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AML Policy


1.1. We aim to provide top-tier security for all users of, achieved through regular account verification of our customers. This process ensures the accuracy of registered user details and verifies that deposit methods are legitimate, preventing misuse or theft by unauthorized parties. This initiative aligns with the broader framework established with in combating money laundering (ML). implements sensible measures to manage and mitigate the risk of money laundering, including allocating suitable resources and controls.

1.2. is dedicated to upholding stringent anti-money laundering (AML) regulations, mandating that both management and employees strictly adhere to these standards to prevent the misuse of its services for money laundering activities.

1.3.'s AML program is structured to adhere to:

1.3.1. Commission Delegated Regulation (EU) 2018/1108 on Central Contact Points

1.3.2. Commission Delegated Regulation (EU) 2019/758 on Measures for Group present in Certain Third Countries.

1.3.3. Commission Delegated Regulation (EU) 2016/1675 on High-Risk Third Countries.

1.3.4. Directive (EU) 2015/849 – Fourth Anti-Money Laundering Directive

1.3.5. Regulation (EU) 2015/847 – Information accompanying Transfer of Funds

1.3.6. Directive 2005/60/EC – Third Anti-Money Laundering Directive

1.3.7. 2006/70/EC – Implementation Directive

1.3.8. Regulation (EC) 1781/2006

1.3.9. Directive (EU) 2018/843 – Fifth Anti-Money Laundering Directive

1.3.10. National Ordinance on the reporting of unusual transactions (LMOT)

1.3.11. Appointment of the GCB as the AML/CFT supervisor for the LMOT for the gaming industry

1.3.12. Rules for Reporting Unusual Transactions PB 2020, 157

1.3.13. Indicators for recognizing unusual transaction PB 2015, 73

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


Money Laundering is understood as:

2.1. 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.

2.2. The concealment or disguise of the true nature, source, location, disposition, movement, or 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 an activity.

2.3. 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.

2.4. Participation in, association to commit, attempts to commit and aiding, abetting, facilitating, and counsel the commission of any of the actions referred to in points before.

2.5. 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.


3.1. Formal customer identification upon entering commercial relationships is crucial for compliance with anti-money laundering regulations and Know Your Customer (KYC) policies.

To complete our verification checks, we may ask you to provide us with:

National identity card, Passport, or driver's license, along with a recent utility bill (such as gas, electric, council tax, bank, or building society statement), dated within the last six months;

Proof of ownership of the payment method used for deposits. This may vary depending on the deposit method and could include a copy of the credit card used, a screenshot of the e-wallet, or a recent bank statement.

* We may additionally request any other documents that we deem necessary to complete our verification process.

3.2. Below are potential indicators, or "red flags," that employees should consider when assessing transactions for potential money laundering:

3.2.1. Uncooperative customers in completing Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD) procedures.

3.2.2. Attempts by customers to register multiple accounts with

3.2.3. Deposits of significant amounts via multiple prepaid cards within a single session.

3.2.4. Deposits exceed typical betting patterns by a considerable margin.

3.2.5. Small wagers despite significant deposits, followed by requests for withdrawals well beyond any winnings.

3.2.6. Frequent deposit and withdrawal requests without reasonable explanation.

3.2.7. Noticeable changes in a customer's gaming activity, particularly in transaction volumes.

3.2.8. Inquiries about transferring funds between accounts within the same gaming group.

3.2.9. Transactions disproportionate to the customer's known wealth, income, or financial situation.

3.2.10. Suspicious behavior observed during high-risk gameplay.

In addition, you might be required to provide information concerning the origin of your funds and wealth. This entails providing a declaration of your source of wealth and any corroborating documents verifying the declared source, such as bank statements and payslips. We reserve the right to suspend further deposits and withdrawals and to lock your account if you do not comply with our request for the necessary information and documentation.

Under certain circumstances, we may need to reach out to you and request additional information to complete the verification process. At any time, you may be asked to provide a live photo of yourself holding the identification documentation. If our checks cannot be completed using the provided identification documentation, we may request a notarized ID or an equivalent certified ID as per the applicable law in a certain jurisdiction. Until we receive satisfactory information, we may restrict any activity related to your account. Additionally, if we suspect deliberately incorrect information or if there are concerns regarding money laundering or terrorist financing, we reserve the right to retain any deposited funds following the closure of your account.

By accepting these terms, you give us permission to conduct necessary checks to verify your identity and contact information to prevent money laundering. Furthermore, we retain the right to postpone or withhold any payments to or from your account until we are content with our verification process.

