AML Policy of Curacao Co N.V.

Last updated: 15.09.2022 is operated by Alistair Solutions N.V.

For Cash Deposits and Cash Withdraws

AML Anti-Money-Laundering policy of

Introduction: is operated by Alistair Solutions N.V., with its office at Abraham de Veerstraat 9 Willemstad, Curacao. Company Registration number 155702.

Objective of the AML Policy: We seek to offer the highest security to all of our Users and Customers on, which is why a three-step account verification is implemented to ensure our customers' identity. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into account that depending on the nationality and origin, the way of payment, and withdrawal, different safety measures must be taken. also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means. is committed to high standards of anti-money laundering (AML) according to the EU guidelines and compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of is designed to be compliant with :

EU : "Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering"

EU : "Regulation 2015/847 on information accompanying transfers of funds"

EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE : "Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash"

Definition of money laundering

Money Laundering is understood as:

  • The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
  • The concealment or disguise of the true nature, source, location, disposition, movement, and rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
  • The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
  • Participation in, association to commit, attempts to commit and aiding, abetting, facilitating, and counseling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for

In accordance with the AML legislation, has appointed the "highest level" for the prevention of ML: The full management of Alistair Solutions N.V. is in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML Policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general management:

AML policy changes and implementation requirements

Each major change of's AML policy is subject to approval by the general management of Alistair Solutions N.V. and the anti-money laundering compliance officer.

Three step Verification

Step one verification:
Step one verification must be done by every User and customer to withdraw. Regardless of the choice of payment, the amount of payment, the amount of withdrawal, and the nationality of the User/Customer, step one verification must be done first. Step one verification is a document that must be filled out by the User/Customer himself. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender, and full address.

Step two verification:
Step two verification must be done by every User who deposits over 2000$ (two thousand USD), withdraws over 2000$ (two thousand USD), or sends another User over 1000$ (one thousand USD). Until step two verification is done, the withdrawal, tip, or Deposit will be held. Step to verification will lead the User or customer to a subpage where he must send in his ID. The User/Customer must take a picture of his ID. At the same time, a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification; depending on the country, the variety of accepted IDs may be different. There will also be an electronic check to see if the filled-in data from step one verification is correct. The electronic check will be checked via two different databanks to ensure the given information matches the filled document and the name from the ID. If the electronic test fails or is not possible, the User/Customer is required to send in a confirmation of his current residence. A certificate of registration by the government or a similar document is required.

Step three verification:
Step three verification must be done by every User who deposits over 5000$ (five thousand USD) or withdraws over 5000$ (five thousand USD) or sends another User over 3000$ (three thousand USD). Until step three verification is done, the withdrawal, tip or Deposit will be held. For step 3 a User/Customer will be asked for a source of wealth.

Customer identification and verification (KYC)

  • Copy of a valid photo ID (driver’s license, ID, passport). The copy should be a high-quality colored image scan or colored digital photo. The copy must not be cropped and should also include both sides and all details of the ID.
  • Copy of any credit/debit cards successfully used. The copy should be a high-quality colored image scan or colored digital photo. The copy must not be cropped and should include the cardholder’s full name, the first 6 and last 4 digits of the card number, and the expiry date.
  • Copy of Utility Bill no older than two months. The copy should be a high-quality colored image scan or colored digital photo. The copy must not be cropped and should include full name, date of issue, and full billing address.
  • Card Authentication is required only if you use your Credit/Debit Card to deposit with the casino.
  • Withdrawal Application with valid banking details aimed to ensure accurate withdrawal cashier.

Source of funds

If a player deposits over five thousand USD, there is a process of understanding the source of wealth (SOW)

Examples of SOW are:
  • Ownership of business
  • Employment
  • Inheritance
  • Investment
  • Family

It is critical that the origin and legitimacy of that wealth are clearly understood. If this is not possible, an employee may ask for an additional document or proof.

The account will be frozen if the same User deposits either this amount in one go or multiple transactions that amount to this. An email will be sent to them manually to go through the above and information on the website itself. also asks for a bank wire/credit card to further ensure the identity of the User/Customer. It also gives additional information about the financial situation of the User/Customer

Basic document for step one

The basic document will be accessible via the settings page on Every User has to fill out the following information:

  • First name
  • Second name
  • Nationality
  • Gender
  • Date of Birth

The document will be saved and created by an AI; an employee may do additional checks, if necessary, based on the situation.

