Anti Money Laudering (AML) and Counter-Terrorist Financing (CTF) Statement
All casinosocial.us products are operated by Keypads Limited, a limited liability company registered in Cyprus, with registration number HE 473368, and a registered address at Griva Digeni 1, RENADA COMPLEX, BLOCK 1, Flat/Office 11, Agios Tychonas, 4532, Limassol, Cyprus.
1. Business Model and Compliance Approach
casinosocial.us provides online social gameplay and related platform services. As part of operating these services, we implement compliance measures designed to help deter and detect illicit activity on the Platform. These measures may include customer onboarding checks, ongoing monitoring, and transaction-based controls, commensurate with the nature of our services and risk profile.
Given the nature of our services (including optional purchases of virtual gameplay credits and, where offered, prize redemption requests), our controls focus on fraud prevention, platform integrity, sanctions compliance, and risk-based checks proportionate to our business model.
Our controls are intended to be risk-based and aligned with industry practices, taking into account the features we offer and the evolving risk environment.
2. Policy Statement
We expressly prohibit and reject the use of our Platform, products, or services for any form of illicit activity, including money laundering, terrorist financing, or violations of applicable sanctions and trade restrictions.
Our intention is to follow risk-based, industry-aligned practices to help prevent misuse of the Platform. These practices may include:
- Maintaining written policies, procedures, and controls reasonably designed to address AML/CTF and sanctions risks;
- Assigning responsibility for compliance oversight to appropriately designated personnel;
- Providing periodic education and training to relevant personnel, as appropriate to role and risk;
- Reviewing and updating controls as necessary to reflect changes in law, regulation, products, and risk.
3. Definitions
The following terms are commonly used in the AML/CTF context:
- Money laundering: the process of making illegally obtained proceeds appear legitimate, often described as involving placement, layering, and integration.
- Placement: introducing illicit proceeds into the financial system (for example, through purchases, transfers, or other funding activity).
- Layering: separating criminal proceeds from their origin through complex transactions intended to obscure the trail.
- Integration: reintroducing laundered funds into the legitimate economy through apparently lawful transactions.
- Suspicious activity: activity indicating that a person may be engaging in fraudulent, illegal, or prohibited conduct.
- Sanctions: restrictions imposed by governments or international bodies intended to limit or prohibit certain activities, entities, jurisdictions, or transactions.
4. Governance and Oversight
We maintain governance and oversight measures appropriate to our Platform and risk profile. Where appropriate, we designate personnel responsible for coordinating compliance activities, including maintaining the AML/CTF program, monitoring regulatory developments, and supporting reviews of potentially suspicious or unusual activity.
5. Customer Due Diligence (KYC) and Monitoring
We apply risk-based user due diligence and ongoing monitoring measures intended to help prevent illicit or otherwise unauthorized activity. The specific controls applied may vary depending on the customer, the product features used, the payment method, and observed risk indicators.
5.1 KYC / Customer Due Diligence (CDD)
We may collect and verify information to establish a reasonable belief that we know the identity of our customers, commensurate with risk. This may include documentary and non-documentary checks and may involve third-party verification providers.
Depending on circumstances and risk assessment, KYC information may include:
- Full name
- Date of birth
- Country of residence and/or citizenship
- Residential address
- Government-issued identification
- Payment-related identifiers (for example, wallet addresses or account identifiers), where relevant to a purchase or redemption request
We may apply additional controls intended to prevent use of the Platform from jurisdictions where our services are restricted or prohibited, and to help prevent use of the Platform by persons or entities subject to applicable sanctions lists.
5.2 Enhanced Due Diligence (EDD) and Ongoing Monitoring
Where risk indicators or “red flags” are identified, we may apply enhanced due diligence. This may include requesting additional information or documentation and/or restricting account functionality while a review is conducted.
Enhanced due diligence may include, where appropriate:
- Additional identity verification information
- Additional proof of address
- Source of funds and/or source of wealth information
- Further clarification regarding the purpose of account activity or specific transactions
5.3 Acceptance and Refusal Policy
We may refuse service, restrict functionality, suspend, or close accounts where, for example:
- required identification information is not provided;
- information or documents provided appear to be false, misleading, or inconsistent;
- there are indicators of attempts to conceal true location or identity;
- the customer appears to be from a restricted/prohibited jurisdiction (including any Excluded Territories as defined in our Terms of Use, where applicable);
- the customer appears on applicable sanctions lists; or
- there are reasonable grounds to suspect money laundering, terrorist financing, fraud, or other prohibited activity.
5.4 Transaction and Activity Monitoring
We use risk-based monitoring controls intended to identify and review unusual or suspicious activity. Monitoring may include review of patterns relating to purchases, redemption requests (if offered), account behavior, device and network signals, and other relevant indicators.
Monitoring may also include review of promotional and support-request activity (including AMOE requests where available) for indicators of abuse, multi-accounting, or attempted circumvention of eligibility/location restrictions.
Where potentially suspicious activity is identified, we may take steps such as:
- requesting additional information from the customer;
- delaying, restricting, or refusing certain transactions (including purchase processing or redemption processing, where applicable) pending review;
- suspending or closing the account where appropriate; and/or
- reporting the activity to competent authorities where required by applicable law.
6. Education and Training
We may provide AML/CTF and sanctions compliance training to relevant personnel on a periodic basis, as deemed appropriate based on role and risk.
7. Reporting
Where required by applicable law, we may report suspicious or unusual activity to competent authorities. Customers identified as appearing on applicable sanctions lists or linked to suspected illicit activity may be subject to reporting, account restrictions, and other actions consistent with legal requirements and our internal controls.