AML & KYC Policy

Our Commitment to Preventing Financial Crime

SpinMoment is 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.

SpinMoment complies with all applicable anti-money laundering, counter-terrorist financing and sanctions legislation, regulations, directives and regulatory requirements applicable to its licence, including the requirements of the Tobique Gaming Commission, applicable financial intelligence authorities and internationally recognised standards, including the Financial Action Task Force (FATF) Recommendations.

The AML and KYC Measures We Apply

To meet our legal obligations and protect the integrity of our operations, SpinMoment has implemented a risk-based AML/CFT and sanctions compliance framework that includes:

• Customer Identification and Verification (CDD). We apply customer due diligence and identity verification measures in accordance with applicable legal and regulatory requirements, and may require verification before or during the business relationship, prior to processing withdrawals, when risk indicators are identified, or whenever otherwise required by law. We collect and verify name, date of birth, nationality, residential address, and government-issued ID. SpinMoment may request additional documentation at any stage of the business relationship.
• Enhanced Due Diligence (EDD). Applied to high-risk customers (e.g., politically exposed persons, 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, daily and/or on an ongoing basis thereafter against global sanctions lists and PEP databases. SpinMoment does not knowingly conduct business with persons or entities subject to applicable sanctions.
• Ongoing Monitoring. Our system continuously monitors user behaviour, transactions, and customer data. Unusual or suspicious activity triggers manual investigation and possible escalation.
• Reporting of Unusual Transactions (UTRs). When suspicion arises, such transactions may be reported where required or permitted by applicable law, promptly and confidentially, to competent regulatory and law enforcement authorities.
• Record Keeping. All relevant data and documents are securely stored for at least five (5) years and made available to authorities upon lawful request.
• Refusal of Transactions. SpinMoment may refuse deposits, withdrawals or other transactions where necessary to comply with legal or regulatory obligations.
• Training and Awareness. Staff receive ongoing training in AML/KYC procedures and red-flag indicators.
• Third-party Reliance and Oversight. Appropriately qualified and compliant (including but not limited to FATF-compliant) third-party service providers may be used for identity or documentation verification, under strict contracts and audit trails.

Our Risk-Based Approach to AML and CFT

SpinMoment 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).
• The transaction level (value, frequency, pattern).

Factors increasing risk include the use of third-party payment instruments; players from high-risk jurisdictions or using cryptocurrency (where supported by SpinMoment); and clients seeking anonymity or providing an unclear source of funds. Higher-risk users are subject to enhanced scrutiny, monitoring, and controls.

Your Obligations as a SpinMoment Player

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

• Provide complete and truthful KYC documentation.
• Undergo verification — provide any information or documentation reasonably requested by SpinMoment to comply with its legal and regulatory obligations — at the Casino's request.
• Disclose the source of funds and, when necessary, the 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.

Termination and Freezing of Accounts

SpinMoment 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 where SpinMoment determines that the risks associated with a politically exposed person (PEP) cannot be appropriately managed.
• The customer's behaviour suggests potential money laundering or terrorist financing activity.

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

Confidentiality and the No-Tipping-Off Rule

In accordance with Tobique law and AML guidelines, all suspicious activity reports (UTRs) are filed without notifying the customer, and internal reviews, decisions, and communications with competent regulatory and law enforcement authorities are handled confidentially.

Customers are not informed of any investigation, report, or freeze action related to AML procedures.

Requesting the Full AML/KYC Policy

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

The full AML/KYC Policy of SpinMoment can be made available upon legitimate request by regulators, partners, or institutional stakeholders. Please contact our Compliance Department at legal@spinmoment.com.

Cooperation With Regulators and Authorities

SpinMoment cooperates fully with competent regulatory, law enforcement and financial intelligence authorities, and takes its AML/KYC 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.

If you have a question about verification or the documents we have requested, contact our support team.