Risk management

In order to deal with the different risks and different states of wealth in different regions, will categorize every nation into three different regions of risk.

Region one: Low risk

For every nation from the region, the three-step verification is done as described earlier.

Region two: Medium risk

For every nation from region two, the three-step verification will be done at lower Deposit, withdrawal, and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand USD), withdrawing 1000$ (one thousand USD) or tipping another User/Customer 500$(five hundred USD) Step three will be done after depositing 2500$ (two thousand five hundred USD), withdrawing 2500$ (two thousand five hundred USD) or tipping another User/Customer 1000$ (one thousand USD). Also, Users from a low-risk region who change the cryptocurrency to any other currency will be treated like Users/Customers from a medium-risk region.

Region three: High risk

Regions of high risk will be banned. High-risk regions will be regularly updated to keep up with the fast-changing world environment.

Additional measurements

In addition, an AI that is overseen by the AML compliance officer will look for any unusual behavior and report it right away to an employee of

According to a risk-based and general experience, the human employees will recheck all checks that are done bevor by the AI or other employees and may redo or do additional checks according to the situation.

In addition, a data scientist supported by modern, electronic, analytical systems will look for unusual behavior like depositing and withdrawing without longer betting sessions. Attempts to use a different bank account for deposit and withdrawal, nationality changes, currency changes, behavior and activity changes, as well as checks, if an account is used by its original owner.

Also, a User has to use the same method for withdraw as he used for deposit, for the amount of the initial deposit to prevent any Money Laundering.

Enterprise-wide risk assessment

As part of its risk-based approach, has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines, such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.

The identification of AML risk categories is based on understanding of regulatory requirements, regulatory expectations, and industry guidance. Additional safety measures are taken to take care of the additional risks the World Wide Web brings with it.

The EWRA is reassessed yearly.

Ongoing transaction monitoring

AML-Compliance ensures that “ongoing transaction monitoring” is conducted to detect transactions that are unusual or suspicious compared to the customer profile. This transaction monitoring is conducted on two levels:

1) The first Line of Control: works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the large majority of suspicious deposits onto from taking place without proper execution of KYC procedures on the potential customer.

2) The second Line of Control: makes its network aware so that any contact with the customer, player, or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular, these include:

- Requests for the execution of financial transactions on the account;

- Requests in relation to means of payment or services on the account.

Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of at all times.

Also, all transactions must be overseen by employees and watched by the AML compliance officer, who is overwatched by the general management.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager, must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment in relation to the knowledge of the customer (KYC), their financial behavior, and the transaction counterparty.

These checks will be done by an automated system while an Employee crosschecks them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must, therefore, rapidly be considered atypical (as they are not directly justifiable).

Any staff member must inform the AML division of any atypical transactions that they observe and cannot attribute to a lawful activity or source of income known to the customer.

3) The third Line of Control:

As the last line of defense against AML, will do manual checks on all suspicious and higher-risk Users in order to prevent money laundering fully.

If fraud or Money Laundering is found, the authorities will be informed.

Reporting of Suspicious transactions

In its internal procedures, describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, the AML team:

- will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;

- will decide whether or not it is necessary to terminate the business relations with the customer.


The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Intranet site of

Record keeping

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

These data will be safe, encrypted, and stored offline and online.

Training human employees will make manual controls on a risk-based approval for which they get special training.

The training and awareness program is reflected by its usage:

  • A mandatory AML training program in accordance with the latest regulatory evolutions for all in touch with finances
  • Academic AML learning sessions for all new employees
  • The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML specialist working for Alistair Solutions N.V. AML team.


Internal audit regularly establishes missions and reports about AML activities.

Data Security

All data given by any User/Customer will be kept secure and will not be sold or given to anyone else. Only if forced by law or to prevent money laundering data may be shared with the AML authority of the affected state. will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

Contact us

If you have any questions about our AML and KYC Policy, please contact us:

If you have any complaints about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us: