Anti-Money Laundering (AML)
and Know Your Customer (KYC)
Policy
A. Purpose & Legal Basis
PALASINO MALTA Limited (the “Operator”) maintains a zero-tolerance approach toward financial crime.
As a Malta-licensed gaming operator regulated by the Malta Gaming Authority, the Operator is bound by:
- Prevention of Money Laundering Act (Chapter 373)
- Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR)
- FIAU Implementing Procedures – Part II (Remote Gaming Sector)
- Applicable EU AML Directives
This Policy outlines the controls implemented to mitigate financial crime risks.
B. Identity Verification
To protect the integrity of the platform and ensure compliance with MGA licensing conditions, all users must undergo identity verification. This process requires the submission of:
- Government-issued identification documents, such as passports, national identity cards, or driver’s licenses
- Verification of full name, date of birth, and residential address.
Where necessary, third-party verification services may be employed to confirm the authenticity of documents. Verification ensures that users meet the legal age requirement for gambling and prevents unauthorized or fraudulent accounts.
C. Source of Funds and Transaction Screening
We implement procedures to ensure that all funds deposited and wagered on our platform are from legitimate sources:
- Users may be asked to provide proof of funds (e.g., bank statements, salary slips, or financial statements)
- Transactions are assessed for unusual patterns or inconsistencies with the user’s profile or account history
- Deposits, withdrawals, and high-value transactions may be temporarily suspended pending verification
CTF procedures are also applied to screen users against sanctioned parties and terrorist financing risk lists, ensuring that the platform is not used for illegal purposes.
D. Ongoing Monitoring & Behavioural Analysis
The Operator utilises monitoring tools designed to detect:
- Abnormal wagering cycles
- Unusual withdrawal requests
- Dormant-to-active risk transitions
- Indicators of third-party account use
- Potential fraud or identity misuse
Monitoring is continuous and risk-sensitive.
E. Cooperation with Competent Authorities
The Company fully cooperates with MGA and other regulatory and law enforcement authorities:
Suspicious activity reports (SARs) are submitted promptly in accordance with applicable AML and CTF regulations to the Financial Intelligence Analysis Unit (FIAU) Malta.
Data and information may be shared with regulators, law enforcement, or financial intelligence units, as required by law.
The Company complies with all requests related to investigations of financial crime, fraud, or illegal gambling activities.
F. Risk-Based Customer Assessment and Periodic Reporting
The Operator adopts a structured risk assessment methodology, evaluating:
- Customer risk
- Geographic risk
- Product risk
- Transactional risk
- Delivery channel risk
Each customer is assigned a risk profile upon registration and reassessed throughout the relationship.
G. User Obligations
All users are required to:
- Provide accurate and complete personal information during account registration
- Update their information promptly if any details change
- Provide documentation or information requested for AML/KYC verification
Failure to comply with AML/KYC requirements may result in account suspension, denial of transactions, or account closure, consistent with MGA licensing requirements.
H. Privacy and Data Protection
All personal and financial information collected for AML/KYC purposes is handled in accordance with our Privacy Policy and applicable data protection standards, including GDPR, ISO/IEC 27701, and other applicable regulations. Data is stored securely and shared only with authorized parties for compliance purposes. Measures ensure the confidentiality, integrity, and appropriate retention of personal information, in line with MGA expectations.
KYC and AML records will be retained for at least five (5) years from the date a business relationship ends or the last transaction occurs, in line with MGA’s AML/CTF obligations.
I. Staff Training and Internal Controls
Company staff undergo regular training in AML, CTF, and KYC procedures, including identification of suspicious transactions and proper escalation processes. Internal controls, documentation, and audit trails are maintained to ensure regulatory compliance and adherence to MGA requirements.
J. Policy Updates
The Company reserves the right to update this AML/KYC Policy to reflect changes in legislation, MGA regulations, industry standards, or operational procedures. Updated versions will be made available through the Services and communicated to users as appropriate.