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Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Customer (KYC/AML) Policy

Effective Date: September 27, 2025
Operator: Carlitta N.V. (Curaçao License No. OGL/2024/1516/0841)
Website: pinco-crypto.casino

1) Introduction

At pinco-crypto.casino, we prioritize transparency, security, and regulatory compliance. Our Know Your Customer (KYC) and Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) framework prevents unlawful activity and protects players and the platform.

We align with:

  • Curaçao Gaming Authority AML/CFT requirements
  • National Ordinance on Reporting Unusual Transactions (NORUT)
  • National Ordinance on Identification (NOIS)
  • Kingdom Sanctions Act and related ordinances
  • FATF 40 Recommendations

2) Policy Objectives

This Policy aims to:

  • Prevent money laundering, terrorist or proliferation financing
  • Verify that customer funds are from legitimate sources
  • Apply a risk-based, tiered verification approach
  • Comply with Curaçao and international laws
  • Safeguard players, systems, and our corporate reputation

3) Definitions

  • KYC: Identity verification via official documentation and screenings
  • CDD: Customer Due Diligence—authenticating customers and assessing risk
  • ML/TF/PF: Money Laundering / Terrorist Financing / Proliferation Financing
  • PEP: Politically Exposed Person
  • FIU: Curaçao Financial Intelligence Unit

4) Applicability

This Policy applies to all registered users, internal teams (compliance, KYC, support), and third-party vendors performing verification or payments on our behalf.

5) Eligibility & Jurisdictions

5.1 Minimum Age
Only persons 18+ (or higher local legal age) may register. Underage accounts are terminated and balances may be forfeited.

5.2 Restricted Jurisdictions
Service is denied to:

  • Sanctioned countries/regions (UN, EU, OFAC)
  • FATF high-risk jurisdictions
  • Areas on Carlitta N.V.’s internal exclusion list

Geo-blocking, VPN/proxy detection, and transaction monitoring are enforced.

6) Registration Requirements

On account creation, customers must provide:

  • Full legal name, date/place of birth, nationality
  • Residential address
  • Email and phone number (with email confirmation)
  • Identification number (where applicable)
  • Chosen currency and a secure password

Additional documents may be requested where necessary.

7) Know Your Customer (KYC)

KYC is required before withdrawals and/or full feature access.

Accepted Identity Documents:

  • Passport, National ID, Driver’s License, Residence Permit

Proof of Address (issued within 6 months):

  • Utility bill, Bank statement, Rental/tenancy agreement

Document standards: clear, in color, unaltered, full edges visible; certified copies or notarized translations may be required. We may also request payment-method ownership, source of funds/wealth, or certified verification packs.

8) Payment Verification

Key rules:

  • Only personal (non-third-party) payment methods are allowed
  • Where possible, withdrawals use the same method as deposits
  • No cash; only traceable channels are accepted
  • Ownership verification can be requested
    Non-compliance may cause restrictions or delays.

9) Customer Due Diligence (CDD)

CDD is risk-based. Enhanced Due Diligence (EDD) applies to higher-risk customers, complex structures, unusual behavior, or large transactions.

10) Politically Exposed Persons (PEPs)

For PEPs, we implement:

  • Enhanced screening and verification
  • Senior management approval
  • Ongoing monitoring throughout the relationship

11) Re-Verification

We may request updated documents at any time. Access to services may be limited until re-verification is completed.

12) Ongoing Monitoring

We continuously assess:

  • Document validity
  • Behavior and risk indicators
  • Alerts for suspicious patterns
    This protects customers and the platform over time.

13) Transaction Oversight

Monitoring systems flag:

  • Unusual/irregular activity
  • Structuring/smurfing attempts
  • Activity inconsistent with the customer profile
    Where required, suspicious matters are escalated to authorities.

14) Sanctions Screening

We screen against:

  • UN Security Council sanctions lists
  • EU and OFAC lists
  • Curaçao regulatory lists
    Matches may lead to suspension or termination.

15) Recordkeeping

We retain relevant records 5–10 years, including:

  • Identification/KYC files
  • Transaction and payment history
  • Risk assessments and CDD/EDD outcomes
  • Communications with regulators
    Records are secured under applicable data protection laws.

16) Policy Review

We update this Policy as needed due to legal/regulatory changes, emerging risks/technologies, or internal audit findings.

17) Consequences of Non-Compliance

Failure to meet KYC/AML obligations may result in:

  • Account suspension/closure
  • Withdrawal limits or holds
  • Reporting to competent authorities
  • Potential legal action

18) Withdrawal Conditions

Withdrawals are processed only after:

  • Successful verification (KYC/CDD/EDD as required)
  • Using, where feasible, the same payment method as the deposit
  • Meeting bonus/wagering and fair-use requirements
  • Ensuring full traceability (no third-party payouts)

19) Player Obligations

Customers must:

  • Provide accurate, current information
  • Use only their own identity and payment instruments
  • Cooperate promptly with verification requests
  • Maintain a single active account
  • Refrain from abusing promotions or payment systems

20) Transparency & Support

We inform users when verification is needed and provide clear guidance through our support team.

21) Data Protection

All personal data is:

  • Encrypted and stored securely
  • Accessible only to authorized personnel
  • Protected by strict administrative and technical controls

22) Regulatory Cooperation

We fully cooperate with the Curaçao FIU and other competent authorities. Where legally required, we may disclose identification data, transaction records, and compliance reports.

23) Compliance Officer

A designated Compliance Officer oversees KYC/AML implementation, coordinates audits and reporting, liaises with FIU, conducts staff training, and manages enterprise risk. The Officer acts independently and reports to senior management.

24) Contact Information

For compliance or verification inquiries:
📧 [email protected]

All communications are treated confidentially and processed in accordance with applicable data protection standards.