Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy.

1. Introduction.

Spinx Club, a luxury crypto casino launched in June 2025, is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance and ethical conduct. This policy outlines our internal procedures to prevent our platform from being used for illicit financial activities, including money laundering and terrorism financing in cryptocurrency transactions.

2. Objective.

To detect, prevent, and report any attempts of money laundering or terrorism financing through Spinx Club’s operations, particularly in cryptocurrency transactions, while protecting user trust and ensuring the continuity of our luxury gaming platform.

3. Scope.

This policy applies to:

• All users of Spinx Club
• All employees, contractors, and partners involved in our operations
• Any third parties affiliated with our platform, including technology vendors and marketing affiliates

4. Regulatory Compliance.

We commit to comply with applicable AML/CTF laws under our Anjouan gaming license and adhere to international standards, including FATF guidelines (e.g., Travel Rule for crypto transactions). We cooperate with authorities in all jurisdictions where we operate and with partners to ensure compliance with their local regulations.

5. Risk-Based Approach.

We adopt a risk-based approach to assess users, transactions, and regions for AML/CTF exposure, including:

• User profiling to identify high-risk individuals, including Politically Exposed Persons (PEPs).
• Transaction monitoring thresholds (e.g., crypto deposits/withdrawals above $1,000).
• High-risk country flagging (per FATF grey/black lists, e.g., UAE, North Korea).
• Screening crypto addresses for potential links to illicit activities through internal processes, with a commitment to adopt industry-standard blockchain analytics tools as our platform scales.

6. Know Your Customer (KYC).

We conduct KYC for all users at signup, first deposit, or upon reaching a $1,000 cumulative deposit and for those exhibiting suspicious activity, including:

• Identity verification using government-issued IDs (e.g., passport).
• Address verification via utility bills or bank statements.
• Enhanced Due Diligence (EDD) for high-risk users, including Source of Funds (SoF) checks.

KYC data may be collected using trusted third-party providers.

7. Ongoing Monitoring.

We monitor:

• Unusual transaction patterns (e.g., rapid crypto deposits followed by immediate withdrawals).
• High-volume crypto transactions.
• Multiple account creation from the same IP/device, including affiliate referrals.
• Deposit/withdrawal behaviors inconsistent with user profiles.

Suspicious activity may lead to account suspension pending investigation within 48 hours and will be reported to competent authorities if confirmed.

8. Record Keeping.

All KYC documents, transaction logs (including crypto transactions), monitoring records, and STR filings are maintained securely on encrypted servers for a minimum of 5 years, as mandated by our Anjouan license.

9. Reporting Obligations.

Suspicious transactions are internally flagged and reviewed by our compliance team. If confirmed, a Suspicious Transaction Report (STR) will be filed with the relevant authorities under our Anjouan license or as required by international regulations (e.g., FATF).

10. Employee Training.

All employees and relevant third-party contractors involved in financial, compliance, or customer operations undergo AML/CTF training upon onboarding, with annual refreshers. Training covers new threats, crypto-specific typologies (e.g., layering via gaming), and legal changes.

11. Privacy & Data Protection.

All AML/CTF procedures comply with data privacy laws, including GDPR for EU users. User information is collected with consent, securely stored, and access is limited to authorized personnel only.

12. Policy Review.

This policy will be reviewed and updated annually by our compliance officer, with the first review scheduled for June 2026, or sooner in case of regulatory changes.

13. Partnership Due Diligence.

Spinx Club conducts due diligence on all partners, including third-party payment gateways, to ensure they comply with their local AML/CTF regulations. We collaborate with partners to share necessary data for compliance purposes while maintaining user privacy.