This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of AccelCore Enterprise Limitada ("we", "us", "the Operator") in relation to the detection, prevention, and reporting of money laundering, terrorist financing, and other financial crime in connection with the operation of DiceSpin Casino at casino-dicespin.org. The Policy applies to all players, transactions, and activities conducted on the platform and is maintained in accordance with the requirements of our licence, Anjouan licence reference ALSI-202506031-FI2, issued by the Government of the Autonomous Island of Anjouan.

1. Introduction and Purpose

Money laundering is the process by which the proceeds of criminal activity are disguised to appear as legitimate funds. Terrorist financing involves the use of funds — whether lawfully or unlawfully obtained — to support terrorist activity. Both represent serious threats to the integrity of the financial system and to society at large.

AccelCore Enterprise Limitada is committed to conducting its operations at casino-dicespin.org in a manner that actively deters and prevents the use of our platform for any such purpose. This Policy establishes the internal controls, procedures, and standards that dicespin implements to fulfil that commitment. All members of staff involved in the operation of casino-dicespin.org are required to understand and adhere to this Policy.

This Policy should be read alongside our Terms and Conditions, Privacy Policy, and Responsible Gambling Policy, all of which are published on casino-dicespin.org.

2. Legal and Regulatory Framework

dicespin operates under Anjouan licence ALSI-202506031-FI2. The Operator is incorporated as AccelCore Enterprise Limitada in Costa Rica (registration number 3102926243). We apply AML and KYC standards consistent with internationally recognised best practice, including the recommendations of the Financial Action Task Force (FATF), as the foundation for our compliance framework. Our obligations include, but are not limited to:

• Identifying and verifying the identity of all customers before processing withdrawals and, where required, before processing deposits;
• Monitoring customer activity on an ongoing basis to detect suspicious patterns or behaviour;
• Maintaining adequate records of customer identification and transaction data for the period required by applicable law;
• Reporting suspicious activity to the relevant authorities where we have grounds to suspect money laundering or terrorist financing;
• Training relevant personnel in AML and KYC obligations and ensuring awareness of the latest typologies and red flags;
• Appointing a designated Money Laundering Reporting Officer (MLRO) responsible for oversight of this Policy.

3. Money Laundering Reporting Officer (MLRO)

The Operator has designated a Money Laundering Reporting Officer who bears overall responsibility for the implementation and ongoing review of this Policy. The MLRO is the central point of contact for all internal suspicion reports and is responsible for determining whether a report to the relevant competent authority is warranted. All staff who suspect or become aware of potential money laundering or terrorist financing activity must report their concern to the MLRO without delay. The MLRO can be contacted via the compliance contact address published internally and, for player-facing queries, through [email protected].

4. Customer Due Diligence (CDD) — Know Your Customer

Know Your Customer (KYC) procedures form the foundation of our AML framework. dicespin applies a risk-based approach to customer due diligence, meaning that the level of verification applied to any given customer is proportionate to the risk that customer presents. We distinguish between Standard Due Diligence, Simplified Due Diligence, and Enhanced Due Diligence as described below.

4.1 When KYC is Required

dicespin may request identity verification documents at any stage of a customer's relationship with the casino. However, KYC verification must be completed, and all required documents approved, before any withdrawal is processed. In addition, verification may be triggered at any earlier point where:

• A customer's cumulative deposits reach a threshold that requires us to conduct enhanced review;
• A pattern of deposits or play raises a concern about the source of funds;
• Unusual transaction behaviour is identified through our transaction monitoring systems;
• A customer requests a change of registered payment method or account details;
• We receive information that calls into question the accuracy of previously provided identification data;
• Any other circumstance arises that, in the judgement of our compliance team or MLRO, warrants verification.

Players are advised to complete verification proactively to avoid delays to withdrawals. Our published payout speed is 1–3 business days after verification is complete.

