1. Introduction
Spinz Casino, operated via insidersexpeditions.com, is fully committed to preventing money laundering and the financing of terrorism. We uphold strict compliance with applicable Anti-Money Laundering (AML) laws and regulations in New Zealand and globally.
This AML Policy outlines our procedures and controls to detect, prevent, and report any suspicious activities, in line with the Financial Transactions Reporting Act 1996, the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act), and best industry practices.
2. Objectives
Our AML program is designed to:
- Prevent criminals from using Spinz Casino for money laundering or terrorist financing
- Establish and maintain robust customer identification procedures
- Monitor player activity and identify suspicious behavior
- Ensure all employees are trained in AML procedures
- Cooperate with law enforcement and regulatory bodies
3. Customer Due Diligence (CDD)
We implement Know Your Customer (KYC) processes to verify the identity of all users.
a) Identity Verification
All players must provide:
- Full name
- Date of birth
- Residential address
- Valid government-issued photo identification
- Proof of address (e.g., utility bill, bank statement)
- In some cases, a selfie or video verification may be required
b) Enhanced Due Diligence (EDD)
EDD is applied to high-risk customers or transactions, such as:
- Large deposits or withdrawals
- Use of multiple accounts or payment methods
- Players from high-risk jurisdictions
- Politically Exposed Persons (PEPs)
EDD may include source of funds verification and additional document requests.
4. Ongoing Monitoring
Spinz Casino continuously monitors player accounts for:
- Unusually high transaction volumes
- Frequent deposits and withdrawals without gameplay
- Use of multiple or third-party payment methods
- Attempts to conceal identity or avoid verification
- Irregular behavior inconsistent with player profile
Automated systems and manual reviews are used to flag suspicious activity.
5. Record Keeping
We maintain comprehensive records for all player transactions and identity verification, including:
- KYC documentation
- Deposits, withdrawals, and gameplay logs
- Communication records related to suspicious activities
All records are retained for a minimum of 7 years or longer if required by law.
6. Reporting Suspicious Activity
All suspicious transactions or behavior are reported to the appropriate regulatory authorities.
We comply with the legal obligation to report to:
- New Zealand Financial Intelligence Unit (FIU)
- Any other relevant local or international agency as required
We do not inform players when a suspicious transaction report (STR) has been filed (“tipping off” is prohibited by law).
7. Employee Training
All employees and relevant staff receive mandatory AML training, including:
- AML legal requirements and responsibilities
- Customer identification procedures
- Identifying suspicious behavior
- How and when to escalate concerns
- Confidentiality obligations
Refresher training is provided regularly.
8. Appointed AML Compliance Officer
Spinz Casino has designated an AML Compliance Officer responsible for:
- Oversight of the AML program
- Implementing procedures and internal controls
- Monitoring compliance
- Coordinating staff training
- Liaising with regulatory and law enforcement bodies
The Compliance Officer has full access to player records and transaction data.
9. Risk-Based Approach
We adopt a risk-based approach to AML compliance by:
- Conducting periodic risk assessments
- Categorizing players based on risk levels
- Adjusting CDD and monitoring accordingly
This enables efficient allocation of resources and increased scrutiny where necessary.
10. Cooperation with Authorities
Spinz Casino cooperates fully with regulatory and law enforcement authorities and responds promptly to lawful requests for information or assistance.
11. Policy Review
This AML Policy is reviewed at least annually and updated as necessary to reflect:
- Changes in laws and regulations
- Emerging money laundering risks
- Improvements in technology and monitoring systems
12. Contact Information
For questions related to this AML Policy, please contact:
Spinz Casino
444 Tristram Street, Whitiora, Hamilton 3200, New Zealand
Email: [email protected]
Website: insidersexpeditions.com