This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Betspino, operated by Cashbit Group N.V. under Curaçao eGaming licence number 157923, and the corresponding obligations of all persons who register and transact on betspino-app.nl. The Policy applies to every account, every payment method, and every transaction processed through the platform.

1. Introduction and Purpose

Betspino is committed to preventing its platform from being used, intentionally or unintentionally, for money laundering, terrorist financing, or any other financial crime. Cashbit Group N.V. operates betspino-app.nl in compliance with applicable Curaçao eGaming regulations and international AML/CFT standards derived from the Financial Action Task Force (FATF) recommendations.

The objectives of this Policy are to:

• Establish clear procedures for verifying the identity of customers before processing withdrawals and, where risk dictates, before accepting deposits;
• Detect and report suspicious activity in a timely manner;
• Ensure that funds accepted and paid out through betspino-app.nl are derived from legitimate sources;
• Protect Betspino, its customers, and the wider financial system from exposure to illicit funds;
• Comply with all conditions attached to Curaçao eGaming licence number 157923.

2. Scope

This Policy applies to:

• All registered customers of betspino-app.nl, regardless of nationality or country of residence;
• All deposit and withdrawal transactions conducted through any payment method offered on the platform, including iDEAL, Trustly, Visa, Mastercard, Skrill, Neteller, Apple Pay, Paysafecard, and all accepted cryptocurrencies (Bitcoin, Ethereum, Litecoin, USDT, Dogecoin, and XRP);
• All Cashbit Group N.V. employees, contractors, and third-party service providers who handle customer data or financial transactions on behalf of betspino-app.nl.

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.
• CFT — Countering the Financing of Terrorism: measures designed to prevent funds, regardless of their origin, from being used to finance terrorist activity.
• KYC — Know Your Customer: the process by which Betspino verifies the identity, age, and financial standing of its customers.
• CDD — Customer Due Diligence: standard identity and verification checks applied to all customers.
• EDD — Enhanced Due Diligence: additional checks applied to higher-risk customers or transactions.
• PEP — Politically Exposed Person: an individual who holds, or has held within the preceding 12 months, a prominent public function.
• Suspicious Transaction — any transaction that Betspino has reasonable grounds to suspect is related to money laundering, terrorist financing, or other criminal activity.
• MLRO — Money Laundering Reporting Officer: the designated compliance officer responsible for receiving internal suspicion reports and submitting external disclosures where required.

4. Our Legal and Regulatory Framework

Betspino is licensed and regulated by the Curaçao eGaming authority under licence number 157923, issued to Cashbit Group N.V. This licence requires the operator to maintain AML and KYC controls consistent with internationally recognised standards. Betspino additionally respects and monitors guidance issued by FATF and relevant European Union AML directives, applying those standards on a best-practice basis where they exceed the minimum requirements of the Curaçao framework.

5. Know Your Customer (KYC) Procedures

5.1 When KYC Is Required

KYC verification is mandatory before Betspino will process any withdrawal request. No first withdrawal — regardless of amount, payment method, or currency — will be released until the customer's identity has been fully verified. Betspino reserves the right to request identity documents at any point during a customer's registration or account lifetime, including before a deposit is accepted, if the account presents risk indicators.

5.2 Standard Identity Verification (CDD)

All customers are required to provide, at a minimum, the following documents:

• Proof of Identity: a clear copy of a valid, government-issued photo ID — acceptable documents include a national identity card, passport, or driving licence. The document must be current (not expired), must clearly show the customer's full name, date of birth, photograph, and document number.
• Proof of Address: a recent document confirming the customer's residential address — acceptable documents include a utility bill (gas, electricity, water, or internet), bank statement, or official government correspondence. The document must be dated within the last three months and must display the customer's full name and address.

Once these documents have been reviewed and approved by Betspino's compliance team, the account is marked as verified. Subsequent withdrawals will not require re-submission of the same documents unless Betspino has reason to believe that the previously verified information has changed or the documents have expired.

5.3 Age Verification

Betspino does not permit persons under 18 years of age to register or transact on betspino-app.nl. Age is verified as part of the standard KYC process. Where the compliance team cannot confirm a customer's age from the documents provided, access to deposit, withdrawal, and gameplay functions will be restricted until the matter is resolved. Any funds deposited by a person subsequently found to be under 18 will be returned to source and the account permanently closed.

