Rollyspin

This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Rollyspin Casino, operated by Comentive LTD under Belize licence registration number 000047924, and the standards we apply at rollyspinwin.org to detect, prevent and report financial crime. All players, accounts and transactions processed through our platform are subject to this Policy.

1. Introduction and Purpose

Rollyspin is committed to operating a safe, transparent and legally compliant online gaming environment. Money laundering — the process of concealing the origins of criminally obtained funds — and the financing of terrorism represent serious harms to society and to the integrity of the gaming industry. This Policy exists to ensure that rollyspinwin.org is not used as a vehicle for either.

Comentive LTD maintains a zero-tolerance stance toward money laundering, terrorist financing, fraud and any other financial crime. This Policy applies to every member of staff, every third-party agent acting on our behalf, and every registered player on the platform.

Our AML/KYC programme is built around four pillars:

2. Legal and Regulatory Framework

Rollyspin operates under the authority of its Belize gaming licence (Reg. No. 000047924), issued to Comentive LTD. Our compliance obligations derive from that licence, applicable Belizean legislation governing gaming and financial crime, and internationally recognised AML standards including the recommendations of the Financial Action Task Force (FATF). Where we accept players from jurisdictions with their own AML requirements, we apply standards at least as stringent as those required by the player's home jurisdiction where reasonably practicable.

This Policy is reviewed at least annually and updated whenever there is a material change to the regulatory environment, our product offering or our risk profile.

3. Designated AML Compliance Officer

Comentive LTD appoints a Money Laundering Reporting Officer (MLRO) who carries overall responsibility for this Policy. The MLRO's responsibilities include:

4. Risk-Based Approach

Rollyspin applies a risk-based approach to customer due diligence. This means that the level of scrutiny applied to any given customer or transaction is proportionate to the risk that customer or transaction poses. Factors used in our risk assessment include, but are not limited to:

Based on this assessment, each customer is categorised as low, medium or high risk. Higher-risk customers are subject to Enhanced Due Diligence (EDD) and more frequent ongoing monitoring. Lower-risk customers benefit from Simplified Due Diligence (SDD) where permitted, though a minimum level of verification always applies.

5. Know Your Customer (KYC) — Customer Due Diligence

5.1 When KYC Is Required

Rollyspin applies Know Your Customer checks at various stages of the customer relationship. KYC may be triggered by any of the following:

We state openly on rollyspinwin.org that the first withdrawal may trigger a KYC check. There are no hidden steps beyond the standard documentation described in this Policy. Once documents have been submitted and verified, processing moves forward without unnecessary delay.

5.2 Standard KYC Documentation

Standard Customer Due Diligence requires the following documents. All documents must be valid, legible, unaltered and provided in full.

Document Category Acceptable Forms Requirements
Government-Issued Photo ID Passport, national identity card, driving licence Must be current and unexpired; full name, date of birth and photo must be clearly visible
Proof of Address Utility bill, bank statement, government correspondence Issued within the last three months; must show full name and residential address
Payment Method Verification Screenshot or scan confirming ownership of the deposit method used Must confirm the player's name matches the account name; card numbers may be partially redacted for security

Where a player's account currency is not EUR, we accept documents issued in the relevant local language, though we reserve the right to request a certified translation where necessary.

5.3 Age Verification

We do not permit persons under the age of 18 to register or play at rollyspinwin.org. Age is verified as part of the standard KYC process using the government-issued photo ID described above. Where there is any doubt about a player's age, the account will be restricted until satisfactory age verification is completed. Any funds deposited by a person found to be underage will be returned and the account will be permanently closed.

5.4 Enhanced Due Diligence (EDD)

Enhanced Due Diligence applies to customers assessed as high risk. EDD may involve any or all of the following, in addition to the standard documentation set:

EDD is not a punitive measure; it is a proportionate response to elevated risk and is applied consistently across all customers who meet the relevant criteria.

