Anti-Money Laundering Policy

The process for the registration of players is provided for under the Terms and Conditions.

Before any opening of an Account there must be registration by the Players which involves the provision of accurate details to Casino. It is the Player's responsibility to immediately provide Casino with updated information to any information/documentation provided at the initial Account opening stage. Casino has the discretion to verify creditworthiness of a Player with third parties who previously provided any information on the Player.

Upon Registration, Player must fill in all the information requested, and it is Player's responsibility to ensure that the information provided is complete and accurate.

Casino reserves the right to carry out verification procedures. In case Casino suspects that Player provided false information, we are entitled to close and block Player's access to Account.

Player has the responsibility to inform Casino of any updates or changes of his information.

If Casino becomes aware that a person has provided false information, we will immediately cancel that person's registration as a Player with Casino and close his Account.

No person under eighteen years of age (or the applicable majority age in that person's jurisdiction) may be registered as a Player and any funds deposited or any money won by any such persons shall be forfeited to the Regulatory Authority.

Casino shall, at all times, keep a secure online list of all registered Players. Any one individual can only register a single Account with Casino and multi-account practices are strictly prohibited.

ChapinWin shall not open anonymous Accounts or Accounts with fictitious names such that the true beneficial owner is not known or cannot be verified. Proxy betting or betting by bots is not permitted and is in violation of these Terms.

Casino reserves the right to monitor all the transactions with a view to prevent money laundering. Furthermore, Casino reserves the right to examine with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.

A Player requesting the first withdrawal following registration shall be required to verify his identity through the submission of a copy of an identification document. The withdrawal request shall not be acceded to by Casino prior to receipt of a copy of this document from the Player.

In all cases, Casino reserves the right to suspend a cash-out request pending verification of Player's identity, age and location.

Payments of winnings or refunds shall be transferred back through the same channel from which Player had made the original transfer in the first place. Where this is not possible, the Player shall be requested to provide an alternative channel together with sufficient proof that such channel relates back to the Player. It shall be within the Casino's sole discretion to determine whether proof provided by the Player is sufficient or not. Casino may, in its sole discretion and in accordance to the licencing compliance rules and an internal risk assessment, require a first payment of winnings for the Player being released as the bank transfer wire with a purpose of completing the KYC verification checks.

All withdrawals from Players must be thoroughly checked as per our payout management procedures before being processed. When it becomes evident that a Player never had the intention to carry out any betting activity with us, the Player should be informed that funds will not be processed until his identity, age and place of residence is proven beyond doubt and/or a period of at least three months has elapsed from when the deposit was made.

Casino shall not accept a wager from a Player unless an Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager; and the funds necessary to cover the amount of the wager are provided in an approved way.

To reduce the possibility that our operation is used to launder money:

• Only bets from known individuals are accepted.
• Cash deposits or withdrawals are not accepted.
• We reserve the right to limit bets without prior notice.
• Betting activity will be monitored for irregular patterns.
• All withdrawal requests will be manually checked to ensure withdrawals are always paid out to the same account used to deposit whenever possible.
• Players who deposited but did not place any bets, or only made a deposit to receive free spins, cannot withdraw any money from their casino account.
• A player always needs to have placed at least his deposit amount in bets before he or she is able to withdraw the money.
• Casino shall not make a payment which results in an excess of two thousand euro (€2,000) gained within 24 hours or a payment which results in an excess of two thousand three hundred euro (€2,300) cumulated of all payouts requested by a Player from the moment of registration, being withdrawn out of a Player's Account to a Player until the Player's identity, age and place of residence have been verified.

Casino cannot accept cash from players and funds may be received from players only by any of the following methods:

• Credit cards
• Debit cards
• Bank transfer
• E-wallets

ChapinWin reserves the right to report suspicious transactions to the relevant authorities.

ChapinWin is licensed by the Curaçao Gaming Control Board since 2025 to offer games of chance in accordance with the National Ordinance on Offshore Games of Hazard, which provides management, payment processing and support services related to the operation of the Website. The Customer Support team is available at support@chapinwin.com.

We seek to offer the highest security to all of our users and customers on www.chapinwin.com. For that, a three-step account verification is done to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into account that depending on the nationality and origin, the way of payment and for withdrawing, different safety measurements must be taken. ChapinWin also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

ChapinWin is committed to high standards of anti-money laundering (AML) according to the EU guidelines and other jurisdictions, and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

Money Laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or company's action.
• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity.
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity.
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.
• Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

In accordance with the AML legislation, Gem Solutions B.V has appointed a Money Laundering Reporting Officer ("MLRO") that is responsible for coordinating the implementation of the AML Policy and policy program. The MLRO's duties also include developing AML initiatives, working with other ChapinWin holders to revise the AML policy, assessing new regulatory requirements, and investigating potentially suspicious or unusual activity. ChapinWin also provides AML training to all its employees on a regular basis.

Each major change of www.chapinwin.com AML policy is subject to approval by the management of Gem Solutions B.V.

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy. This identification relies on the following fundamental principles:

A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture, to secure their privacy.

Please note that all four corners of the ID have to be visible in the same image and all details have to be clearly readable besides the named above. We might ask for all details if necessary.

An employee may do additional checks if necessary, based on the situation.

Proof of address will be done via two different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manual proof.

A recent utility bill sent to your registered address, issued within the last 3 months, or an official document made by the government that proves your state of residence.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible, and all text is readable. For example: an electricity bill, water bill, bank statement or any governmental post addressed to you.

An employee may do additional checks if necessary, based on the situation.

If a player continuously deposits large amounts of money into the account, and if we deem it necessary, there is a process of understanding the source of wealth (SOW). Examples of SOW are:

• Ownership of business
• Employment
• Inheritance
• Investment
• Family

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or proof.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and an information on the website itself.

www.chapinwin.com also asks for a bank wire/credit card to further ensure the identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

In its internal procedures, www.chapinwin.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, the AML team:

• Will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017.
• Will decide whether or not it is necessary to terminate the business relations with the customer.

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Intranet site of www.chapinwin.com.

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship. These data will be safely, encrypted stored offline and online.

All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering, data may be shared with the AML-authority of the affected state.

www.chapinwin.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC).

If you have any questions about our AML and KYC Policy, please contact us by email: support@chapinwin.com