This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Winzoria Casino, operated at winszoria.nl under a Curaçao eGaming licence, to detect, prevent and report financial crime. It applies to every player account opened on winszoria.nl and governs how we collect, verify and monitor customer information in accordance with applicable anti-money laundering legislation and the conditions of our Curaçao eGaming licence.
Winzoria is committed to operating a clean, transparent and compliant gaming environment. Money laundering — the process by which funds derived from criminal activity are introduced into the legitimate financial system — poses a serious risk to regulated online gaming operators and to the wider public. The financing of terrorism through gaming platforms represents an equally grave concern.
This Policy exists to ensure that winszoria.nl is never knowingly used as a vehicle for money laundering, terrorist financing, fraud or any other financial crime. We achieve this through robust customer due diligence, ongoing transaction monitoring, clear internal procedures and full cooperation with competent authorities wherever required by law.
All staff with customer-facing or financial responsibilities at Winzoria are required to understand and adhere to this Policy. Any third-party payment processors or service providers engaged by Winzoria are likewise expected to meet equivalent standards.
Winzoria operates under a Curaçao eGaming licence, launched in 2024, and is bound by the anti-money laundering and counter-terrorist financing requirements imposed by that licence. In addition, this Policy reflects the principles contained in widely accepted international standards, including the recommendations of the Financial Action Task Force (FATF). Where players access winszoria.nl from jurisdictions that impose additional local AML obligations, Winzoria takes those obligations into account in applying this Policy.
Nothing in this Policy limits our right or duty to report suspicious activity to the relevant authorities or to refuse service where we have reasonable grounds to suspect financial crime.
This Policy applies to:
Our KYC programme is the foundation of our AML framework. It allows us to establish the true identity of every customer, assess the risk they present and detect behaviour that is inconsistent with their stated profile. KYC at Winzoria is not a one-time event — it is an ongoing process that continues for the lifetime of the account.
When a player creates an account at winszoria.nl, they are required to provide the following information:
Account registration is completed only after the player confirms their email address via the verification link sent to their inbox. Providing false or misleading information at registration is a breach of Winzoria's Terms and Conditions and may constitute a criminal offence under applicable law.
KYC document verification is a mandatory requirement and must be completed before any withdrawal is processed. We strongly encourage players to submit their documents as early as possible after registration so that there is no delay when a winning withdrawal is requested. The minimum withdrawal amount at winszoria.nl is €20, and our target payout speed is under one hour — but that speed is conditional on KYC being complete and satisfactory.
Players will be asked to provide documentation from the categories set out below. Winzoria reserves the right to request additional documents at any stage if our compliance team considers it necessary.
One of the following government-issued documents, valid at the time of submission:
Documents must be in colour, fully legible, and show the player's full name, date of birth, photograph, document number and expiry date. Expired documents will not be accepted.
One of the following, dated within the last three months:
Mobile phone bills are not accepted as proof of address. The address on the document must match the address provided during registration.
Where a player deposits using a credit or debit card (Visa or Mastercard), we may request a copy of the card used, showing the cardholder name, the first six and last four digits, and the expiry date. The CVV and any digits not described above must be obscured. For bank transfer deposits, we may request a copy of a recent bank statement confirming account ownership. For cryptocurrency deposits, we may request evidence linking the sending wallet address to the player.
Standard verification procedures apply to the majority of our players. However, certain circumstances trigger Enhanced Due Diligence, under which additional information and documentation will be required. EDD applies in the following situations:
Under EDD, Winzoria may require the player to provide a source of funds declaration, source of wealth evidence (such as payslips, tax returns, business accounts or evidence of an inheritance), and any other documentation considered relevant. Withdrawals and, in some cases, continued deposits may be suspended pending completion of EDD.
KYC is not static. Winzoria reviews customer profiles on an ongoing basis, particularly when account activity changes materially. We may request updated or additional documentation from any player at any time, including players who have previously passed full verification. If a player fails to respond to a request for updated documentation within a reasonable timeframe, Winzoria reserves the right to restrict or close the account and, where required by law, report the matter to the relevant authority.