5.5 Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds, or has held within the last 12 months, a prominent public function, or who is a close family member or known associate of such a person. Rollyspin screens all customers against PEP databases at registration and on an ongoing basis. PEP status automatically triggers EDD. We do not categorically refuse business with PEPs; however, senior management approval is required before a PEP account may be activated or retained.

5.6 Sanctions Screening

All customers are screened against applicable international sanctions lists — including those maintained by the United Nations, the European Union, the United Kingdom's OFSI, and the United States OFAC — at the point of registration and on a periodic basis thereafter. Any match, or potential match, against a sanctions list results in the immediate suspension of the account and an internal escalation to the MLRO. Funds will not be returned to a sanctioned individual or entity without the appropriate regulatory clearance.

5.7 Corporate and Non-Individual Accounts

Where an account is operated on behalf of a legal entity, Rollyspin requires documentation establishing the identity of the entity itself, the identity of all individuals with significant control (typically those holding 25% or more of ownership or voting rights), and the identity of the individual(s) authorised to operate the account. The same verification standards described in sections 5.2 and 5.4 apply to all relevant natural persons associated with a corporate account.

5.8 Ongoing Due Diligence

KYC is not a one-time exercise. Rollyspin monitors customer accounts throughout the duration of the relationship. We will re-verify a customer's details when:

6. Transaction Monitoring

6.1 Automated Monitoring

All transactions processed through rollyspinwin.org are subject to automated monitoring systems that flag activity deviating from expected patterns. These systems assess individual transactions and cumulative behaviour over time. Alert rules cover, among other things, large or sudden changes in deposit volume, rapid cycling of funds through the cashier with minimal play, and the use of multiple payment methods in quick succession.

6.2 Deposit and Withdrawal Limits as a Control Mechanism

The transaction limits published on rollyspinwin.org serve both player-protection and AML purposes. The current limits are set out below for reference.

Limit Type EUR GBP BRL NOK
Minimum Deposit €20 £20 R$100 200 NOK
Maximum Single Deposit €4,000 Equivalent Equivalent Equivalent
Minimum Withdrawal €40 £40 R$200 400 NOK
Daily Withdrawal €2,000 £1,500 R$10,000 20,000 NOK
Weekly Withdrawal €5,000 £4,000 R$25,000 50,000 NOK
Monthly Withdrawal €15,000 £12,000 R$75,000 150,000 NOK

VIP players at Gold tier and above may, in agreement with their dedicated VIP Manager, negotiate higher withdrawal limits. Any such increase is only authorised following a satisfactory review of the player's KYC documentation and, where appropriate, source of funds evidence. Progressive jackpot wins are paid in full irrespective of the monthly withdrawal cap; such payments are subject to enhanced AML review prior to processing.

6.3 Deposit Wagering Requirement

All deposits — including those made without any active bonus — are subject to a x3 wagering requirement before a withdrawal can be processed. This requirement exists to ensure funds flow through the platform in a manner consistent with genuine gambling activity and to reduce the risk of the cashier being used for money-cycling purposes.

6.4 Cryptocurrency Transactions

Rollyspin accepts Bitcoin for both deposits and withdrawals. Cryptocurrency transactions carry specific AML considerations, including the pseudonymous nature of blockchain addresses. We apply the following controls to all cryptocurrency transactions:

6.5 Red Flags and Indicators of Suspicious Activity

The following behaviours, among others, may indicate money laundering or other financial crime and will be escalated for review:

7. Suspicious Activity Reporting

Where Rollyspin's compliance team or MLRO identifies, or has reasonable grounds to suspect, that a customer's funds are derived from criminal activity or that a transaction may constitute money laundering or terrorist financing, a Suspicious Activity Report (SAR) will be filed with the appropriate financial intelligence unit or competent authority without undue delay.

Crucially, we will not "tip off" the customer — that is, we will not inform the player that a report has been made or is being considered. Accounts subject to an active SAR investigation may be suspended, and funds may be withheld, without detailed explanation being provided to the account holder. This is a legal obligation, not a discretionary act.

Internal reports of suspicious activity may be submitted to the MLRO by any member of the Rollyspin compliance or customer support team. All such reports are treated confidentially.

8. Record Keeping

Rollyspin retains all KYC documentation and transaction records for a minimum of five years from the date on which the relevant customer relationship ends, or from the date of the relevant transaction, whichever is the later. Records retained include:

All records are stored securely. Access is restricted to authorised personnel only and is subject to audit logging. Records are available for production to the licensing authority, law-enforcement agencies or other competent authorities upon lawful request.

9. Staff Training

All employees and contractors of Comentive LTD who interact with customers, process transactions or have access to player account data are required to complete AML/KYC training before taking up their role and at regular intervals thereafter. Training covers:

Training records are maintained by the MLRO and are available for inspection by regulators.

10. Multi-Currency and Multi-Jurisdiction Considerations

Rollyspin supports 17 fiat currencies alongside Bitcoin. Customers transacting in GBP, BRL, NOK, EUR and other supported currencies are all subject to the same underlying AML/KYC standards, applied consistently. The equivalent thresholds in each currency are calculated at the prevailing exchange rate applicable at the time of the transaction and are reviewed periodically to ensure they remain proportionate.

Where a player is resident in a jurisdiction that applies stricter AML requirements than those set out in this Policy, we will seek to apply the higher standard. Certain jurisdictions are classified as high-risk by FATF or are subject to enhanced international scrutiny; players from such jurisdictions are automatically subject to EDD, regardless of any other risk indicators.

11. Account Restrictions, Suspension and Closure

Rollyspin reserves the right to restrict, suspend or permanently close any account where:

Where an account is closed for AML-related reasons, funds held in the account may be withheld pending the outcome of any investigation or the satisfaction of any regulatory or law-enforcement obligation. We are not obliged to provide detailed reasons for a restriction or closure where doing so would constitute tipping off.

12. Bonus Abuse and Financial Crime

Rollyspin's bonus structure — including the five-deposit welcome package, weekly promotions and VIP cashback — is designed for genuine players. Systematic exploitation of bonuses, particularly where combined with minimal genuine play or rapid fund cycling, may indicate activity that is not consistent with lawful gambling. Such behaviour may be treated as suspicious activity for AML purposes in addition to constituting a breach of our promotional terms.

Players whose bonus-to-deposit ratio exceeds 50% after eight deposits may have their VIP status suspended pending review. This threshold exists partly as a responsible-gaming and fairness measure and partly as an indicator that the account may warrant enhanced scrutiny.

13. Responsible Gambling and AML — the Connection

Problem gambling and money laundering are distinct concerns, but our monitoring systems address both simultaneously. Unusual transaction patterns that may indicate financial crime often overlap with patterns associated with disordered gambling. Where a player's behaviour raises concerns under both frameworks, our obligations under each will be addressed separately and concurrently. Players seeking help with gambling-related issues are encouraged to contact our 24/7 Live Chat support team or to make use of the responsible-gambling tools available within their account settings at rollyspinwin.org.

14. Contact and Complaints

Questions regarding this Policy, or requests for information about how your personal data is used in connection with AML/KYC processes, should be directed to our compliance team via the following channels:

Players who believe a KYC decision has been applied incorrectly to their account are entitled to raise a formal complaint. Complaints will be acknowledged promptly and investigated by a member of the compliance team independent of the original decision. The outcome of any complaint will be communicated in writing.

15. Policy Updates

This AML/KYC Policy is subject to periodic review by the MLRO and senior management of Comentive LTD. Updates will be published at rollyspinwin.org and will take effect from the date of publication. Continued use of the platform following an update constitutes acceptance of the revised Policy. Players are encouraged to review this page periodically to remain informed of our current compliance standards.

Last reviewed: 2025. Operated by Comentive LTD, Belize Licence Reg. No. 000047924.