AML & KYC Policy

1. Purpose & Scope

This policy establishes the framework Matrix Spins Casino uses to detect, prevent, and report money laundering, terrorism financing, fraud, and other financial crime. It applies to every employee, contractor, agent, payment processor, and counterparty acting on behalf of the platform.

The program is designed to comply with:

• The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and accompanying AUSTRAC Rules
• The Financial Action Task Force (FATF) 40 Recommendations
• EU 6th AML Directive obligations for European players
• UK Money Laundering Regulations 2017 (as amended)
• OFAC, UN, EU, AU/DFAT, and HM Treasury sanctions lists

2. Our Commitment

We will not knowingly accept funds derived from criminal activity, nor permit our platform to be used to launder proceeds, finance terrorism, or evade tax. We commit to:

• Verifying every customer's identity, age, and jurisdiction before payouts
• Applying a risk-based approach proportionate to player activity
• Cooperating fully with regulators, law enforcement, and financial intelligence units
• Maintaining a Money Laundering Reporting Officer (MLRO) with direct reporting lines to senior management
• Reviewing this policy annually, or sooner if regulation changes

3. Know Your Customer (KYC) Procedures

Before a player can withdraw funds, deposit above tier-1 thresholds, or claim accumulated bonuses above limits, we collect and verify the following:

Tier 1 — Account Opening

• Full legal name, date of birth, residential address
• Email address (verified via confirmation link)
• Phone number (verified via SMS one-time-code)
• Self-declared country of residence and currency

Tier 2 — First Withdrawal or Deposits ≥ AUD $1,000

• Government-issued photo ID (passport, driver's licence, or national ID)
• Proof of address dated within the last 90 days (utility bill, bank statement, or government letter)
• Selfie with ID for biometric liveness check

Tier 3 — Cumulative deposits ≥ AUD $10,000 in a rolling 12 months

• Source of funds questionnaire
• Supporting evidence (payslip, tax assessment, sale-of-asset contract, inheritance document)
• Politically Exposed Person (PEP) screening refresh

All ID documents are encrypted at rest and accessible only to verified compliance staff. Records are retained for seven (7) years from the date of account closure as required by law.

4. Customer Due Diligence (CDD)

CDD is performed at onboarding and refreshed periodically based on player risk score. The score considers:

• Geographic risk (FATF grey/black list, sanctioned country, high-risk jurisdiction)
• Product risk (crypto deposits attract higher scrutiny than card deposits)
• Behavioural risk (rapid deposit-withdrawal cycling, low playthrough relative to deposits)
• Customer profile risk (PEP, adverse-media match, previous AML history)

5. Enhanced Due Diligence (EDD)

EDD applies to high-risk customers, including:

• Politically Exposed Persons (PEPs), their family members, and close associates
• Customers whose home jurisdiction appears on FATF or sanctions lists
• Customers depositing via privacy-preserving cryptocurrencies or mixers
• Customers flagged by transaction monitoring or adverse-media screening

EDD requires senior compliance approval before account funding, ongoing enhanced monitoring, and at least one comprehensive review every twelve months.

6. Source of Funds & Source of Wealth

For deposits exceeding the Tier 3 threshold, or where transaction monitoring flags unusual flow, we will request documented evidence of where the money originated. Acceptable evidence includes:

• Recent payslips or salary deposits
• Most recent tax return or notice of assessment
• Bank statements showing income for the last six months
• Sale documents (property, vehicle, business interests)
• Inheritance, dividend, or trust distribution paperwork
• Cryptocurrency exchange statements with on-chain provenance

7. Transaction Monitoring

Every deposit, withdrawal, transfer, and bonus credit is screened in real-time against rule-based detection logic. Flags include:

• Structuring: Multiple deposits just below reporting thresholds within a short window
• Velocity: Unusually rapid increases in deposit volume relative to baseline
• Low-play withdrawal: Funds deposited then withdrawn with minimal wagering activity
• Geographic anomalies: Logins, deposits, and withdrawals from inconsistent locations
• Method-switching: Funding via one channel and withdrawing to another (potential layering)

Each flag generates an alert to the compliance team for review within 24 hours. False positives are documented; confirmed risks escalate to the MLRO.

8. Suspicious Matter Reporting (SMRs)

Where there are reasonable grounds to suspect a transaction relates to money laundering, terrorism financing, fraud, or any other reportable predicate offence, the MLRO will lodge a Suspicious Matter Report with AUSTRAC within the statutory timeframe (3 business days for terrorism financing, 24 hours for high-risk matters).

Tipping-off the customer is a criminal offence and is strictly prohibited. Suspicious activity will be reviewed without alerting the player, the player's account may be frozen pending investigation, and reported funds may be returned to source under regulatory direction.

9. Sanctions & Watchlist Screening

All players are screened at onboarding and continuously thereafter against:

• UN Security Council Consolidated List
• OFAC Specially Designated Nationals (SDN) and consolidated non-SDN lists
• EU consolidated financial sanctions
• UK HM Treasury financial sanctions
• Australian DFAT consolidated list
• PEP and adverse-media databases

A confirmed match results in immediate account suspension, asset freezing where required, and notification to the appropriate authority. Funds will not be returned without explicit regulatory authorisation.

10. Record Keeping

We retain the following for a minimum of seven (7) years from the end of the customer relationship or the date of the transaction, whichever is later:

• Identity verification documents and verification audit trail
• Transaction records (deposits, withdrawals, bonus events, gameplay)
• Source-of-funds and source-of-wealth evidence
• Internal SAR/SMR memos and external regulatory filings
• Risk assessments, EDD files, and senior-management approvals

Records are stored in encrypted form across geographically diverse data centres with access logged and reviewed.

11. Staff Training

All staff with customer or transactional access undergo AML/CTF training at induction and at minimum annually thereafter. Training covers red flags, escalation procedures, customer-confidentiality, sanctions awareness, the criminal offence of tipping-off, and any updates from regulators.

The compliance team and MLRO undergo additional advanced training and maintain professional certification (e.g. ICA, ACAMS).

12. Reporting & Compliance Governance

The MLRO reports independently to the Board's Audit & Risk Committee. Quarterly reports cover transaction volumes, alert activity, SMR statistics, training completion, and program effectiveness.

An external independent audit of the AML/CTF program is conducted at least every two years. Recommendations are tracked to closure and reported to the Board.

13. Contact the MLRO

If you wish to raise a concern, request information about your file, or report suspicious activity: