This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy applies to all players registered at spiny-rush.nl, operated by Comentive LTD, Belize, and licensed under the Anjouan Gaming authority (Comoros), licence reference ALSI-202505024-FI1. spinyrush is committed to preventing financial crime, protecting the integrity of its platform, and fulfilling all obligations imposed by its regulatory framework. All customers, transactions, and accounts are subject to the procedures described below.

1. Purpose and Scope

spinyrush operates spiny-rush.nl as a licensed online casino. The purpose of this policy is to establish clear, enforceable procedures that:

• Prevent the platform from being used as a vehicle for money laundering, terrorist financing, or other financial crime;
• Verify the identity of all customers before processing deposits, withdrawals, or significant account activity;
• Ensure that funds wagered and withdrawn on spiny-rush.nl originate from legitimate sources;
• Satisfy the requirements of spinyrush's Anjouan Gaming licence (ALSI-202505024-FI1) and applicable international AML standards.

This policy applies to every registered account on spiny-rush.nl, regardless of nationality, loyalty level, or payment method used. By registering and using the platform, all customers expressly agree to cooperate fully with all KYC and AML procedures described herein.

2. Legal and Regulatory Framework

spinyrush conducts its operations under licence ALSI-202505024-FI1 issued by the Anjouan Gaming authority (Comoros). Our AML and KYC procedures are designed to meet or exceed the standards outlined by:

• The Financial Action Task Force (FATF) Recommendations on combating money laundering and terrorist financing;
• The Anjouan Gaming regulatory requirements applicable to our licence;
• Internationally recognised best practices for responsible online gaming operations.

Comentive LTD, as the corporate operator of spiny-rush.nl, bears ultimate responsibility for ensuring that these procedures are implemented, maintained, and regularly reviewed.

3. Definitions

• AML (Anti-Money Laundering): The set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.
• KYC (Know Your Customer): The process by which spinyrush verifies the identity of its customers and assesses potential risks of illegal activity.
• Customer Due Diligence (CDD): The collection and assessment of information about a customer's identity, source of funds, and transactional behaviour.
• Enhanced Due Diligence (EDD): A higher level of scrutiny applied to customers or transactions that present elevated risk indicators.
• Politically Exposed Person (PEP): An individual who holds or has held a prominent public position, or who is closely associated with such a person, and therefore presents a higher potential risk for bribery and corruption.
• Suspicious Activity: Any transaction, behaviour, or pattern that appears inconsistent with a customer's stated profile or that raises reasonable grounds to suspect money laundering or fraud.
• Source of Funds (SoF): The origin of the specific funds deposited or wagered on spiny-rush.nl.
• Source of Wealth (SoW): The means by which a customer has accumulated their overall financial assets.

4. Customer Registration and Account Eligibility

To create an account on spiny-rush.nl, every applicant must:

• Be at least 18 years of age or the legal gambling age in their jurisdiction of residence, whichever is higher;
• Register using accurate, truthful personal information, including full legal name, date of birth, residential address, and valid contact details;
• Not be a resident of any jurisdiction where online gambling is prohibited;
• Not be self-excluded from spiny-rush.nl or any connected platform;
• Act on their own behalf and not as an agent or nominee for any third party.

spinyrush reserves the right to decline any application for registration without providing a reason where we have reasonable grounds to believe that acceptance would conflict with our AML or KYC obligations.

5. KYC Verification Procedures

5.1 Standard Verification (Identity)

All customers are required to complete identity verification. The following documents are accepted as proof of identity (one required):

• Valid government-issued passport;
• National identity card (front and back);
• Government-issued driving licence with photograph (front and back).

Documents must be current (not expired), clearly legible, and display the customer's full name, date of birth, and photograph. Digital copies, scans, or photographs of documents are accepted provided they are of sufficient quality for review.

5.2 Proof of Address

Customers are required to provide documentary evidence of their current residential address. Accepted documents (issued within the preceding three months) include:

• Utility bill (gas, electricity, water, or landline telephone);
• Bank statement or official correspondence from a regulated financial institution;
• Government-issued correspondence or tax document;
• Official tenancy agreement.

The document must clearly show the customer's full name and residential address as registered on their spiny-rush.nl account. PO box addresses are not accepted as proof of residential address.

5.3 Payment Method Verification

spinyrush requires that all payment methods used on spiny-rush.nl are registered in the account holder's own name. Third-party deposits are strictly prohibited. To verify ownership of a payment method, we may request:

• A photograph or screenshot of the payment card (with the middle eight digits obscured and the CVV concealed), showing the cardholder name;
• A recent bank statement confirming the account holder's name and the account number corresponding to the SEPA or bank transfer used;
• Confirmation screenshots from digital payment services such as Revolut, Apple Pay, or Google Pay, showing the account holder's name.