3.3. Identifying Politically Exposed Persons and Sanctioned individuals

Handling Politically Exposed Persons (PEPs) and sanctioned individuals on website involves implementing stringent compliance and due diligence measures. Here is a detailed description of this measures taken by our Risk/Compliance Team:

3.3.1. Customer Due Diligence (CDD)

Implemented robust KYC procedures aimed to collect and verify personal information of all customers at the time of registration. This includes, but not limited to full name, date of birth, address, and identification documents.

3.3.2. Enhanced Due Diligence (EDD)

Apply EDD for high-risk customers, including PEPs and sanctioned individuals. This involves more detailed background checks and continuous monitoring.

3.3.3. Screening, which may includes:

- PEPs and Sanctions Lists: Regularly update and use databases of PEPs and sanctioned individuals. These can include lists from global organizations like the United Nations, OFAC (Office of Foreign Assets Control), and national government sanctions lists;
- Third-Party Services: Employ third-party services or software solutions specializing in PEP and sanction screenings to automate and streamline the process.


4.1. reserves the right to monitor all player transactions on our Website to prevent money laundering and other unlawful activities. It is strictly forbidden to utilize the Website and its systems for facilitating any form of illegal money transfer. The website must not be used for engaging in any unlawful, fraudulent, or prohibited activities, including but not limited to money laundering or financing terrorism.

4.2. reserves the right to notify pertinent authorities, as well as other online service providers, banks, credit card companies, or other institutions, including financial institutions about your identity and any suspected unlawful, fraudulent, or improper activities.

4.3. Given's commitment to anti-money laundering and combating the financing of terrorism, you acknowledge that:

4.3.1. the details, including name and address, provided when opening your account are accurate;

4.3.2. you are the legal owner of the funds deposited into your account at any time;

4.4. AML compliance mandates the implementation of continuous transaction monitoring to identify transactions that deviate from the established customer profile and appear unusual or suspicious. If there is suspicion that you are involved in fraudulent, unlawful, or improper activities, such as money laundering or terrorism financing, or if you violate our Terms & Conditions, your access to the Website will be immediately terminated, and your account may be blocked. In such cases, we reserve the right to withhold all funds in the relevant account(s). Any suspicious account activity might be a subject of investigation, depending on the findings. 

Based on the findings of this examination and the information collected, the AML team will determine whether it is necessary to submit a SAR (Suspicious Activity Report) to the FIU, as mandated by the legal obligations outlined in the Law of 18 September 2017.

Any activity report must be submitted in writing (either manually or electronically) to the AMLCO using the provided disclosure form. This report should contain comprehensive details, including but not limited to:

4.4.1. Complete information regarding the individuals involved.

4.4.2. Detailed description of the nature of their involvement.

4.4.3. Identification of the types of money laundering activities observed.

4.4.4. Dates of the suspected activities.

4.4.5. Status of the transactions—whether they have occurred, are ongoing or are imminent.

4.4.6. Locations where the activities occurred.

4.4.7. Methods used to undertake the activities.

4.4.8. Amount of money involved.

4.4.9. Rationale for Suspicion.

4.4.10. Inclusion of all relevant supporting documentation available to the Employee or Consultant to aid the MLRO in making informed decisions on how to proceed.

By accepting the Terms of Conditions, you grant authorization to to conduct verification checks as necessary, either at our discretion or as requested by third parties, to confirm these details (referred to as "Checks"). Further to this, you acknowledge that upon our request, you may need to provide further information regarding any previously supplied details, including those concerning deposits made into your account.


5.1. In accordance with the AML legislation, has appointed the “highest level” for the prevention of ML: The full management of BlockBit N.V. is in charge.

5.2. Furthermore, an AMLCO /Anti Money Laundering Compliance Officer/ is in charge of the enforcement of the AML policy and procedures within the System.

5.3 The AMLCO is placed under the direct responsibility of the General Management.


Each major change of AML policy is subject to approval by the general management of BlockBit N.V. and the Anti-money laundering compliance officer.


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


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

8.2. 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.

8.3. These data will be safely, encrypted and stored offline and online.


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

9.2. 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;

9.3. 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 in the BlockBit N.V. AML team.


Internal audit regularly establishes missions and reports about AML activities.


11.1. All data given by any user/customer will be kept secure and not 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.

11.2. will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)


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

By email: [email protected].

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

By email: [email protected]

AML Policy of BlockBit N.V.

Last updated: 12/04/2024