This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy applies to all players who register and transact on winzorria.nl, operated by Winzoria Casino ("Winzoria", "we", "us", "our"). Winzoria holds a Curaçao eGaming licence (OGL/2025/9421/9865) and is committed to operating in full compliance with applicable anti-money laundering legislation, counter-terrorist financing obligations, and responsible gaming standards. All players are required to read, understand, and comply with this Policy as a condition of using our services.

1. Introduction and Purpose

Money laundering is the process by which the proceeds of criminal activity are disguised to make them appear legitimate. Terrorist financing involves the provision of funds for the purpose of financing terrorist activity, organisations, or individuals. Both represent serious threats to the integrity of the financial system and to society at large.

Winzoria maintains a zero-tolerance stance towards money laundering, terrorist financing, and any other financial crime. This Policy sets out the framework by which Winzoria identifies, assesses, monitors, and mitigates those risks across all deposit and withdrawal activity conducted through winzorria.nl. It also describes the obligations placed upon our players and the procedures we follow when verifying identity and the source of funds.

This Policy applies to all registered accounts on winzorria.nl, regardless of the payment method used, the currency in which funds are held, or the tier of the player's VIP membership.

2. Regulatory Framework

Winzoria operates under Curaçao eGaming licence OGL/2025/9421/9865. In addition to the conditions imposed by our licensing authority, we apply the following general principles drawn from internationally recognised AML/CFT standards:

• The Financial Action Task Force (FATF) Recommendations on combating money laundering and terrorist financing.
• The Curaçao National Ordinance on the Reporting of Unusual Transactions (MOT) and related AML legislation applicable to licensed gaming operators.
• The policies and guidance issued by our licensing authority from time to time.
• Internal risk-based procedures developed and maintained by our Compliance team.

Where more stringent national legislation applies to individual players or transactions, Winzoria will apply the higher standard.

3. Know Your Customer (KYC) Policy

3.1 Why KYC Is Required

KYC verification allows Winzoria to confirm that players are who they claim to be, that they are of legal gambling age, that their funds originate from legitimate sources, and that they are not subject to sanctions or other restrictions. Completing KYC is a regulatory obligation, not an optional step. Players who do not successfully complete verification will not be permitted to make withdrawals and may have their accounts suspended pending review.

3.2 When KYC Is Triggered

Winzoria applies a risk-based approach to verification. KYC checks are triggered in the following circumstances as a minimum:

• Before the first withdrawal — no withdrawal will be processed from winzorria.nl until full KYC verification has been completed and approved.
• On registration or shortly after — Winzoria may request identity documentation at any point following account creation, including before any deposit is made, if our systems flag a risk indicator.
• When cumulative deposits or transaction volumes reach internal thresholds — these thresholds are determined by our Compliance team and are subject to change in line with our risk assessment framework.
• When unusual or suspicious activity is detected — including, but not limited to, atypical deposit patterns, large or rapid withdrawals, or behaviour inconsistent with a player's stated profile.
• When a player's account information changes materially — for example, a change of payment method, registered address, or email address.
• At any point our Compliance team deems it necessary — Winzoria reserves the right to request updated documentation at any time.

3.3 Standard KYC Documents Required

Players will be asked to supply the following documentation as part of the standard verification process:

• Proof of Identity (POI) — a valid, government-issued photographic document such as a national identity card, passport, or driving licence. The document must be current (not expired), clearly legible, and show the player's full name, date of birth, and photograph.
• Proof of Address (POA) — a document confirming the player's residential address, dated within the last 90 days. Acceptable documents include a utility bill, bank statement, official government correspondence, or mortgage statement. The document must display the player's full name and address clearly.
• Proof of Payment Method (POPM) — confirmation that the player owns the payment method used to fund their account. For bank cards, this typically means a photograph or scan of the card showing the name and last four digits (with the middle digits obscured). For e-wallets such as Skrill, Neteller, or PayPal, a screenshot of the account dashboard showing the player's name and account identifier may be required. For cryptocurrency wallets, confirmation of wallet ownership may be requested.

