Anti Money Laudering (AML) and Counter-Terrorist Financing (CTF) Statement

All casinosocial.us products are operated by GB SWEEPS LTD, a limited liability company registered in Cyprus, with registration number HE 490002, and a registered address at Synergatismou, 20 Kato Polemidia, 4159, 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 maintain compliance measures designed to help deter, detect, and prevent illicit activity on the Platform. These measures include customer onboarding checks, ongoing monitoring, and transaction-based controls, applied in line 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, payout, or withdrawal-style redemption requests — our controls focus on fraud prevention, platform integrity, sanctions compliance, and AML/CTF risk controls proportionate to our business model.

Our controls are 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, fraud, abuse, sanctions evasion, or violations of applicable sanctions and trade restrictions.

We maintain risk-based, industry-aligned practices to prevent misuse of the Platform. These practices include:

  • Maintaining written policies, procedures, and controls designed to address AML/CTF, fraud, and sanctions risks;
  • Assigning responsibility for compliance oversight to designated personnel;
  • Providing education and training to relevant personnel, appropriate to role and risk;
  • Reviewing and updating controls to reflect changes in law, regulation, products, and risk;
  • Conducting KYC/CDD, sanctions screening, fraud checks, and AML/CTF review before any prize redemption, payout, or withdrawal-style redemption is approved or processed.

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, including through purchases, transfers, or other funding activity.
  • Layering: separating criminal proceeds from their origin through 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 is engaged in fraudulent, illegal, abusive, or prohibited conduct.
  • Sanctions: restrictions imposed by governments or international bodies intended to limit or prohibit certain activities, entities, jurisdictions, or transactions.
  • Prize redemption / payout: any process through which a customer requests to redeem eligible prize value or receive value from the Platform, including any withdrawal-style redemption process where such terminology is used.

4. Governance and Oversight

We maintain governance and oversight measures appropriate to our Platform and risk profile. Designated personnel coordinate compliance activities, including maintaining the AML/CTF program, monitoring regulatory developments, and supporting reviews of potentially suspicious, unusual, fraudulent, or prohibited activity.

5. Customer Due Diligence (KYC), AML/CTF Controls, and Monitoring

We apply risk-based user due diligence and ongoing monitoring measures to prevent illicit, fraudulent, abusive, or otherwise unauthorized activity. The controls applied depend on the customer, product features used, payment method, redemption activity, account behavior, device and network signals, and observed risk indicators.

Before any prize redemption, payout, or withdrawal-style redemption is approved or processed, we complete all applicable KYC/CDD, sanctions screening, fraud checks, and AML/CTF controls. A redemption, payout, or withdrawal-style redemption does not proceed while required verification or compliance review remains outstanding, incomplete, or unresolved.

5.1 KYC / Customer Due Diligence (CDD)

We collect and verify information to establish a reasonable belief that we know the identity of our customers, commensurate with risk. This includes documentary and non-documentary checks and can involve third-party verification providers.

KYC/CDD is required before a customer receives any prize redemption, payout, or withdrawal-style redemption from the Platform. If the required KYC/CDD process is not successfully completed, the redemption, payout, or withdrawal-style redemption remains pending, is rejected, or is cancelled.

Depending on the circumstances and risk assessment, KYC information includes:

  • Full name
  • Date of birth
  • Country of residence and/or citizenship
  • Residential address
  • Government-issued identification
  • Payment-related identifiers, including wallet addresses or account identifiers, where relevant to a purchase, redemption, payout, or withdrawal-style redemption request

We apply controls to prevent use of the Platform from jurisdictions where our services are restricted or prohibited, and to prevent use of the Platform by persons or entities subject to applicable sanctions lists.

5.2 Pre-Redemption and Pre-Payout Verification

Before approving or processing any prize redemption, payout, or withdrawal-style redemption, we verify the customer’s identity, eligibility, account activity, payment details, location, sanctions status, and any other information required for compliance, fraud prevention, AML/CTF controls, and platform integrity.

A prize redemption, payout, or withdrawal-style redemption is delayed, rejected, or cancelled where:

  • the customer does not provide the requested KYC/CDD information or documentation;
  • the information or documents provided are incomplete, expired, inconsistent, misleading, false, or cannot be verified;
  • enhanced due diligence review is required and has not been completed;
  • there are indicators of fraud, abuse, multi-accounting, prohibited location access, sanctions exposure, money laundering, terrorist financing, or other prohibited activity;
  • the customer is not eligible to receive a redemption, payout, or withdrawal-style redemption under our Terms of Use or applicable law.

No prize redemption, payout, or withdrawal-style redemption is final or completed until all applicable verification and compliance checks have been satisfied.

5.3 Enhanced Due Diligence (EDD) and Ongoing Monitoring

Where risk indicators or red flags are identified, we conduct enhanced due diligence. This includes requesting additional information or documentation and restricting account functionality while the review is conducted.

If EDD is required in connection with a prize redemption, payout, or withdrawal-style redemption request, the request is not approved or processed until the EDD review has been completed to our satisfaction.

Enhanced due diligence includes, where required:

  • 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
  • Additional review of payment method ownership, account history, device signals, network signals, and location indicators

5.4 Acceptance and Refusal Policy

We refuse service, restrict functionality, suspend, or close accounts where:

  • required identification information is not provided;
  • information or documents provided appear to be false, misleading, inconsistent, or unverifiable;
  • there are indicators of attempts to conceal true location, identity, payment ownership, or account control;
  • the customer is from a restricted or prohibited jurisdiction, including any Excluded Territories as defined in our Terms of Use, where applicable;
  • the customer appears on applicable sanctions lists;
  • there are reasonable grounds to suspect money laundering, terrorist financing, fraud, abuse, sanctions evasion, or other prohibited activity.

5.5 Transaction and Activity Monitoring

We use risk-based monitoring controls to identify and review unusual, suspicious, fraudulent, abusive, or prohibited activity. Monitoring includes review of patterns relating to purchases, prize redemption requests, payout requests, withdrawal-style redemption requests, account behavior, device and network signals, location indicators, payment activity, and other relevant risk indicators.

Monitoring also includes review of promotional and support-request activity, including AMOE requests where available, for indicators of abuse, multi-accounting, fraud, or attempted circumvention of eligibility, location, or redemption restrictions.

Where potentially suspicious, fraudulent, abusive, or prohibited activity is identified, we take action, including:

  • requesting additional information from the customer;
  • delaying, restricting, rejecting, or refusing purchase processing, prize redemption processing, payout processing, or withdrawal-style redemption processing pending review;
  • restricting account functionality while the review is conducted;
  • suspending or closing the account where appropriate;
  • reporting the activity to competent authorities where required by applicable law.

6. Education and Training

We provide AML/CTF, fraud prevention, sanctions compliance, and platform integrity training to relevant personnel on a periodic basis, appropriate to role and risk.

7. Reporting

Where required by applicable law, we report suspicious or unusual activity to competent authorities. Customers identified as appearing on applicable sanctions lists or linked to suspected illicit activity are subject to reporting, account restrictions, refusal of redemption or payout processing, suspension, closure, and other actions consistent with legal requirements and our internal controls.