This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Stellar Ltd ("we", "us", "our"), operator of Spinbara Casino at spinbaraonline.org, with respect to the prevention of money laundering, terrorist financing, and other financial crime. Spinbara is licensed under the Anjouan Licensing Services International (ALSI), licence number 202412012 (FI1), and Curaçao eGaming. This Policy applies to all players registered on spinbaraonline.org and governs all transactions processed through the platform.
Money laundering is the process by which the proceeds of criminal activity are disguised to appear as legitimate funds. Terrorist financing involves the provision of funds or resources to support terrorist acts or organisations. Both activities are serious criminal offences, and Spinbara is firmly committed to ensuring that its platform is not used as a vehicle for either.
The purpose of this Policy is to:
All staff and, where applicable, third-party service providers engaged by Stellar Ltd are required to adhere to the principles contained in this Policy.
Spinbara operates under licences issued by the Anjouan Licensing Services International (ALSI), licence number 202412012 (FI1), and Curaçao eGaming. Our AML and KYC obligations are derived from the conditions attached to these licences, as well as internationally recognised standards, including the Financial Action Task Force (FATF) Recommendations.
We reserve the right to update this Policy at any time in order to remain compliant with evolving regulatory requirements or licence conditions. Material changes will be published on spinbaraonline.org, and continued use of the platform following such publication constitutes acceptance of the revised Policy.
This Policy applies to:
Spinbara requires all players to undergo identity verification before any withdrawal is processed. Players are strongly encouraged to complete the KYC process promptly after registration to avoid delays when requesting funds. KYC verification may also be triggered at any point during a player's activity, including upon deposit, during active play, or following a risk assessment flag.
We reserve the right to restrict access to the cashier, suspend an account, or withhold funds pending the satisfactory completion of KYC requirements.
Standard Customer Due Diligence requires players to provide documents sufficient to verify the following:
Players must submit one of the following valid, government-issued documents:
The document must be current (not expired), clearly legible, and must display the player's full name, date of birth, and a photograph. Documents must be submitted in colour; black-and-white copies are not accepted.
Players must provide proof of their residential address by submitting one of the following, dated within the last three (3) months:
The document must clearly show the player's full name and residential address as registered on their Spinbara account. PO box addresses are not accepted as proof of residence.
Spinbara applies a same-method withdrawal rule: withdrawals must be made using the same payment method as the deposit, where technically possible. To verify ownership of a payment method, we may request:
Enhanced Due Diligence applies in higher-risk circumstances, including but not limited to:
Under EDD, we may request additional documentation, including:
Spinbara reserves the right to decline or limit a player's activity, or to close an account, if EDD requirements cannot be satisfactorily fulfilled.
A Politically Exposed Person is an individual who holds or has held a prominent public function, including heads of state, senior government officials, senior judicial or military officials, senior executives of state-owned corporations, or senior officials of political parties. Immediate family members and known close associates of PEPs are treated with equivalent caution.
Spinbara applies enhanced scrutiny to PEP accounts and requires senior management approval before establishing or continuing a business relationship with a PEP. PEP status does not automatically result in account refusal; however, the relationship will be subject to ongoing enhanced monitoring.
Spinbara does not permit access to real-money gambling by any person under the age of 18. Age verification is a mandatory component of the KYC process. Where there is any doubt about a player's age, the account will be suspended and access to gambling features restricted until identity documentation confirming age is received and reviewed.
If it is determined that a player is underage, the account will be closed immediately, all funds will be returned (less any winnings derived during the period of underage play, which may be forfeited in line with regulatory requirements), and the matter may be reported to the relevant authority.
Documents may be submitted via the account verification portal on spinbaraonline.org or by sending them directly to our support team at [email protected]. All documents are processed securely. Spinbara uses 256-bit SSL encryption across all data transmissions, and documents are stored in accordance with applicable data protection obligations.
We aim to review and process submitted KYC documents as promptly as possible. Players will be notified of the outcome of their verification. If documents are rejected due to quality, legibility, or relevance, the player will be informed and given the opportunity to resubmit.
Spinbara adopts a risk-based approach to AML compliance. This means we assess the money-laundering risk associated with each player and each transaction proportionately, and apply controls commensurate with that assessed risk level. Lower-risk players and transactions receive standard monitoring; higher-risk scenarios trigger enhanced controls.
