due diligence
  • When a transaction or pattern of behaviour raises a concern that warrants further investigation
  • At any time we deem it necessary to maintain compliance with our regulatory obligations
  • When a player requests an increase to their account limits
  • Upon a material change in a player's account activity or profile

Winzoria reserves the right to restrict or suspend access to an account — including the ability to deposit, wager, or withdraw — until satisfactory KYC documentation has been received and verified.

4.3 Standard KYC Documents

The following categories of documentation form the basis of our standard verification process:

Verification Category Acceptable Documents
Proof of Identity (POI) Valid passport; national identity card; government-issued driving licence with photograph
Proof of Address (POA) Utility bill (gas, electricity, water, or fixed-line telephone) dated within 3 months; bank or credit card statement dated within 3 months; official government correspondence dated within 3 months
Proof of Payment Method Photograph or screenshot of the front of the card used (showing name, expiry, and first six and last four digits — middle digits may be obscured); e-wallet account confirmation; crypto wallet details where applicable
Proof of Age Confirmed by valid POI document — players must be at least 18 years of age (or the legal gambling age in their jurisdiction, whichever is higher)

All submitted documents must be clear, legible, and unedited. Cropped, blurred, or digitally altered images will not be accepted and may trigger further investigation. Documents submitted in a language other than English may be required to be accompanied by a certified translation.

4.4 Enhanced Due Diligence (EDD)

In addition to standard KYC, Enhanced Due Diligence may be applied in higher-risk scenarios. EDD is a more detailed level of scrutiny applied when standard verification alone is insufficient to give Winzoria adequate confidence in the legitimacy of a player's account activity. Circumstances that may give rise to EDD include but are not limited to:

  • High-volume or high-value transactions, particularly where the activity is disproportionate to the player's apparent profile
  • Rapid or repeated deposits and withdrawals with minimal wagering in between
  • Use of multiple payment methods, particularly where these are inconsistent with one another
  • Players identified as Politically Exposed Persons (PEPs) or close associates thereof
  • Players from jurisdictions identified by FATF as high-risk or non-cooperative
  • Any other factor that, in the reasonable judgement of our compliance team, warrants additional scrutiny

EDD may require the player to provide documentation evidencing their source of funds (for example, payslips, bank statements, tax returns, evidence of a business interest, or documentation relating to an inheritance or asset sale) and/or their source of wealth. Winzoria will communicate clearly with affected players about what is required and will aim to resolve EDD procedures as promptly as possible.

4.5 Politically Exposed Persons (PEPs) and Sanctions Screening

Winzoria screens all registered accounts against recognised PEP and sanctions databases. A Politically Exposed Person is an individual who holds or has held a prominent public function — such as a head of state, senior government official, judicial authority, military commander, senior executive of a state-owned enterprise, or senior official of an international organisation — as well as their immediate family members and known close associates.

The presence of PEP status does not automatically prohibit an individual from holding an account, but it does mean that Enhanced Due Diligence is automatically applied and that the account will be subject to ongoing monitoring at a higher level of scrutiny. Accounts associated with individuals who appear on applicable sanctions lists will be suspended pending further review and, where required, reported to the relevant authorities.

5. Customer Due Diligence (CDD) — Ongoing Monitoring

KYC is not a one-time event. Winzoria maintains a programme of ongoing Customer Due Diligence to ensure that account activity remains consistent with what we know about a player's profile and the stated purpose of their account. Our monitoring systems flag anomalies for human review and, where appropriate, for escalation to the MLRO.

Ongoing CDD activities include:

  • Automated transaction monitoring across all deposit and withdrawal activity
  • Behavioural analysis comparing current activity against a player's established patterns
  • Periodic re-verification of documentation for long-standing accounts where circumstances appear to have materially changed
  • Monitoring of payment method changes, including the introduction of new cards or e-wallets to an account
  • Review of withdrawal requests relative to deposit history and wagering activity

6. Payment Methods and AML Controls

Winzoria accepts a range of deposit and withdrawal methods. All methods accepted on the platform are subject to AML controls, including the requirement that funds must be deposited and withdrawn using the same method wherever technically possible — a practice commonly referred to as the "return-to-source" principle. This principle helps prevent the platform from being used as a mechanism to convert funds between payment instruments.