3.4 Enhanced Due Diligence Documents

Where a player's transaction activity, profile, or risk score warrants a higher level of scrutiny, Winzoria may request Enhanced Due Diligence (EDD) documentation in addition to the standard set above. EDD documents may include:

• Source of Funds (SOF) — evidence demonstrating the origin of the funds deposited with Winzoria. This may include recent payslips, tax returns, bank statements covering a minimum of three months, a letter from an accountant or solicitor, evidence of a business interest, or documentation of a specific financial event such as an inheritance or asset sale.
• Source of Wealth (SOW) — a broader demonstration of how a player has accumulated their overall net worth, which may be relevant for high-volume players or those depositing significant sums.
• Politically Exposed Person (PEP) declaration — players who are, or are closely associated with, a politically exposed person are subject to automatic EDD and ongoing enhanced monitoring.
• Sanctions screening documentation — in the event that a player's name or details return a potential match against international sanctions lists, additional verification will be required before any account activity is permitted.

3.5 KYC Verification Timescale

Winzoria aims to complete standard KYC verification within 24 hours of receiving all required documents in a satisfactory format. Players will be notified by email to their registered address ([email protected]) upon approval or if further information is required. EDD reviews may take longer depending on the complexity of the case and the documentation provided. Winzoria will endeavour to keep players informed of progress throughout the review period.

3.6 Document Standards

To be accepted, submitted documents must meet the following minimum standards:

• Submitted in colour (black-and-white copies are generally not accepted).
• All four corners of the document must be visible in photographs or scans.
• Text must be fully legible — blurred, cropped, or heavily compressed images will be rejected.
• No digital alterations of any kind. Submission of falsified or altered documents constitutes fraud and will be reported to the relevant authorities.
• Documents must be in date — expired identity documents or proof-of-address documents older than 90 days will not be accepted.

3.7 Consequences of Non-Completion

If a player does not provide the requested documentation within a reasonable timeframe, or if the documents provided cannot be verified, Winzoria reserves the right to:

• Suspend the player's account and freeze all pending withdrawals pending resolution.
• Void bonus balances and any winnings derived from unverified play, in accordance with our Bonus Terms.
• Close the account and return deposited funds net of any applicable deductions where fraud or misrepresentation is not suspected, or to withhold funds and file a report with the relevant authority where fraud or financial crime is suspected.

4. Anti-Money Laundering Procedures

4.1 Risk-Based Approach

Winzoria applies a risk-based approach to AML compliance. This means that the level of scrutiny applied to any given player, account, or transaction is proportionate to the risk it presents. Players and transactions are assigned an internal risk rating, which may be adjusted over time as new information becomes available. Higher-risk players and transactions attract greater monitoring and more stringent verification requirements.

4.2 Deposit Wagering Requirement for AML Purposes

Before processing any withdrawal, Winzoria requires that the player's deposited amount has been wagered at least 3 times (3x). This is a standard AML control measure designed to ensure that funds deposited to winzorria.nl have been genuinely used for gambling activity and are not simply being cycled through the platform. This requirement applies to all players regardless of their VIP tier and is separate from any bonus wagering requirements that may apply.

4.3 Transaction Monitoring

Winzoria operates automated and manual transaction monitoring systems that flag activity meeting predefined risk criteria. Indicators that may trigger a review include, but are not limited to:

• Large or unusually frequent deposits inconsistent with a player's verified profile or prior history.
• Rapid withdrawal requests shortly after deposit, with minimal or no gaming activity in between.
• Deposits across multiple payment methods within a short period, particularly where the methods are not associated with the player's verified identity.
• Use of cryptocurrency in combination with other indicators of structuring or layering behaviour.
• Requests to withdraw to a payment method different from the one used to deposit.
• Patterns consistent with the placement, layering, or integration stages of money laundering.
• Deposits at or just below reporting thresholds in rapid succession (structuring).

Where a flag is raised, our Compliance team will review the account and may place a hold on withdrawals, request additional documentation, or escalate the matter in accordance with our internal reporting procedures.

4.4 Withdrawal Controls and Limits

Winzoria applies the following standard withdrawal limits, which serve both as an operational control and as part of our broader AML framework:

Players at Gold and Platinum VIP tiers may be eligible for enhanced withdrawal limits. Any increase in limits is subject to satisfactory completion of enhanced due diligence and approval by our Compliance team. Elevated limits do not exempt a player from AML monitoring obligations.

4.5 Payment Method Controls

Winzoria accepts a defined range of payment methods for deposits and withdrawals. Third-party payments — where funds are sent to or received from a person other than the verified account holder — are strictly prohibited. All payment accounts used on winzorria.nl must be registered in the name of the Winzoria account holder. Where a discrepancy is identified, the transaction will be declined and the matter referred to our Compliance team.

Withdrawals are made to the same payment method used for the corresponding deposit wherever possible, in line with standard AML practice. Where this is not technically possible (for example, where a prepaid card cannot receive funds), Winzoria will request proof of ownership of the alternative withdrawal method before processing.

4.6 Cryptocurrency Transactions

Winzoria accepts deposits and processes withdrawals in Bitcoin (BTC), Ethereum (ETH), Dogecoin, and USDT. Cryptocurrency transactions are subject to the same KYC and AML requirements as fiat transactions. In addition, Winzoria may use blockchain analytics tools to assess the risk profile of incoming cryptocurrency transactions. Funds originating from addresses associated with illicit activity, darknet markets, mixing services, or sanctioned entities will not be accepted, and the relevant matter will be escalated in accordance with our internal reporting procedures.

Players should note that all cryptocurrency amounts are converted to euro equivalents for the purposes of limit calculations and compliance reporting.

4.7 Sanctions Screening

All player registrations on winzorria.nl are screened against international sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and Her Majesty's Treasury. Screening is conducted at registration and on an ongoing basis. Any player identified as a sanctioned individual, or as closely associated with a sanctioned entity, will have their account frozen immediately and the matter reported to the relevant authorities. No funds will be made available to sanctioned individuals.

4.8 Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds, or has held within the past 12 months, a prominent public function, including heads of state or government, senior politicians, senior government, judicial, or military officials, senior executives of state-owned corporations, and important political party officials. The immediate family members and known close associates of PEPs are also considered to be PEPs for these purposes.

Winzoria applies automatic Enhanced Due Diligence to all PEPs and their associates. This includes, at a minimum, senior management approval for account activation, detailed source-of-funds and source-of-wealth verification, and enhanced ongoing monitoring. PEP status does not automatically disqualify a player from using winzorria.nl; however, accounts will not be permitted to operate until the EDD process has been satisfactorily completed.

5. Suspicious Activity Reporting

5.1 Internal Reporting

All Winzoria staff who identify, or reasonably suspect, that a player or transaction may be connected to money laundering or terrorist financing are required to report their concerns immediately to the designated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for assessing all internal reports and determining whether an external report to the relevant financial intelligence unit or regulatory authority is required.

5.2 External Reporting

Where the MLRO concludes that a suspicion is well-founded, Winzoria will file a Suspicious Activity Report (SAR) or equivalent disclosure with the appropriate authority under the jurisdiction in which we are licensed. Winzoria is legally prohibited from tipping off a player or any associated third party that a SAR has been filed or that an investigation is underway. Accordingly, if your account is placed under review or a withdrawal is delayed, Winzoria may be unable to provide a specific reason for this in certain circumstances.

5.3 Cooperation with Authorities

Winzoria will fully cooperate with any lawful request from a regulatory authority, law enforcement agency, or financial intelligence unit. This includes providing account records, transaction histories, KYC documentation, and any other information required as part of an investigation. Player confidentiality obligations do not apply where disclosure is required by law or by the order of a competent authority.