4.2 Standard Due Diligence — Required Documents

All players will be required to provide the following as part of the standard verification process:

• Proof of Identity (POI): A valid, government-issued document bearing your full name, date of birth, and photograph. Acceptable documents include a national identity card, passport, or driving licence. The document must be current (not expired) and legible in its entirety, including all four corners and the document number.
• Proof of Address (POA): A document confirming your residential address, issued within the last three months. Acceptable documents include a utility bill (gas, electricity, water), bank statement, or official government correspondence. PO Box addresses are not accepted.
• Proof of Payment Option (POPM): Evidence that the payment method used to deposit funds belongs to you. For cards, this typically means a photograph or scan of the card showing your name, the first six and last four digits, and the expiry date. For e-wallets (Skrill, Neteller, MiFinity, Jetonbank), a screenshot of the account dashboard confirming your name and account identifier may be required. For bank transfers via IBAN, a bank statement or letter confirming your account details may be requested. All payment methods must be registered in your own name — business accounts are not permitted on casino-dicespin.org.

4.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied where our risk assessment identifies a higher risk of money laundering or where specific circumstances demand additional scrutiny. EDD may be triggered by, amongst other things, large or unusual deposits or withdrawals, customers identified as Politically Exposed Persons (PEPs), customers from higher-risk jurisdictions, or patterns of play that are inconsistent with the customer's stated profile.

Where EDD is required, we may request one or more of the following in addition to the standard KYC documents:

• Source of Funds (SOF): Documentation evidencing the origin of the specific funds deposited at dicespin. This may include recent payslips, bank statements covering the relevant period, or evidence of a specific transaction such as a property sale or investment withdrawal.
• Source of Wealth (SOW): Broader documentation establishing the overall financial standing of the customer and the legitimate origin of their accumulated wealth. This may include tax returns, employment contracts, evidence of business ownership, or inheritance documentation.
• Additional Identity Checks: For customers identified as PEPs or their close associates, we may request a signed declaration and will conduct appropriate screening against relevant sanctions lists and adverse media sources.
• Selfie / Liveness Check: We may ask customers to submit a photograph of themselves holding their identity document alongside a handwritten note containing the current date and "dicespin" in order to confirm liveness and document authenticity.

Failure to provide requested EDD documentation within the timeframe specified in our communication will result in the suspension of withdrawal processing and may result in account restriction or closure. Where funds have been deposited but EDD cannot be completed to our satisfaction, we will manage the return of funds in accordance with applicable law and our regulatory obligations.

4.4 Simplified Due Diligence

In limited, low-risk circumstances, we may apply a reduced level of due diligence where this is permitted under applicable guidance and where the customer's activity presents a demonstrably low risk profile. This determination is made solely by the compliance team and is not an entitlement that customers can elect.

5. Account Registration and Identity Requirements

To register an account at casino-dicespin.org, customers must be at least 18 years of age. By creating an account, you confirm that all information provided — including name, date of birth, residential address, email address, and contact details — is accurate, complete, and up to date. You further confirm that you are acting on your own behalf and not on behalf of any third party.

Each individual may hold only one registered account at dicespin. The creation of multiple accounts by the same individual is prohibited and constitutes grounds for account closure, forfeiture of bonus funds, and reporting to the relevant authorities where this behaviour is indicative of fraud or abuse. dicespin employs automated and manual detection methods to identify duplicate accounts.

All payment methods linked to an account must be in the account holder's own name. Deposits from or withdrawals to third-party accounts are strictly prohibited. Where a third-party payment is identified, the deposit will be reversed and the account reviewed. This rule applies equally to all payment methods available at casino-dicespin.org, including Visa, Mastercard, Skrill, Neteller, Trustly, Brite, MiFinity, Jetonbank, Sofort, and bank transfer (IBAN).

6. Transaction Monitoring and Limits

dicespin operates an ongoing transaction monitoring programme designed to identify activity that may be indicative of money laundering, fraud, or other financial crime. This includes automated alerting based on predefined thresholds as well as manual review by our compliance team.