Winzoria maintains automated and manual transaction monitoring systems that operate across all player accounts and all payment channels. These systems are designed to identify patterns and behaviours that may be indicative of money laundering, fraud or other financial crime.
Our monitoring systems flag activity including but not limited to:
As a general rule, Winzoria applies a same-method withdrawal policy: funds deposited by a particular method will, where technically possible, be returned via that same method. This applies to Visa, Mastercard, bank transfer, Bitcoin, Ethereum and Litecoin. Where a player has used multiple methods, withdrawals are ordinarily directed to the method used for the most recent qualifying deposit. This practice reduces the risk of funds being redirected through unrelated accounts or wallets.
Winzoria accepts deposits and withdrawals in Bitcoin, Ethereum, Litecoin and other cryptocurrencies. While cryptocurrency transactions offer speed and convenience, they also present specific AML risks. We apply all standard KYC and EDD requirements to cryptocurrency users without exception. In addition, we may conduct blockchain analysis on wallet addresses associated with a player's account. Transactions linked to wallets that have interacted with sanctioned entities, darknet markets, or high-risk mixing services will be treated as suspicious and may result in account restriction and regulatory reporting.
Winzoria applies a risk-based approach to customer due diligence, meaning that the level of scrutiny applied to any individual account is proportionate to the risk that account presents. Risk factors considered include:
| Risk Factor | Lower Risk Indicators | Higher Risk Indicators |
|---|---|---|
| Geography | Low-risk jurisdiction with strong AML frameworks | FATF grey-listed or blacklisted jurisdiction |
| Deposit behaviour | Regular, modest deposits consistent with stated profile | Large, sudden or irregular deposits; multiple methods |
| Withdrawal behaviour | Withdrawals proportionate to deposit and play history | Immediate large withdrawals with minimal play |
| PEP / Sanctions status | No PEP or sanctions match | Confirmed or potential PEP; sanctions list match |
| Account history | Long-standing account with consistent behaviour | New account with high-value activity or unusual pattern |
| Payment method | Verified card or bank account in player's own name | Third-party payment; unverified crypto wallet |
Risk assessments are reviewed periodically and updated whenever material new information becomes available about a player or their account activity.
Winzoria screens all players against applicable international sanctions lists at the point of registration and on an ongoing basis. These lists include, without limitation, those maintained by the United Nations Security Council, the European Union, the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury, and other relevant regulatory bodies. Any match — confirmed or potential — will result in immediate account restriction pending further review, and may result in mandatory reporting to the competent authority and permanent account closure. Winzoria will not process any transaction involving a sanctioned individual, entity or jurisdiction.
A Politically Exposed Person is an individual who holds or has recently held a prominent public position, including heads of state or government, senior politicians, senior government officials, senior judicial or military officials, senior executives of state-owned enterprises, and senior officials of major political parties. Immediate family members and known close associates of such individuals are also treated as PEPs for the purposes of this Policy.
Winzoria screens all customers against PEP databases at registration and at regular intervals thereafter. If a player is identified as a PEP, their account will be subject to Enhanced Due Diligence as described in section 4.6. Winzoria's senior compliance personnel must approve the opening or continued operation of any account held by a PEP. PEP status alone does not result in automatic refusal of service, but the heightened risk associated with such accounts requires additional scrutiny and ongoing monitoring at all times.
Where Winzoria's compliance team identifies activity that is suspected, on reasonable grounds, to involve money laundering, terrorist financing or another financial crime, we are obliged to file a Suspicious Activity Report (SAR) or equivalent report with the relevant competent authority. This obligation exists regardless of the amount involved and regardless of whether any criminal proceedings are ultimately brought.
Winzoria operates a strict policy of non-tipping-off: no player will be informed that a SAR has been filed, or that their account is under investigation, or that information about them has been disclosed to an authority. Disclosing such information — whether intentionally or through carelessness — may itself constitute a criminal offence and is prohibited by this Policy.
