This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Winzoria Casino, operated at win-zoria.bet under a Curaçao eGaming licence, to prevent money laundering, terrorist financing, and other financial crimes. All players, employees, and third parties engaged with win-zoria.bet are subject to this Policy. By registering an account and using our services, you acknowledge and agree to comply with the procedures described herein.

1. Introduction and Purpose

Winzoria is committed to operating a secure, transparent, and legally compliant gambling environment. Money laundering is the process by which criminally obtained funds are introduced into, moved through, or extracted from the legitimate financial system to disguise their true origin. Terrorist financing involves the use of funds — whether of legitimate or illegitimate origin — to support terrorist activity.

This Policy exists to:

• Prevent win-zoria.bet from being used as a vehicle for money laundering or terrorist financing;
• Ensure Winzoria meets its obligations under applicable Curaçao eGaming regulatory requirements and internationally recognised AML standards;
• Establish clear procedures for customer identification, verification, and ongoing monitoring;
• Define how suspicious activity is identified, assessed, and reported.

2. Regulatory Framework

Winzoria operates under a Curaçao eGaming licence. Our AML and KYC procedures are designed to align with the standards set by the Financial Action Task Force (FATF) and related guidance issued by the Curaçao eGaming authority. Where applicable, we also take into account recognised international best practices for the online gambling sector.

This Policy is reviewed and updated regularly to reflect changes in applicable legislation, regulatory guidance, or our own operational risk profile.

3. Designated Compliance Officer

Winzoria appoints a designated Compliance Officer (also referred to as the Money Laundering Reporting Officer, or MLRO) who holds overall responsibility for:

• Implementing and overseeing this Policy;
• Receiving and evaluating internal suspicious activity reports;
• Making disclosures to the relevant authorities where required;
• Ensuring staff receive appropriate AML/KYC training;
• Maintaining adequate records of all compliance activity.

Employees who suspect money laundering or terrorist financing activity must report their concerns to the Compliance Officer promptly. No employee will suffer any detriment for making a good-faith report.

4. Risk-Based Approach

Winzoria applies a risk-based approach to AML and KYC compliance. This means we assess the risk associated with each customer relationship and each transaction, and calibrate our due diligence accordingly. Factors we consider when assessing risk include, but are not limited to:

• The customer's country of residence or nationality, particularly where that country appears on FATF grey or black lists;
• The volume, frequency, and value of deposits and withdrawals relative to stated player profile;
• The payment methods used and whether they are consistent with the customer's profile;
• Whether the player is, or is associated with, a Politically Exposed Person (PEP);
• Unusual patterns in gaming activity or cashier behaviour;
• Any negative information identified during screening.

Higher-risk customers will be subject to Enhanced Due Diligence (EDD) as described in Section 7 below. Lower-risk customers may be subject to Simplified Due Diligence (SDD), though a minimum level of verification always applies.

5. Know Your Customer (KYC) — Customer Due Diligence

5.1 When KYC is Required

Winzoria reserves the right to request identity verification at any point during a customer's relationship with win-zoria.bet. In practice, KYC checks are triggered by any of the following circumstances:

• At account registration, as part of our standard onboarding process;
• Before processing any withdrawal request, regardless of amount;
• When cumulative deposits or transactions reach a threshold that triggers regulatory review;
• When a player requests a significant change to their account details;
• When our monitoring systems flag unusual or potentially suspicious activity;
• At any time we deem it necessary to verify or update customer information.

Players should note that withdrawals — including those processed under our standard under-one-hour payout benchmark — will not be released until any outstanding KYC requirements have been satisfied. Completing verification promptly ensures no unnecessary delay to your funds.

5.2 Identification Documents — Personal Identity

To verify your identity, Winzoria requires at least one valid government-issued photo identity document. Acceptable documents include:

• Valid passport;
• National identity card (where issued by a recognised government authority);
• Government-issued driving licence bearing a photograph.

Documents must be current (not expired), clearly legible, and must show your full legal name, date of birth, and a photograph. We accept clear digital photographs or scanned copies. Poor-quality images that obscure any required detail will not be accepted, and we will request resubmission.

5.3 Proof of Address

In addition to photographic identity, players may be required to provide documentary evidence of their residential address. Acceptable documents include:

• Utility bill (electricity, gas, water, or landline telephone) issued within the last three months;
• Bank statement issued within the last three months;
• Official government correspondence bearing your name and address, issued within the last three months.

The document must clearly show your full name and residential address. Mobile telephone bills and documents older than three months will not be accepted as proof of address.

5.4 Proof of Payment Method

Winzoria supports a range of deposit and withdrawal methods, including Visa, Mastercard, Bank Transfer, Bitcoin (BTC), Ethereum (ETH), Litecoin (LTC), Skrill, and Neteller. To verify ownership of the payment method used and to satisfy AML requirements, we may request:

• For cards: a photograph or scan of the card used (with the middle eight digits obscured and the CVV covered);
• For e-wallets such as Skrill or Neteller: a screenshot of the account dashboard confirming the registered name and account identifier;
• For bank transfers: a recent bank statement confirming the account holder's name and account details;
• For cryptocurrency payments: confirmation of the wallet address used.

