AML and KYC Policy

1. Introduction

Duff Spin is committed to the highest standards in the prevention of money laundering, terrorist financing, and other financial crime. This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") sets out the procedures and controls in place to detect, prevent, and report suspicious activity. Tomás Reyes, Head of Compliance and AML, is responsible for overseeing this policy.

This policy applies to all players, accounts, and transactions processed through Duff Spin and is reviewed and updated regularly to reflect changes in applicable law and regulatory guidance. The Curaçao gaming licence under which Duff Spin operates requires compliance with international AML standards. Questions regarding this policy should be directed to [email protected].

2. Know Your Customer (KYC) Requirements

All players are required to complete identity verification before withdrawals are processed and, in some cases, before certain GBP deposit thresholds are reached. KYC is a legal obligation, not an optional step.

2.1 Standard KYC Documents

The following documents are required from all players:

• Proof of Identity: A valid, current government-issued photo ID. Acceptable documents: UK passport, UK driving licence, or national identity card. The document must show your full legal name, date of birth, and photograph. Expired documents are not accepted.
• Proof of Address: An official document showing your full name and current residential address, dated within the last three months. Acceptable documents: UK bank statement, utility bill (electricity, gas, water, landline), or official correspondence from a UK government body. PO Box addresses are not accepted.
• Proof of Payment Method: For card payments, a photograph of the front of the card (card number partially obscured, showing name and expiry). For crypto, a screenshot of the sending wallet showing the wallet address.

2.2 Enhanced Due Diligence

Players who deposit or withdraw above defined GBP thresholds, or who display transaction patterns consistent with money laundering risk factors, will be subject to Enhanced Due Diligence (EDD). EDD may require:

• Source of Funds documentation (payslips, bank statements, tax returns, or equivalent)
• Source of Wealth documentation for high-value players
• Additional identity verification
• Video verification call with the compliance team

Players subject to EDD will be notified by the compliance team at [email protected]. Failure to provide requested documentation within the stated timeframe may result in withdrawal requests being placed on hold and, ultimately, account suspension.

3. Transaction Monitoring

Duff Spin operates automated transaction monitoring systems that flag unusual patterns, including: deposits or withdrawals that deviate significantly from a player's established behaviour, rapid cycling of funds without material gambling activity, use of multiple payment methods, and patterns consistent with structuring (deliberately splitting large transactions to avoid reporting thresholds).

Flagged transactions are reviewed manually by the compliance team. Where suspicious activity is confirmed, Duff Spin is required by law to file a Suspicious Activity Report (SAR) with the relevant authority. We are legally prohibited from informing the subject of a SAR filing ("tipping off").

4. Sanctions Screening

All new player registrations and existing accounts are screened against applicable international sanctions lists, including HM Treasury's UK Sanctions List, the UN Consolidated List, and OFAC's Specially Designated Nationals list. Players who appear on sanctions lists cannot register or maintain an account at Duff Spin. Existing accounts are screened on an ongoing basis.

5. Record Retention

KYC documents, transaction records, and AML investigation notes are retained for a minimum of five years following account closure. This retention period is mandated by law and cannot be reduced on individual request. After the retention period, documents are securely deleted or anonymised. Full details are in the Privacy Policy.

6. Responsible Officer

Tomás Reyes serves as Duff Spin's Head of Compliance and AML. He is responsible for implementing and reviewing this policy, training relevant staff, and acting as the primary point of contact with the Curaçao gaming authority on compliance matters. Contact: [email protected].