Account restrictions, withdrawal suspensions or document requests issued by our compliance team in connection with a suspicious activity review will be communicated to the player only in terms that do not reveal the underlying investigation.
Winzoria reserves the right to restrict, suspend or permanently close any player account at any time where:
Where an account is restricted or closed on AML grounds, Winzoria will handle any funds in the account in accordance with our legal obligations and the directions of the relevant competent authority. The player will be notified of the closure in accordance with our Terms and Conditions, subject always to the non-tipping-off obligation described in section 9.
The payment limits set out on winszoria.nl — a minimum deposit and withdrawal of €20, a maximum card deposit of €5,000 and a maximum bank transfer or cryptocurrency deposit of €10,000 — form part of our broader financial controls framework. These limits help us to manage risk across our payment channels. Approaching or reaching the upper limits of any payment method may trigger additional due diligence requirements, as described in section 4.6. Players using multiple payment methods to aggregate deposits that would otherwise exceed a single-method limit should be aware that such behaviour may itself constitute a monitoring flag.
Winzoria's welcome package — up to €10,000 across ten deposit tiers, with associated free spins — and ongoing weekly promotions (reload bonuses, cashback offers, free spin drops and seasonal promotions) are subject to the same AML monitoring as all other account activity. Attempts to exploit bonus structures in a manner designed to generate withdrawable funds without genuine play, or to use promotional funds to launder money, will be treated as suspicious activity and may result in bonus forfeiture, account closure and regulatory reporting. Wagering requirements attached to bonus funds must be met through genuine gameplay.
Winzoria's VIP and loyalty programme rewards consistent play through progressive tiers, with benefits including higher cashback percentages, personal account management and exclusive promotions. Players at senior VIP tiers deposit and withdraw at higher volumes than the general player population, which means their accounts are subject to proportionally greater scrutiny under our risk-based approach. Senior VIP accounts will undergo periodic source of funds and source of wealth reviews as a matter of routine, regardless of whether any specific suspicious activity flag has been generated. Cooperation with these reviews is a condition of maintaining VIP status.
Winzoria's responsible gaming commitments and our AML obligations are complementary. Both require us to understand our customers — their identity, their financial circumstances and the way in which they use our platform. Players who exhibit problem gambling behaviours may also exhibit unusual financial patterns; our compliance team works alongside our responsible gaming function to ensure that concerning signals are addressed appropriately through both frameworks. Self-exclusion, deposit limits, session limits and other responsible gaming tools available at winszoria.nl remain in force throughout any AML review, and the existence of an AML review does not suspend a player's access to responsible gaming protections.
All Winzoria employees and contractors who handle customer accounts, process payments or have access to player data receive training in AML and KYC obligations proportionate to their role. Training covers the recognition of suspicious activity, the correct escalation procedures, the non-tipping-off obligation and the consequences of non-compliance. Training is conducted at induction and refreshed on a regular basis, or whenever material changes are made to this Policy or to the applicable legal framework.
Winzoria maintains a designated Money Laundering Reporting Officer (MLRO) who is responsible for receiving internal suspicion reports, assessing them and, where appropriate, making external reports to the competent authority. The MLRO has direct access to senior management and to all information required to carry out their function.
Winzoria retains records of all customer identification documents, due diligence information, transaction data and internal investigation records for a minimum of five years from the date of the relevant transaction or the closure of the account, whichever is later. Records are stored securely and may be disclosed to competent authorities on request. This retention practice is in accordance with standard AML record-keeping requirements and forms part of our obligations under the Curaçao eGaming licence.
This Policy is reviewed at least annually by Winzoria's compliance function and updated whenever material changes occur in the applicable legal or regulatory framework, in our business model or in the risk environment in which we operate. The current version of this Policy is available at winszoria.nl at all times. Continued use of winszoria.nl constitutes acceptance of the Policy as in force at the time of that use.
If you have a question about this Policy, your KYC verification status or a document request you have received, please contact our support team, which is available 24 hours a day, seven days a week, via live chat or email at winszoria.nl. All AML and KYC enquiries are handled in strict confidence.
