1. Commitment to AML Compliance
Coolbet operates under a Curaçao eGaming licence and is committed to full compliance with applicable anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. Our AML program is risk-based and proportionate, designed to detect, prevent, and report suspicious financial activity.
All staff with player-facing or financial responsibilities receive mandatory AML training. This training is conducted at onboarding and refreshed annually. Our AML Compliance Officer oversees the implementation and effectiveness of this policy.
2. Know Your Customer (KYC)
KYC verification is mandatory before: (a) processing withdrawals; (b) transactions exceeding regulatory thresholds; (c) when transaction patterns trigger enhanced due diligence. Players must provide government-issued identity documentation, proof of address, and payment method verification.
Enhanced due diligence (EDD) is applied to: high-value players (cumulative deposits above €10,000/month); politically exposed persons (PEPs); transactions with unusual patterns relative to player history; jurisdictions identified as high-risk by FATF. EDD may require source-of-funds documentation.
3. Transaction Monitoring
All transactions are monitored using automated risk scoring. Alerts are generated for: structured transactions designed to avoid reporting thresholds (structuring); rapid cycling of funds (deposit immediately followed by withdrawal without significant play); transactions from high-risk countries; inconsistency between stated income and transaction volume.
Flagged transactions are reviewed by our AML team within 24 hours. Accounts under investigation may be temporarily restricted pending review. Players will not be informed of the reason for restriction if doing so would constitute tipping off under applicable law.
4. Suspicious Activity Reporting
Coolbet files Suspicious Activity Reports (SARs) with the relevant Financial Intelligence Unit (FIU) when we have reasonable grounds to suspect money laundering or terrorist financing. Filing a SAR does not require certainty of wrongdoing — suspicion is sufficient. We do not disclose to the subject of a SAR that a report has been filed.
5. Record Keeping
KYC documentation, transaction records, and AML monitoring logs are retained for a minimum of 5 years after the end of the business relationship. Records are stored securely with access restricted to authorized personnel. In the event of a regulatory request, records are provided within legally mandated timeframes.
6. Contact
AML compliance inquiries: [email protected]. Players with concerns about potential financial crime may report anonymously through our support channel.