Any payment method that cannot be verified as belonging to the account holder will be suspended from use on that account, and associated funds may be held pending investigation.

5.4 Source of Funds and Source of Wealth

spinyrush may request documentation evidencing a customer's source of funds and/or source of wealth in the following circumstances:

• Where cumulative deposits exceed thresholds determined by our internal risk framework;
• Where transaction patterns are inconsistent with the customer's stated profile;
• Where a customer is identified as a PEP or close associate of a PEP;
• Where automated or manual monitoring raises a flag for suspicious activity;
• Where a large single withdrawal is requested that has not previously been subject to SoF review.

Documents accepted as evidence of source of funds include, but are not limited to:

• Recent payslips or employment contracts confirming salary;
• Business accounts or self-assessment tax returns for self-employed customers;
• Dividend or investment statements;
• Documentation of an inheritance, property sale, or other one-time financial event;
• Pension statements.

Failure to provide satisfactory source of funds documentation within the timeframe specified in any request will result in account suspension and, where applicable, the withholding of pending withdrawals pending investigation.

5.5 Timing of Verification

spinyrush applies a risk-based approach to the timing of full KYC verification. However:

• Full identity verification must be completed before any withdrawal is processed;
• Verification may be requested at any point during a customer's lifecycle on spiny-rush.nl, including prior to the first deposit where risk factors are present;
• Enhanced or repeat verification may be requested when account activity materially changes or when periodic review is triggered by our internal controls.

Withdrawals will not be processed until all required KYC documentation has been submitted and approved. This applies regardless of the payment method, withdrawal amount, or loyalty level of the customer.

6. Risk-Based Approach and Customer Risk Assessment

spinyrush categorises customers according to a risk-based framework. The level of due diligence applied to any individual account reflects that customer's assessed risk profile. Factors considered in risk assessment include, but are not limited to:

• Country of residence and associated jurisdictional risk;
• Deposit frequency, amounts, and payment methods used;
• Withdrawal patterns relative to deposit history;
• Identification as a PEP or association with a sanctioned individual or entity;
• Inconsistencies between stated profile information and observed transactional behaviour;
• Nature of games played and whether bonus activity is consistent with normal customer behaviour.

Customers assessed as higher risk will be subject to Enhanced Due Diligence (EDD), which may include requests for additional documentation, more frequent periodic review, and closer transactional monitoring. spinyrush reserves the right to restrict, suspend, or close any account where EDD requirements are not met to our satisfaction.

7. Politically Exposed Persons (PEPs) and Sanctions Screening

spinyrush screens all customers against relevant PEP lists and international sanctions databases at the point of registration and on an ongoing basis thereafter. A customer identified as a PEP, or as a close family member or known associate of a PEP, is automatically subject to Enhanced Due Diligence. This includes:

• Senior management approval prior to establishing or continuing a business relationship;
• Mandatory source of funds and source of wealth documentation;
• Ongoing, enhanced transactional monitoring for the duration of the relationship.

Where a customer is identified on a sanctions list maintained by any internationally recognised authority, spinyrush will freeze the account, suspend all transactions, and take appropriate action in compliance with applicable obligations, including reporting to relevant authorities where required.

8. Transaction Monitoring

spinyrush operates ongoing automated and manual monitoring of customer transactions across spiny-rush.nl. Our monitoring procedures are designed to detect patterns or individual transactions that may indicate:

• Structuring — the deliberate splitting of deposits or withdrawals to avoid verification thresholds;
• Rapid deposit-withdrawal cycles with minimal gameplay in between;
• Deposits that significantly exceed the customer's established spending profile without explanation;
• Use of multiple payment methods in ways inconsistent with normal account use;
• Transfers or activity that appear designed to obscure the origin or destination of funds;
• Unusually large single transactions relative to the account's history.

spinyrush notes that deposited funds must be wagered at least three times (x3) before a withdrawal can be processed. Accounts where deposits are made and withdrawal requested with minimal or no gameplay may be flagged and held for review, and the applicable processing cost deducted where the x3 wagering requirement has not been met.

Where suspicious activity is identified, the relevant account will be flagged for internal review. spinyrush reserves the right to place a hold on funds, suspend withdrawal processing, and report the matter to the appropriate authorities without notifying the customer (so as not to engage in tipping-off).

9. Withdrawal Controls and Payment Integrity

The following withdrawal controls apply on spiny-rush.nl and form part of our AML framework:

Withdrawals are paid using the same method as the deposit wherever technically possible and permitted by the payment provider. This ensures a consistent and auditable trail between funds deposited and funds withdrawn. Where a payment method does not support withdrawals, spinyrush will request additional verification before processing via an alternative method.