The following financial limits apply to all accounts at casino-dicespin.org:

Parameter	Limit / Detail
Minimum Deposit	€20 (all methods)
Minimum Withdrawal	€50
Withdrawal Fee	€3 per withdrawal (refunded if withdrawal is not processed)
Maximum Withdrawal — Daily	€5,000
Maximum Withdrawal — Weekly	€10,000
Maximum Withdrawal — Monthly	€40,000
Large Win Payments	Wins of €40,000 or more paid in instalments
Withdrawal How Long It Takes	1–3 business days following successful KYC verification
Supported Currencies	EUR, USD, AUD, CAD, CZK, NOK, PLN, CHF, NZD

These limits are applied cumulatively across all payment methods. Attempts to circumvent transaction limits — including, without limitation, splitting deposits or withdrawals across multiple transactions, methods, or accounts — will be flagged as suspicious and may result in account suspension, investigation, and reporting to the relevant authorities.

Our transaction monitoring system identifies, among other patterns, the following as requiring review:

• Rapid deposit and withdrawal activity with minimal or no gameplay, particularly where there is no clear recreational or entertainment purpose;
• Deposits made via multiple different payment methods in a short period;
• Requests to withdraw to a different payment method or account from that used to deposit;
• Deposits that significantly exceed the customer's stated income or employment profile;
• Unusually large single deposits not consistent with prior account history;
• Patterns of play that appear designed to generate a transaction record without genuine gambling activity;
• Activity consistent with chip-dumping or collusion in table or live casino games.

7. Politically Exposed Persons (PEPs) and Sanctions Screening

A Politically Exposed Person (PEP) is an individual who holds, or has held, a prominent public function, together with their immediate family members and known close associates. By virtue of the influence they may exercise, PEPs present a heightened risk of involvement in bribery and corruption and are therefore subject to Enhanced Due Diligence under this Policy.

dicespin screens all new customers against recognised PEP databases and international sanctions lists at the point of registration and on an ongoing basis. We also screen against the relevant sanctions lists maintained by bodies including the United Nations, the European Union, and other competent authorities. Any customer identified as a PEP, a sanctioned individual or entity, or a close associate of either, will be subject to enhanced scrutiny. We reserve the right to decline registration, restrict activity, or close an account where our screening identifies an unacceptable risk.

Customers who are, or become, PEPs are required to notify dicespin of that status. Failure to do so may constitute a breach of our Terms and Conditions and, where relevant, of applicable law.

8. Suspicious Activity Reporting

Where the Operator, the MLRO, or any member of the compliance team suspects or has reasonable grounds to suspect that funds held in, transacted through, or associated with a player account are connected to money laundering or terrorist financing, we will file a report with the relevant competent authority. This obligation arises regardless of the size of the transaction or the account balance involved.

The Operator and all personnel are legally prohibited from "tipping off" any customer that a suspicious activity report has been filed or that an investigation is underway. Accordingly, if your account is placed under review, we may be unable to disclose the specific reason for any restriction, delay, or closure, even if you contact our support team. We appreciate that this may be frustrating and thank customers for their understanding of our legal obligations.

dicespin will co-operate fully with any lawful request for information from regulatory bodies, law enforcement agencies, or other competent authorities, and will provide all documentation and records requested within the timeframes specified.

9. Record Keeping

The Operator maintains comprehensive records relating to customer identification, verification, and transaction history for the period required by applicable law and regulatory guidance. These records include, but are not limited to:

• Copies of all identity and verification documents submitted by customers;
• Records of all deposits and withdrawals, including method, amount, currency, date, and time;
• Records of all internal suspicion reports and the outcome of MLRO review;
• Records of all external reports made to competent authorities;
• Records of staff AML training undertaken and completion dates;
• Risk assessments conducted in connection with individual customer accounts.

All personal data collected in connection with this Policy is processed in accordance with our Privacy Policy, which sets out how we collect, use, store, and protect customer data and the rights customers have in respect of their personal information.

10. Staff Training

All personnel involved in the operation of casino-dicespin.org who are in scope for AML obligations receive regular training covering the requirements of this Policy, the recognition of money laundering and terrorist financing typologies and red flags, the correct procedure for raising an internal suspicion report, and the legal consequences of tipping off. Training is reviewed and updated periodically to reflect changes in the regulatory environment and emerging financial crime typologies. Records of training completion are maintained by the MLRO.