5.4 Source of Funds and Source of Wealth

Where a customer's transaction volumes, deposit patterns, or withdrawal amounts give rise to concern, or where Enhanced Due Diligence is otherwise triggered, Betspino will request documentation confirming the source of the funds being deposited and, where applicable, the customer's broader source of wealth. Acceptable documentation includes, but is not limited to:

• Recent payslips or employment contract;
• Bank statements covering a relevant period;
• Evidence of a business income, dividend, or investment return;
• Inheritance or legal settlement documentation;
• Tax returns or accountant's letter.

Betspino will determine on a case-by-case basis what level of documentation is proportionate to the risk presented. Customers are expected to cooperate promptly with any such request. Failure to provide satisfactory documentation within a reasonable timeframe may result in the suspension of the account and the withholding of pending withdrawals pending investigation.

5.5 Cryptocurrency Transactions

Betspino accepts deposits and processes withdrawals in Bitcoin, Ethereum, Litecoin, USDT, Dogecoin, and XRP. Cryptocurrency transactions are subject to the same KYC requirements as fiat transactions. In addition, Betspino may use blockchain analytics tools to assess the risk profile of incoming and outgoing cryptocurrency transactions. Funds originating from wallets associated with illicit activity — including darknet markets, known fraudulent exchanges, or sanctioned entities — will not be accepted. Where such funds are identified after deposit, they will be frozen pending investigation and reported to the relevant authority.

5.6 Payment Method Consistency

Betspino applies a payment-method consistency principle: customers may only withdraw funds to a payment method from which they have previously deposited, or to a method that can be verified as belonging to the registered account holder. This control prevents the use of third-party accounts and reduces the risk of layering. Customers who wish to withdraw to a new or previously unused payment method may be required to provide additional verification before the withdrawal is processed.

6. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

6.1 Standard Customer Due Diligence

Standard CDD applies to all customers and consists of the identity and address verification described in Section 5.2. Betspino conducts ongoing CDD throughout the customer relationship — not solely at the point of first withdrawal — to ensure that the customer's activity remains consistent with their stated profile and that documentation remains current.

6.2 Triggers for Enhanced Due Diligence

EDD is applied when one or more of the following indicators are present:

• The customer is identified as a Politically Exposed Person (PEP) or is a close associate or family member of a PEP;
• The customer's total deposits within a defined period reach a threshold set by Betspino's compliance team;
• Withdrawal requests approach or exceed the published limits (€10,000 per week or €20,000 per month);
• Multiple accounts appear to be linked to a single beneficial owner;
• The customer is resident in or transacting from a high-risk jurisdiction as designated by FATF;
• Transaction patterns are inconsistent with the customer's stated occupation or financial profile;
• The customer exhibits behaviour characteristic of structuring — for example, making repeated deposits just below a reporting threshold;
• Any other factor that gives the compliance team reasonable grounds for concern.

6.3 Politically Exposed Persons (PEPs)

Customers identified as PEPs, or as close associates or immediate family members of PEPs, are subject to EDD as a matter of course. This includes obtaining senior management approval before establishing or continuing the business relationship, taking reasonable steps to establish the source of wealth and source of funds to be used, and conducting enhanced ongoing monitoring of the relationship. Being identified as a PEP does not automatically disqualify a customer from holding an account at betspino-app.nl, but it does require a higher level of scrutiny.

7. Ongoing Monitoring

Betspino conducts continuous monitoring of customer accounts and transactions. This monitoring includes, but is not limited to:

• Automated transaction monitoring that flags unusual deposit or withdrawal patterns;
• Regular review of customer profiles against updated sanctions lists and PEP databases;
• Periodic re-verification of identity documents where expiry dates have passed or where the customer's circumstances have materially changed;
• Review of accounts that have been dormant for an extended period before allowing renewed transactional activity;
• Monitoring of bonus activity to detect patterns indicative of bonus abuse, multi-accounting, or collusion.

Monitoring parameters are reviewed and updated by the MLRO on a regular basis to reflect changes in risk appetite, regulatory guidance, and observed industry trends.

8. Transaction Limits and Their Role in AML Controls

Betspino's published transaction limits form an integral part of its AML control framework. The following limits apply across the platform:

Withdrawal amounts exceeding €5,000 must be split across multiple transactions. Requests that, individually or cumulatively, approach or breach the weekly or monthly withdrawal limits will trigger a compliance review before funds are released. These limits apply across all payment methods, including cryptocurrency withdrawals denominated in their euro equivalent at the time of processing.

9. Suspicious Activity — Recognition and Reporting

9.1 What Constitutes Suspicious Activity

Betspino considers the following to be examples of potentially suspicious activity, without limitation:

• Deposits of large sums followed immediately by withdrawal requests with minimal or no gameplay in between;
• Repeated deposits made in amounts just below internal or regulatory reporting thresholds (structuring);
• Use of multiple payment methods or currencies in quick succession without a clear legitimate explanation;
• Customer reluctance or refusal to provide identity documents or source-of-funds documentation when requested;
• Inconsistency between the customer's stated occupation or financial profile and the volume of funds being transacted;
• Cryptocurrency deposits originating from wallets flagged by blockchain analytics as high-risk;
• Use of third-party payment methods or attempts to withdraw to accounts not belonging to the registered customer;
• Any communication or behaviour suggesting that the customer is transacting on behalf of an undisclosed third party.

9.2 Internal Reporting

Any member of Betspino's compliance, payments, or customer support teams who identifies or suspects suspicious activity must file an internal suspicion report with the MLRO without delay. Under no circumstances should the customer be informed — directly or indirectly — that a report has been made or that their account is under review. This obligation to avoid "tipping off" applies to all staff and contractors.

9.3 External Reporting

The MLRO is responsible for evaluating all internal suspicion reports and determining whether a disclosure to the relevant Financial Intelligence Unit or competent authority is required. Where such a report is filed externally, Betspino will cooperate fully with any resulting investigation, including providing transaction records, identity documents, and any other information lawfully requested by the investigating authority.

9.4 Account Restrictions During Investigation

Where suspicious activity is identified, Betspino reserves the right to:

• Suspend withdrawal processing pending the outcome of a compliance review;
• Restrict deposit functionality;
• Temporarily lock the account while verification documents are being assessed;
• Permanently close the account and return funds to their verified source where a customer is found to have breached this Policy or applicable law.

Betspino will not be liable for any loss arising from delays in processing withdrawals where those delays are attributable to a good-faith compliance investigation.

10. Sanctions Screening

Betspino screens all customers and counterparties against applicable international sanctions lists, including those maintained by the United Nations Security Council, the European Union, the United States Office of Foreign Assets Control (OFAC), and the United Kingdom's HM Treasury. This screening occurs at account registration and on an ongoing basis thereafter. Any customer found to be a designated individual or entity, or to be connected to a sanctioned party, will have their account immediately frozen. Betspino will not conduct any transaction with a sanctioned person or entity under any circumstances.

11. Record Keeping

Betspino retains all customer identification documents, transaction records, due diligence files, and internal/external suspicion reports for a minimum of five years from the date the relevant document was created or the relevant transaction was processed, or for five years following the closure of the customer's account, whichever is the later. Records are stored securely and are accessible only to authorised compliance personnel. All records will be made available to competent authorities upon lawful request.

12. Staff Training

All Cashbit Group N.V. employees and contractors who perform functions on behalf of betspino-app.nl that involve customer interaction, payment processing, or compliance oversight receive AML/CFT training appropriate to their role. Training covers the recognition of suspicious activity, internal reporting obligations, the prohibition on tipping off, and the requirements of this Policy. Training records are maintained and updated as regulatory requirements evolve.

13. Responsible Gambling and Its Relationship to AML

Betspino recognises that problem gambling and money laundering can present overlapping behavioural indicators — including erratic deposit and withdrawal patterns, rapid cycling of funds through accounts, and reluctance to engage with account verification. Betspino's responsible gambling controls, which include deposit limits, session limits, and self-exclusion tools available to all registered customers, operate in parallel with — and in support of — this AML/KYC Policy. Where a customer's activity raises concerns under both frameworks, the compliance and responsible gambling teams will coordinate their response. Customers seeking assistance with gambling-related concerns may contact our 24/7 support team via live chat or email.

14. Amendments to This Policy

Betspino reviews this Policy at least annually and following any material change in regulatory requirements, business operations, or identified risk. The current version of this Policy is published on betspino-app.nl and supersedes all previous versions. Customers are bound by the version of the Policy in force at the time of each transaction. Continued use of the platform following publication of a revised Policy constitutes acceptance of its terms.

15. Contact and Compliance Queries

Questions relating to this Policy, requests to submit identity documents, or concerns about a specific transaction should be directed to Betspino's compliance and support team via the 24/7 live chat function on betspino-app.nl, or by email at the address provided in the Help section of the platform. Dutch-language support is available around the clock. Betspino aims to respond to all compliance-related correspondence within two business days.