Accepted withdrawal methods on spiny-rush.nl are Visa/Mastercard, Bank Transfer/SEPA, Revolut, and Apple Pay, with a minimum withdrawal of €40 per transaction.

10. Suspicious Activity Reporting

spinyrush maintains internal procedures for the escalation and reporting of suspicious activity. Our designated compliance function is responsible for:

• Receiving and reviewing internal reports of suspicious or unusual account behaviour;
• Determining whether activity meets the threshold for external reporting to the relevant authority;
• Filing Suspicious Activity Reports (SARs) or equivalent notifications as required under our regulatory obligations;
• Maintaining confidentiality throughout the reporting process — customers must not be informed that a SAR has been or may be filed (tipping-off prohibition).

All staff and system operators with access to customer account data are trained to recognise red flags and to escalate concerns through the correct internal channels without delay.

11. Record Keeping

spinyrush retains all KYC documentation, transaction records, and related compliance records for a minimum period consistent with the requirements of our Anjouan Gaming licence and applicable AML standards. This includes:

• Copies of all identity and address verification documents submitted by customers;
• Records of all deposit and withdrawal transactions, including method, amount, date, and outcome;
• Internal risk assessments and the outcomes of enhanced due diligence reviews;
• Records of any suspicious activity reports filed and the actions taken;
• Communication records with customers relating to KYC requests.

Retained records are stored securely and are accessible to regulatory authorities upon lawful request. Customer data is handled in accordance with spinyrush's Privacy Policy.

12. Responsible Gaming and AML Interaction

spinyrush recognises that problem gambling and financial crime can intersect. Customers exhibiting signs of disordered gambling behaviour — including rapidly escalating deposit volumes, attempts to recover losses through larger bets, or distress in communications — may also be subject to source of funds review if the amounts involved exceed their established profile.

spinyrush offers the following responsible gaming tools on spiny-rush.nl, which complement our AML controls by providing customers with means to manage their activity:

• Deposit limits;
• Session limits;
• Self-exclusion options;
• Reality checks.

Where a self-exclusion is in place, the account is locked and no deposits, withdrawals, or gameplay are permitted. Any attempts to circumvent a self-exclusion will be treated as a compliance matter.

13. Bonus Activity and AML Considerations

spinyrush offers a range of promotional bonuses, including a five-deposit welcome pack of up to 425% in matched funds, €5,500 in bonus money and 525 free spins, as well as ongoing weekly promotions and automatic cashback at rates between 5% and 20%. All bonus activity on spiny-rush.nl is subject to the following AML considerations:

• Bonuses are issued exclusively to verified, legitimate customers. Accounts under KYC review or with outstanding documentation requests will not have bonuses activated until verification is satisfactorily completed;
• Bonus abuse — including the creation of multiple accounts to claim welcome offers, collusion, or the use of false information to obtain promotional benefits — constitutes fraudulent activity and will result in account closure, forfeiture of any bonus funds, and reporting to the relevant authority where appropriate;
• Wagering requirements attached to all bonuses (x35 on welcome bonus funds and free spin winnings; x35 on reload promotions; x10 on weekly cashback) must be completed using the customer's own, legitimate funds;
• Cashback is calculated on the basis of net position (deposits minus withdrawals minus remaining balance multiplied by the applicable cashback percentage). Any attempt to manipulate this calculation through structured play is treated as suspicious activity.

14. Staff Training and Internal Controls

Comentive LTD ensures that all personnel involved in the operation of spiny-rush.nl who have access to customer accounts, transaction data, or compliance-sensitive information receive appropriate training in:

• Recognising the indicators of money laundering and financial crime in an online gaming context;
• Understanding the KYC procedures described in this policy and applying them consistently;
• Correctly escalating suspicious activity through internal channels;
• Maintaining the confidentiality of compliance investigations and SAR processes.

Training is reviewed and updated on a regular basis to reflect changes in regulatory guidance, emerging criminal typologies, and developments in payment technology relevant to spiny-rush.nl.

15. Policy Review

This AML/KYC Policy is reviewed at least annually, or sooner in the event of material regulatory change, a significant compliance incident, or a change in the operational structure of spiny-rush.nl. The most current version of this policy is published on spiny-rush.nl and supersedes all previous versions.

16. Contact and Escalation

Customers with questions about identity verification, document requirements, or the status of a KYC review should contact the spinyrush compliance and support team through the following channels:

• Live chat: Available 24 hours a day, 7 days a week via spiny-rush.nl;
• Email: [email protected]

Where a customer believes that their account has been incorrectly suspended or that a compliance decision has been made in error, they may submit a formal complaint in writing to the email address above, marked for the attention of the Compliance Department. spinyrush will acknowledge all written complaints and respond with a full explanation of the decision within a reasonable timeframe.