All deposits and withdrawals must be made using payment methods registered in the player's own name. Third-party payments — where a deposit or withdrawal is made from or to an account belonging to another individual — are strictly prohibited.

5.5 Source of Funds and Source of Wealth

Where a player's transaction volume or account behaviour warrants additional scrutiny, Winzoria may request evidence of the source of the funds deposited ("Source of Funds") and, in more substantial cases, evidence of the broader origin of the player's wealth ("Source of Wealth").

Acceptable evidence for Source of Funds may include, but is not limited to:

• Recent payslips or employment contract demonstrating salary income;
• Bank statements showing the origin of deposited funds;
• Evidence of business income, dividends, or investment returns;
• Documentation relating to an inheritance, property sale, or other one-off financial event.

Winzoria will handle all documentation submitted for this purpose in accordance with our Privacy Policy. Documents are reviewed by trained compliance staff only and are stored securely.

5.6 Age Verification

Winzoria does not permit individuals under the age of 18 to register or play. Age verification is an integral part of our KYC process. Where age cannot be confirmed from identity documentation provided, we will request additional evidence. Any account found to belong to a minor will be immediately suspended, all funds returned (net of any bonus amounts), and the matter reported as appropriate.

6. Customer Screening

All customers are screened against relevant sanctions lists and PEP databases at the point of registration and on an ongoing basis throughout the customer relationship. This includes screening against:

• United Nations sanctions lists;
• OFAC (Office of Foreign Assets Control) lists;
• EU consolidated sanctions lists;
• HM Treasury (UK) consolidated list;
• Recognised Politically Exposed Persons (PEP) databases;
• Adverse media and negative news databases.

A match against any of these sources will trigger an immediate review. Depending on the outcome of that review, the account may be restricted, subject to Enhanced Due Diligence, or closed entirely. Where legally required, a report will be made to the relevant financial intelligence unit.

7. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied where a customer or transaction is assessed as presenting a higher risk of money laundering or terrorist financing. EDD will be applied in the following circumstances, amongst others:

• The customer is identified as a Politically Exposed Person (PEP) or a close associate or family member of a PEP;
• The customer is resident in, or the funds originate from, a high-risk or non-cooperative jurisdiction as identified by FATF or our own risk assessment;
• The volume or pattern of transactions is inconsistent with the customer's stated profile;
• The customer has triggered one or more suspicious activity indicators (see Section 9);
• There are inconsistencies in the information provided by the customer during verification.

EDD measures may include, but are not limited to, requesting detailed Source of Funds and Source of Wealth documentation, conducting enhanced ongoing monitoring, applying transaction limits, or requiring senior management approval before processing high-value transactions.

8. Ongoing Monitoring

KYC is not a one-time exercise. Winzoria conducts ongoing monitoring of customer accounts and transactions throughout the customer relationship. Our monitoring systems are designed to identify:

• Unusual patterns of deposits, withdrawals, or gameplay that deviate from a player's established profile;
• Rapid cycling of funds through the account (depositing and withdrawing without significant gameplay);
• Use of multiple payment methods in a manner inconsistent with normal behaviour;
• Transactions that approach or exceed internal or regulatory thresholds without adequate explanation;
• Changes in account details (e.g. address, payment method) that may indicate account compromise or misuse;
• Any activity that suggests the account is being used by or for the benefit of a third party.

Where ongoing monitoring flags a concern, the affected account may be temporarily restricted pending investigation. We will contact the player via the registered email address or through our 24/7 live chat and email support channels to request further information where appropriate.

9. Suspicious Activity Indicators

Our compliance team is trained to recognise a wide range of behaviours that may indicate money laundering or financial crime. Examples of suspicious activity indicators relevant to an online gambling environment include:

• Depositing large sums and withdrawing them shortly afterwards with minimal or no genuine gameplay;
• Making multiple deposits just below reporting thresholds ("structuring");
• Requesting withdrawals to a different payment method from the one used to deposit, particularly where this request cannot be satisfactorily explained;
• Providing inconsistent or contradictory information during the verification process;
• Refusing to provide identity or Source of Funds documentation without reasonable explanation;
• Using cryptocurrency deposits in a manner consistent with mixing or tumbling activity;
• Displaying a pattern of play that appears designed to generate a transaction history rather than to win;
• Unexplained sudden changes in deposit volume or withdrawal frequency.

This list is illustrative and not exhaustive. Any activity that causes concern will be reviewed by our compliance team.

10. Suspicious Activity Reporting

Where Winzoria suspects, or has reasonable grounds to suspect, that funds are derived from criminal activity or are connected with money laundering or terrorist financing, we are obliged to report this suspicion to the appropriate financial intelligence unit. Such reports will be made without tipping off the customer concerned.