Payment Method Deposit Limits Withdrawal Limits Notes
Visa / Mastercard €20 – €5,000 €20 – €5,000 Standard card verification applies; card must be registered in the player's name
Skrill €20 – €10,000 €20 – €10,000 Account must be held in the same name as the Winzoria account
Neteller €20 – €10,000 €20 – €10,000 Account must be held in the same name as the Winzoria account
Bitcoin (BTC) €20 – €20,000 €20 – €20,000 Blockchain analysis tools may be applied; wallet ownership verification may be required
Ethereum (ETH) €20 – €20,000 €20 – €20,000 Blockchain analysis tools may be applied; wallet ownership verification may be required
Bank Transfer €50 – €30,000 €50 – €30,000 Bank account must be held in the same name as the Winzoria account; additional source-of-funds documentation may be requested for large transfers
iDEAL €20 – €5,000 N/A Deposit-only method; funds will be returned to the originating bank account on withdrawal where applicable

Winzoria will not process payments to or from third-party accounts under any circumstances. If a payment is received from an account that does not match the verified name on a player's Winzoria account, the funds will be returned and the account may be suspended pending investigation.

6.1 Cryptocurrency Transactions

Winzoria accepts Bitcoin (BTC) and Ethereum (ETH) as deposit and withdrawal methods. We recognise that the pseudonymous nature of blockchain transactions creates specific AML considerations, and accordingly we apply blockchain analytics tools to assess the risk profile of cryptocurrency transactions. Funds originating from sources associated with illicit activity — including but not limited to darknet markets, mixing or tumbling services, or sanctioned addresses — will not be accepted and will be subject to immediate investigation and, where appropriate, regulatory disclosure.

Players using cryptocurrency are required to transact from wallets they personally own and control. Proof of wallet ownership may be requested as part of the KYC or EDD process.

7. Suspicious Transaction Reporting

7.1 What Constitutes Suspicious Activity

Winzoria's monitoring systems and compliance team are trained to identify patterns and behaviours that may indicate money laundering, terrorist financing, or other financial crime. Indicators that may trigger a suspicious activity review include but are not limited to:

  • Deposits that are followed swiftly by withdrawal requests with minimal or token gambling activity in between
  • Multiple deposits in quick succession up to or near the maximum permitted thresholds
  • Repeated pattern of depositing, placing a small number of low-risk bets, and then withdrawing the balance
  • Deposits from multiple different payment instruments in a short timeframe
  • Account activity that appears inconsistent with a player's stated occupation, location, or financial profile
  • A player showing unusual knowledge of or interest in the platform's transaction limits or monitoring thresholds
  • Requests to transfer balances to another player's account
  • Unusual patterns in live betting, such as deliberately losing large sums to another participant in a peer-to-peer game format
  • Simultaneous or linked activity across multiple accounts suggesting coordinated behaviour

7.2 Internal Reporting Process

Any member of Winzoria's team who becomes aware of, or suspects, activity that may constitute money laundering or terrorist financing is required to file an internal Suspicious Activity Report (SAR) with the MLRO without delay. Staff are prohibited from disclosing to the player concerned — or to any third party — that a report has been made or that an investigation is under way. This prohibition is commonly referred to as the "tipping off" restriction and exists to protect the integrity of the investigative process.

7.3 External Reporting

Where the MLRO concludes, following review of an internal SAR, that there are reasonable grounds to suspect money laundering or terrorist financing, a report will be filed with the relevant competent authority as required under applicable law. Winzoria reserves the right to freeze, restrict, or close an account pending the outcome of any investigation, and to withhold funds where required to do so by law or regulatory direction.

8. Record Keeping

Winzoria maintains comprehensive records in support of its AML and KYC obligations. These records are retained securely for a minimum of five years from the date of the relevant transaction or the end of the customer relationship, whichever is later. Records maintained include:

  • Copies of all KYC documentation submitted by players
  • Records of all transactions, including deposits, withdrawals, bonuses, and wagers
  • Internal and external SARs and any related correspondence
  • Records of EDD assessments and their outcomes
  • Staff training records relating to AML and KYC compliance
  • Audit trails of access to compliance-related records and systems

All records are stored in a manner that allows them to be retrieved promptly and completely if required by a regulatory authority or law-enforcement body.

9. Bonus Abuse and Integrity of Promotional Activity

Winzoria operates a welcome package spread across ten deposits, with a combined maximum value of €10,000, as well as a calendar of ongoing promotional offers. Our AML monitoring extends to the use of these bonuses, as promotional structures can occasionally be exploited as part of a money-laundering strategy. Behaviour that may attract scrutiny in this context includes:

  • Claiming multiple bonuses across accounts operated by the same individual or connected individuals
  • Bonus wagering activity that appears designed to fulfil requirements at minimum risk rather than to engage in genuine recreational gambling
  • Rapid withdrawal of bonus-related winnings immediately upon satisfaction of wagering requirements, particularly where the overall gaming behaviour is otherwise atypical

The existence of a bonus or promotional offer does not create any right to withdraw funds where those funds are subject to an ongoing AML or KYC investigation. All bonus terms and conditions remain subject to this Policy.