6. Record Keeping

Winzoria retains all records relating to customer identification, verification, transactions, and correspondence for a minimum of five (5) years from the date of the last transaction or the closure of the account, whichever is later. This includes, but is not limited to:

• Copies of all KYC documents submitted by players.
• Records of all deposits and withdrawals, including amounts, dates, payment methods, and currencies.
• Records of all AML risk assessments conducted in respect of player accounts.
• Internal and external SAR filings and supporting documentation.
• Records of all EDD reviews and outcomes.
• Correspondence between Winzoria and players relating to verification and compliance matters.

All records are stored securely in accordance with applicable data protection legislation. Players who require access to their personal data may submit a subject access request to [email protected]. Winzoria will respond within the timeframe required by applicable law.

7. Responsible Gaming and AML Interaction

Winzoria recognises that problem gambling and money laundering share certain behavioural indicators, and that robust responsible gaming measures complement our AML controls. Players who are identified as exhibiting signs of problem gambling behaviour may be referred to our responsible gaming team in addition to, or separately from, any AML review.

Players can access responsible gaming tools through their account settings on winzorria.nl, including deposit limits, session limits, self-exclusion, and cooling-off periods. These tools are available to all players regardless of their VIP tier and will not be overridden by a player's loyalty status. A verified account (as required for birthday bonuses and certain VIP benefits) must also comply fully with this AML/KYC Policy. Where responsible gaming concerns overlap with AML indicators, the Compliance team and the responsible gaming team will coordinate their response.

8. Staff Training and Internal Controls

Winzoria maintains a programme of regular AML and KYC training for all staff whose roles involve customer-facing activity, payment processing, compliance monitoring, or account management. Training covers the identification of suspicious activity indicators, the correct escalation procedure for internal reports, and the legal obligations that apply under our licensing framework. Training records are maintained and reviewed periodically by the MLRO.

Our internal AML controls are reviewed and updated on a regular basis to reflect changes in applicable legislation, guidance from our licensing authority, and the evolving risk landscape facing online gaming operators. The MLRO is responsible for maintaining the overall integrity of this Policy and for ensuring that it remains fit for purpose.

9. Player Obligations

By registering an account on winzorria.nl and using our services, players agree to the following obligations:

• To provide accurate, complete, and current information at registration and throughout their time as a Winzoria player.
• To respond promptly and fully to any request for KYC or EDD documentation issued by Winzoria.
• To notify Winzoria immediately if any registered information changes, including name, address, or payment method.
• Not to use winzorria.nl to deposit, wager, or withdraw funds derived from criminal activity of any kind.
• Not to make deposits on behalf of another person, or permit another person to use their account.
• Not to use third-party payment methods or accounts to fund or withdraw from their Winzoria account.
• Not to structure transactions in any way designed to evade internal or external reporting thresholds.
• To cooperate with any investigation or review initiated by Winzoria's Compliance team.

Breach of any of these obligations may result in account suspension, forfeiture of funds, and reporting to the appropriate regulatory or law enforcement authority.

10. Updates to This Policy

Winzoria reserves the right to update, amend, or replace this AML/KYC Policy at any time in response to changes in applicable legislation, regulatory guidance, or our internal risk assessment framework. Material changes will be communicated to players via email to their registered address and/or by means of a notice on winzorria.nl. Continued use of our services following the effective date of any amendment constitutes acceptance of the revised Policy. Players who do not accept a revised Policy should close their account and withdraw any remaining balance before the effective date of the change.

11. Contact

If you have any questions about this Policy, require clarification regarding your verification status, or wish to submit documentation for review, please contact our Compliance and Support team through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 via winzorria.nl

This Policy was last reviewed and updated in 2025 and applies to all accounts registered on winzorria.nl under Curaçao eGaming licence OGL/2025/9421/9865.