In line with applicable tipping-off provisions, Winzoria and its staff are prohibited from disclosing to the customer, or to any third party, that a suspicious activity report has been made or that an investigation is underway. Affected accounts may be restricted or frozen without explanation pending the outcome of any investigation.

11. Consequences of Non-Compliance

Where a player fails to provide the documentation requested under this Policy within a reasonable timeframe, or where the documentation provided is found to be fraudulent, misleading, or insufficient, Winzoria reserves the right to take any or all of the following steps:

• Suspend or permanently close the player's account;
• Withhold pending withdrawals pending satisfactory completion of KYC;
• Void bonus funds or winnings derived during a period when verification requirements were outstanding;
• Report the matter to the relevant regulatory or law enforcement authorities;
• Retain funds where required to do so by law or regulatory direction.

Winzoria will always act proportionately and in good faith. Players who provide complete and accurate documentation can expect their accounts to be fully restored and their withdrawals to proceed without undue delay.

12. Prohibited Players and Restricted Territories

Winzoria does not accept registrations from individuals located in jurisdictions where online gambling is prohibited by local law, or where we are otherwise unable to offer our services in compliance with applicable regulations. Players are responsible for ensuring that their use of win-zoria.bet is lawful in their own jurisdiction.

In addition, Winzoria will not accept funds from, or provide services to, any individual or entity subject to applicable financial sanctions, including those designated under UN, OFAC, or EU sanctions regimes.

13. Payment Method Integrity

Consistent with our AML obligations, Winzoria applies the following rules to all payment transactions:

• No third-party payments: Deposits may only be made from a payment method registered in the account holder's own name. Withdrawals will only be issued to the same method, or to another verified method belonging to the account holder.
• Source consistency: Winzoria will, wherever possible, return funds to the method from which they were originally deposited. This reflects standard AML best practice and limits the risk of funds being diverted through our platform.
• Cryptocurrency transparency: Cryptocurrency transactions, including Bitcoin (BTC), Ethereum (ETH), and Litecoin (LTC), are subject to the same KYC and AML controls as fiat transactions. We may conduct blockchain analytics on wallet addresses associated with player accounts where this is warranted by our risk assessment.

Our minimum deposit and withdrawal threshold of €20 applies across all accepted payment methods. Maximum deposit limits range from €10,000 for cards and e-wallets to €50,000 for cryptocurrency and bank transfer. These limits also serve an AML function by establishing clear parameters for transaction monitoring.

14. Record Keeping

Winzoria retains all KYC documentation, transaction records, and AML-related correspondence for a minimum period of five years from the date of the relevant transaction or the closure of the customer's account, whichever is the later. Records are maintained securely and may be made available to regulatory authorities upon request.

Records retained include, but are not limited to:

• Copies of all identity and address verification documents submitted by customers;
• Records of all deposits, withdrawals, and in-account transactions;
• Records of all KYC checks, screening results, and due diligence assessments;
• Internal suspicious activity reports and any external disclosures made to authorities;
• Communications with customers relating to verification or AML matters.

15. Staff Training

All Winzoria staff who interact with customer accounts or financial transactions receive appropriate AML and KYC training upon joining the company and on a regular ongoing basis. Training covers:

• The legal and regulatory framework applicable to our operations;
• The content and requirements of this Policy;
• How to identify suspicious activity indicators;
• Internal reporting procedures and obligations;
• The consequences of failure to comply with AML obligations.

Records of training completion are maintained by the Compliance Officer.

16. Responsible Gambling and AML

Winzoria recognises that responsible gambling and AML compliance are closely linked. Problem gambling behaviour — such as depositing amounts that appear inconsistent with a player's stated circumstances — can also serve as an indicator of potential financial crime. Our compliance and responsible gambling teams work in tandem.

Players may make use of our responsible gambling tools at any time, including deposit limits, loss limits, and self-exclusion. These tools are available directly through the account dashboard and through our 24/7 support team via live chat or email. A player who sets limits that restrict their transaction activity will not be penalised under this Policy for the resulting change in their deposit or play pattern.

17. Data Protection

All personal data collected in connection with our KYC and AML procedures is processed in accordance with Winzoria's Privacy Policy and applicable data protection legislation. Documentation submitted for verification purposes is used solely for the purpose of identity verification, AML compliance, and regulatory reporting obligations. It is not shared with third parties except where required by law or regulation, or where we engage regulated third-party identity verification service providers operating under equivalent data protection standards.

18. Policy Updates

Winzoria reviews this Policy on a regular basis and whenever there are material changes to applicable law, regulatory guidance, or our own risk environment. The current version of this Policy is published at win-zoria.bet. Continued use of our services following any update to this Policy constitutes acceptance of the revised terms.

19. Contact

If you have questions about this Policy or about your verification status, please contact our compliance team through any of the following channels:

• 24/7 Live Chat: Available directly on win-zoria.bet
• Email: Available via the contact page on win-zoria.bet

We aim to respond to all compliance-related queries promptly. If your account has been restricted pending verification, providing the requested documentation as quickly as possible will ensure the fastest possible resolution.