11. Risk-Based Approach and Internal Risk Assessment

The Operator applies a risk-based approach to AML and KYC, meaning that the resources and controls applied to any customer or transaction are proportionate to the risk identified. Our overall risk assessment takes into account, amongst other factors:

• The jurisdiction from which a customer is accessing the service;
• The payment methods used and the nature of the funds deposited;
• The volume and velocity of transactions relative to the customer's stated profile;
• The nature and pattern of gambling activity on the account;
• Any adverse media, PEP, or sanctions flags identified through screening;
• The products used — noting that casino-dicespin.org offers casino games across 8,650+ titles from 56 studios, 116 live dealer tables, and a full Altenar-powered sportsbook covering 37 sports and 3,570+ events — all of which are factored into our product-level risk assessment.

Our internal risk assessment is reviewed at least annually and whenever a material change in our business, product offering, or regulatory environment warrants a fresh assessment.

12. Responsible Gambling and AML Interaction

dicespin recognises that problem gambling and financial crime can intersect. Unusually high levels of gambling activity relative to a customer's financial means can indicate both problem gambling behaviour and potential money laundering. Our responsible gambling monitoring and our AML monitoring operate in parallel, and concerns identified through either stream are escalated appropriately.

Players who wish to set deposit limits, take a break, or self-exclude from casino-dicespin.org are encouraged to contact our support team via Live Chat (powered by Intercom) or by emailing us. Responsible gambling tools are available to all customers and their use is encouraged as part of our commitment to player wellbeing.

13. Bonus Abuse and Financial Crime

The misuse of promotional offers — including the 200% casino welcome bonus up to €1,000, the 100% Free Bet up to €200 on sports, the 10% daily cashback, and any other ongoing promotions — for the purpose of laundering funds or obtaining an improper financial advantage constitutes a serious breach of our Terms and Conditions and may constitute financial crime. dicespin employs automated and manual controls to detect bonus abuse and will take appropriate action, including forfeiture of bonus funds, account closure, and reporting to relevant authorities, where such behaviour is identified.

The daily cashback of 10% — paid as real, withdrawable cash with no wagering requirement by 11:00 UTC each morning on qualifying net losses from slots and settled sportsbook bets — is subject to the same AML monitoring as all other financial flows on the platform. Customers excluded from the cashback programme (including those in Finland, Estonia, Poland, Austria, Latvia, Canada, Brazil, Chile, and Peru) should note that this exclusion does not affect any other aspect of this Policy, which applies to all registered customers without exception.

14. Consequences of Non-Compliance

Where a customer fails to complete required KYC or EDD procedures, provides false, misleading, or incomplete information, is found to be engaged in suspicious activity, or otherwise breaches this Policy, dicespin reserves the right to take any or all of the following actions:

• Suspend withdrawal processing pending investigation;
• Place a temporary hold on the customer's account;
• Request additional information or documentation;
• Permanently close the customer's account;
• Forfeit bonus funds and cashback credited to the account;
• Retain funds where required to do so under applicable law or a competent authority's direction;
• File a report with the relevant law enforcement or regulatory authority;
• Pursue civil or criminal remedies as appropriate.

We will always seek to act fairly and proportionately, and where account closure or fund retention is required we will communicate with the customer to the extent that our legal obligations permit.

15. Updates to this Policy

This Policy is reviewed on a regular basis — at minimum annually — and updated as necessary to reflect changes in applicable law, regulatory guidance, our licence conditions, or our internal assessment of risk. The current version of this Policy is published on casino-dicespin.org. Continued use of casino-dicespin.org following the publication of an updated Policy constitutes acceptance of its terms. Where changes are material, we will endeavour to notify customers by the contact details held on their account.

16. Contact

If you have any questions about this Policy or about the verification process, you may contact our support team using any of the following channels:

• Live Chat: Available directly on casino-dicespin.org, powered by Intercom
• Email: Available via the Help Centre on casino-dicespin.org
• Help Centre: Self-service articles and FAQs accessible at casino-dicespin.org

This Policy is issued by AccelCore Enterprise Limitada (Costa Rica, registration number 3102926243), operator of dicespin at casino-dicespin.org, under Anjouan licence ALSI-202506031-FI2.