AML Policy

V.Vegas operates its platform under a licence from the Curaçao Gaming Control Board and is fully committed to complying with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations. Money laundering — the process of making illegally obtained funds appear legitimate — causes serious harm to individuals, society, and the global financial system. We take our preventive role seriously and have implemented a comprehensive AML programme that meets or exceeds regulatory requirements aligned with FATF standards.

Our AML Policy is reviewed annually and updated in response to changes in legislation, regulatory guidance, and emerging financial crime typologies.

V.Vegas applies a risk-based approach to AML compliance, meaning the level of controls applied to a player or transaction is proportionate to the assessed risk. We classify players into three risk categories:

A risk rating is assigned at account registration and is continuously reviewed based on transaction behaviour, account activity, and newly received information.

Standard Customer Due Diligence (CDD) applies to all players and includes:

• Verification of the player's identity using official, government-issued identity documents
• Confirmation of the player's residential address
• Collection of information on the purpose and nature of the player's gambling activity
• Assessment of the player's expected transaction volumes

CDD is performed at registration and kept up to date on an ongoing basis. Simplified CDD may be applied to low-risk players with low transaction volumes. Enhanced CDD (see Section 04) applies to high-risk customers.

Enhanced Due Diligence (EDD) is applied to players assessed as presenting a higher risk. EDD is mandatory for:

• Politically Exposed Persons (PEPs) and their immediate family members and close associates
• Players from countries designated as high-risk by the FATF
• Players whose transaction volumes are disproportionate to their stated income or wealth
• Players involved in complex or unusual transaction patterns

EDD includes:

• Verification of source of wealth and source of funds
• Additional identity checks, which may include video verification
• Enhanced ongoing monitoring with lower thresholds for suspicious activity reporting
• Senior management approval to continue the business relationship

Failure to complete the EDD process may result in account restrictions and the withholding of funds pending completion of the investigation.

All transactions on the V.Vegas platform are subject to continuous, automated monitoring. The transaction monitoring system is designed to identify patterns and behaviours characteristic of money laundering, terrorist financing, or other financial crime. Key monitoring indicators include:

• Single transactions equal to or above CA$10,000
• Cumulative deposits exceeding CA$25,000 within a 30-day period
• Rapid deposit and withdrawal cycles with minimal gambling activity
• Use of multiple payment methods without clear justification
• Structuring — splitting transactions to avoid reporting thresholds
• Material deviations from the player's established wagering patterns
• Winnings that are disproportionate to deposits

Flagged transactions are reviewed by the compliance team within 24 hours. Accounts may be temporarily restricted pending completion of the investigation.

When the compliance team identifies activity that may constitute money laundering or terrorist financing, the following process is initiated:

• The player's account is immediately restricted pending completion of the investigation
• An internal Suspicious Activity Report (SAR) is prepared
• The report is submitted to the relevant Financial Intelligence Unit (FIU) as required by applicable law
• The case is escalated to senior compliance management

We cooperate fully with law enforcement agencies and regulatory authorities in the investigation of financial crime.

V.Vegas maintains comprehensive documentation of all customer due diligence, transaction data, and compliance activities. Minimum record retention periods are as follows:

All records are stored securely, with access limited to authorised compliance personnel. Documents are made available to regulatory authorities and law enforcement upon reasonable and legally valid request.

All V.Vegas staff who have customer contact or handle financial transactions complete mandatory AML training. The training programme covers:

• Recognising money laundering typologies and red flags
• Customer due diligence obligations
• Internal reporting procedures
• Whistleblower obligations and protections
• Consequences of non-compliance (criminal and civil)

Training is delivered at onboarding for all new staff and updated annually. Additional training is arranged following material changes to AML legislation or regulatory guidance. Completed training is recorded and audited.

V.Vegas is committed to full compliance with all applicable regulatory requirements. The AML programme is aligned with:

• The licensing requirements of the Curaçao Gaming Control Board
• The FATF 40 Recommendations and associated guidance
• FATF mutual evaluation reports and updated guidance notes
• International AML frameworks and best practices applicable to online gaming operators
• The national legislation of all jurisdictions in which we operate

The compliance programme is independently reviewed by an external auditor annually. Findings and recommendations are reviewed by senior management and implemented promptly. We maintain open and transparent communication with regulatory authorities.

For compliance matters, please contact us through the appropriate channel:

The compliance team is available Monday–Friday 9:00 AM–6:00 PM ET. Urgent matters — including law enforcement and regulatory enquiries — are prioritised and handled within 4 hours regardless of time of day.