10. Player Responsibilities

Players using winzorria.com have an active role in supporting Winzoria's compliance obligations. By registering an account and using our services, each player agrees to:

  • Provide accurate, truthful, and complete information at the time of registration and throughout their relationship with Winzoria
  • Promptly submit any documentation requested as part of the KYC or EDD process
  • Notify Winzoria without delay of any material change in their personal circumstances, including name, address, or source of funds
  • Use only payment methods registered in their own name
  • Not allow any third party to use their account, deposit on their behalf, or receive withdrawals on their behalf
  • Not engage in any activity that could constitute, facilitate, or assist money laundering or terrorist financing
  • Not attempt to circumvent Winzoria's AML or KYC controls through any means, including the use of multiple accounts, proxy services, or the deliberate structuring of transactions to remain below monitoring thresholds

Failure to comply with these obligations may result in the restriction or permanent closure of an account and the reporting of relevant information to appropriate authorities.

11. Responsible Gambling and AML — The Intersection

Winzoria is committed to both responsible gambling and financial crime prevention, and we recognise that these two areas of concern can sometimes overlap. A player who is gambling with funds derived from criminal activity may also exhibit signs of problem gambling behaviour, and vice versa. Our compliance and responsible gambling teams work in coordination to ensure that concerns raised in one domain are appropriately considered in the other.

Players who wish to exercise responsible gambling controls — including deposit limits, session limits, cool-off periods, or self-exclusion — are encouraged to contact our support team, which is available 24 hours a day, 7 days a week via live chat and email at winzorria.com. The availability of these tools does not affect the application of our AML and KYC controls, which continue to operate independently of a player's chosen responsible gambling settings.

12. Staff Training

All members of Winzoria's team who are involved in account management, payments processing, customer support, or compliance functions receive training on AML and KYC obligations appropriate to their role. Training covers the recognition of suspicious activity, the internal reporting process, the tipping-off prohibition, and the consequences of non-compliance. Training is provided at induction and refreshed on a regular basis to reflect any changes in regulatory requirements or internal procedures.

13. Risk-Based Approach

Winzoria applies a risk-based approach to AML and KYC, meaning that the level of scrutiny applied to any given account or transaction is proportionate to the assessed risk it presents. Low-risk accounts — those where the player's identity is clear, the transaction volumes are modest, the payment methods are straightforward, and the gambling behaviour is consistent and credible — will not routinely be subject to the same intensity of monitoring as higher-risk accounts. Conversely, where risk factors accumulate, our controls will respond accordingly. This approach allows us to fulfil our obligations without creating unnecessary friction for the vast majority of players who use our platform legitimately.

Our risk assessments take into account factors including but not limited to the player's country of residence, payment methods used, transaction volumes and frequency, gaming behaviour, PEP or sanctions status, and any prior compliance concerns associated with the account.

14. Account Closure and Fund Withholding

Winzoria reserves the right to close, suspend, or restrict any account where:

  • KYC documentation has not been provided within a reasonable timeframe following a verified request
  • Documentation provided is found to be falsified, altered, or otherwise fraudulent
  • The account is associated with suspicious activity that has been escalated to the MLRO
  • A player is found to have provided false information at the time of registration or at any subsequent point
  • A regulatory authority or law-enforcement body has directed us to take action in respect of the account
  • The account is linked to a breach of our Terms and Conditions that has AML or KYC implications

Where funds are withheld pending an investigation or pursuant to a regulatory direction, Winzoria will act in accordance with its legal obligations and will not release those funds until it is legally and operationally safe to do so. We are not liable for any losses a player may claim to have suffered as a result of a legitimate account restriction or suspension carried out in good faith under this Policy.

15. Policy Review and Updates

This Policy is reviewed at least annually, or more frequently where required by changes in the regulatory environment, our licensing conditions, or internal risk assessments. The most current version of this Policy is published on winzorria.com and supersedes all previous versions. Players are responsible for reviewing this Policy periodically. Continued use of winzorria.com following any update to this Policy constitutes acceptance of the revised terms.

16. Contact

If you have any questions about this Policy, wish to understand how it applies to your account, or need to submit documentation in connection with a KYC request, please contact our support team. We are available around the clock via live chat at winzorria.com, and by email through the address listed in the Contact section of the site. Our team will respond to compliance-related enquiries as promptly as operational circumstances permit.

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