Risk factors considered include, but are not limited to:
All financial transactions on spinbaraonline.org are subject to automated and manual monitoring. Our compliance systems are designed to identify patterns and behaviours that may be indicative of money laundering or terrorist financing, including:
Spinbara accepts deposits and processes withdrawals in a range of cryptocurrencies, including Bitcoin, Ethereum, Litecoin, USDT, USDC, XRP, BNB, and TRX. Cryptocurrency transactions carry specific AML risks, including the potential for anonymity and the difficulty of tracing the ultimate origin of funds.
In addition to standard CDD, cryptocurrency transactions are subject to:
Spinbara reserves the right to reject or reverse cryptocurrency deposits where blockchain screening identifies an unacceptable level of risk, and to apply EDD before processing any associated withdrawal.
Spinbara operates the following standard transaction limits, which form part of our AML framework:
| Parameter | Limit |
|---|---|
| Minimum deposit | €10–€20 (varies by payment method) |
| Minimum withdrawal | €20 |
| Maximum withdrawal (standard accounts) | €20,000 per month |
| Maximum withdrawal (VIP accounts) | Higher limits available — contact support |
Transaction limits are reviewed by our compliance team and may be adjusted in response to risk assessments, regulatory guidance, or individual account activity. Requests to increase withdrawal limits beyond the standard cap will require satisfactory completion of EDD, including source of funds and source of wealth documentation.
Spinbara screens all players against applicable international sanctions lists, including those maintained by the United Nations, European Union, and other relevant authorities. Accounts found to be connected to sanctioned individuals, entities, or jurisdictions will be immediately suspended, and all associated funds will be frozen pending further investigation and reporting obligations.
Spinbara does not knowingly accept players from jurisdictions subject to comprehensive international sanctions or from territories specifically excluded under the terms of our licences.
Where our compliance team identifies activity that gives rise to a suspicion of money laundering or terrorist financing, a Suspicious Activity Report (SAR) or equivalent report will be filed with the relevant financial intelligence unit or regulatory authority as required under our licensing obligations. Spinbara is legally prohibited from disclosing ("tipping off") a player or any third party that a SAR has been filed or that an investigation is under way.
During any investigation, Spinbara may:
These measures do not constitute an admission of wrongdoing and may be lifted once the investigation is concluded satisfactorily.
Spinbara maintains records of all player identification documents, transactional data, and AML-related communications for a minimum period of five (5) years from the date of account closure or the end of the business relationship, whichever is later. Records are stored securely and are available for inspection by our licensing authorities upon request.
Records kept include:
Stellar Ltd ensures that all relevant personnel involved in the operation of spinbaraonline.org receive appropriate AML and KYC training. Training covers the identification of suspicious activity, the correct escalation procedures, record-keeping obligations, and the legal consequences of non-compliance.
A designated Money Laundering Reporting Officer (MLRO) or equivalent compliance function is responsible for overseeing the implementation of this Policy, reviewing internal suspicious activity reports, making determinations on SAR filings, and liaising with regulatory authorities as required.
This Policy is reviewed at least annually, or more frequently where significant changes in regulatory requirements, licence conditions, or business operations make an earlier review necessary.
Spinbara recognises that problem gambling can, in some instances, be associated with financial irregularities, including the use of funds derived from theft, fraud, or other criminal conduct to finance gambling activity. Our responsible gambling programme and our AML controls are therefore complementary. Where a player's financial behaviour gives rise to both a responsible gambling concern and an AML concern, both sets of procedures will be applied concurrently.
Players who display signs of gambling harm are encouraged to make use of the responsible gambling tools available on spinbaraonline.org, including deposit limits, session limits, cool-off periods, and self-exclusion.
By registering an account on spinbaraonline.org, players confirm that:
Providing false, misleading, or incomplete information during the KYC process is a serious breach of these obligations and may result in immediate account closure, forfeiture of balances, and referral to relevant authorities.
Spinbara reserves the right to close any account and to withhold associated funds where:
Where funds are withheld pursuant to this Policy, Spinbara will act in accordance with its legal obligations, which may include transferring funds to a regulatory authority rather than returning them to the player.
If you have any questions regarding this AML / KYC Policy, or if you wish to enquire about the status of your verification, please contact our compliance and support team:
When contacting us regarding a KYC matter, please include your registered username and, where applicable, the type of document you are submitting or enquiring about, to allow us to assist you as efficiently as possible.
This Policy was last reviewed in 2025 and is operated by Stellar Ltd, licence number 202412012 (FI1), issued by the Anjouan Licensing Services International (ALSI), in conjunction with Curaçao eGaming authorisation.
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