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SpellWin Financial Security and Verification Policy

Last updated: 23 February 2026

This policy explains how SpellWin verifies customers, reviews financial activity and reduces the risk of fraud, money laundering and unauthorised use of payment methods.

Purpose of the Policy

SpellWin applies identity and payment checks to confirm that account information is accurate and that deposited funds belong to the registered customer.

The level of verification may depend on several factors, including:

  • the customer’s country of residence and nationality;
  • deposit and withdrawal amounts;
  • the selected payment method;
  • transaction frequency and account behaviour;
  • the overall risk profile of the account.

Reasonable technical, operational and compliance measures are used to identify and limit financial crime risks.

Applicable Compliance Standards

The SpellWin AML framework is based on recognised anti-money laundering, payment transparency, sanctions and customer-identification principles.

The policy takes into account relevant European requirements, including rules concerning:

  • prevention of the use of financial systems for money laundering;
  • information accompanying transfers of funds;
  • financial sanctions and restrictive measures;
  • customer identification and transaction monitoring;
  • record retention and data security.

Meaning of Money Laundering

Money laundering includes activities intended to conceal the criminal origin, ownership, location or movement of funds or other property.

This may include:

  • converting or transferring assets known to originate from criminal activity;
  • hiding the real source, ownership or destination of property;
  • possessing or using assets known to have an unlawful origin;
  • helping another person avoid the legal consequences of criminal conduct;
  • attempting, assisting, facilitating or participating in such activity.

These rules may apply even when the original unlawful activity occurred in another country.

AML Oversight

An Anti-Money Laundering Compliance Officer oversees the implementation of AML procedures within SpellWin.

The compliance officer operates under the responsibility of senior management and may review verification results, unusual transactions, internal reports and account restrictions.

Three-Level Account Verification

SpellWin may use a three-level verification process. Deposits, withdrawals or other account functions may be placed on hold until the required checks are completed.

Level One: Personal Information Check

The first verification level may be required before a withdrawal is approved. The customer must provide accurate personal information, including:

  • first and last name;
  • date of birth;
  • nationality;
  • gender;
  • country of residence;
  • full residential address.

The information must match the details registered on the account and any documents submitted later.

Level Two: Identity Confirmation

The second verification level may be required when total deposits or withdrawals exceed €2,000.

The customer may need to provide a photograph of an official identity document displayed next to a handwritten or generated verification code.

Accepted documents may include:

  • passport;
  • national identity card;
  • driving licence, where accepted.

SpellWin may compare the submitted details with independent databases. If an electronic check cannot be completed, additional proof of residence may be requested.

Level Three: Source of Wealth Review

The third verification level may apply when deposits or withdrawals exceed €5,000, whether through one transaction or several connected transactions.

The customer may be asked to explain and document the origin of their funds or overall wealth before further financial activity is approved.

Identity Document Requirements

Identity documents must be valid, clearly readable and shown in full. All four corners should be visible in the submitted image.

A separate image showing the customer’s face may also be required. SpellWin may request further details where necessary to complete the verification.

Customers may be permitted to conceal information that is not required for the check, provided the following details remain visible:

  • full name;
  • date of birth;
  • nationality;
  • gender;
  • photograph.

Residential Address Confirmation

SpellWin may verify a residential address through independent electronic databases or by requesting a supporting document.

Manual proof of address may include:

  • a utility bill;
  • a bank statement;
  • an official government document;
  • another formal document addressed to the customer.

The document should normally be issued within the previous three months. It must clearly display the customer’s name, address, issue date and all document edges.

Source of Funds and Wealth

Where enhanced verification is required, SpellWin may request evidence explaining how the customer obtained the money used on the platform.

Common sources may include:

  • employment income;
  • business ownership;
  • investments;
  • inheritance;
  • family support;
  • other lawful income or assets.

The source and legitimacy of the funds must be reasonably clear. Additional documents may be requested when the information provided is incomplete or cannot be verified.

Payment Method Ownership

Customers may be asked to confirm ownership of a bank account, payment card or other payment method used on SpellWin.

As a general rule, withdrawals should be returned through the same method used for the original deposit, at least up to the amount initially deposited.

Using payment methods that belong to another person may result in additional checks, delayed transactions or account restrictions.

Country Risk Classification

SpellWin may group countries into different risk categories and apply verification thresholds accordingly.

Standard-Risk Jurisdictions

Customers from standard-risk locations follow the regular three-level verification procedure.

Medium-Risk Jurisdictions

Lower financial thresholds may apply to customers from medium-risk regions:

  • level two verification may begin at deposits or withdrawals of $1,000;
  • level three verification may begin at deposits or withdrawals of $2,500.

Some cryptocurrency conversion activity may also result in the account being assessed under medium-risk conditions.

High-Risk Jurisdictions

Customers from locations classified as high risk may be prohibited from registering, depositing or using SpellWin services.

Risk classifications may be reviewed and updated as legal, regulatory and security conditions change.

Automated and Manual Account Reviews

SpellWin may use automated systems to identify unusual activity. Results may then be reviewed by trained employees or the AML compliance team.

Indicators of unusual behaviour may include:

  • depositing and withdrawing without meaningful gameplay;
  • using different payment methods for deposits and withdrawals;
  • frequent changes to nationality, currency or account details;
  • sudden changes in transaction patterns;
  • activity suggesting that the account is controlled by another person;
  • transactions inconsistent with the customer’s known financial profile.

Additional identity, payment or source-of-funds checks may be applied where account activity cannot be reasonably explained.

Company-Wide Risk Assessment

SpellWin maintains an enterprise-wide assessment of financial crime risks connected with its services, customers, transactions, payment channels and geographic reach.

The assessment considers:

  • the services offered through the platform;
  • customer types and locations;
  • transaction methods and volumes;
  • payment and delivery channels;
  • new or emerging financial crime risks.

The assessment is reviewed periodically and may lead to changes in verification or monitoring procedures.

Continuous Transaction Monitoring

Customer activity may be monitored throughout the business relationship to identify transactions that differ from the expected account profile.

Payment Provider Controls

SpellWin works with payment service providers that maintain their own customer verification and anti-money laundering controls.

Account Activity Review

Deposits, withdrawals, payment requests and other account activity may be reviewed using customer information, financial behaviour and transaction history.

Enhanced Manual Review

Suspicious or higher-risk accounts may be examined manually as an additional control. Transactions may be delayed or restricted while a review is in progress.

Suspicious Activity Reporting

Employees must report activity that appears unusual and cannot be connected to a legitimate source or purpose.

The AML team reviews internal reports and determines whether:

  • additional customer information is required;
  • transactions should be suspended;
  • the account relationship should be ended;
  • a report must be submitted to the relevant authority.

Where fraud or money laundering is reasonably identified, SpellWin may notify the competent authorities and take action permitted by law.

Document and Transaction Records

Identification records may be retained for at least ten years after the customer relationship ends.

Transaction records may also be stored for at least ten years after the transaction is completed or the account relationship is closed.

Records may be stored through encrypted online and offline systems.

Staff Training and Internal Controls

Employees involved in financial operations, customer verification or transaction reviews receive appropriate AML training.

This may include:

  • mandatory compliance training;
  • instruction on current regulatory requirements;
  • training for new employees;
  • risk-based manual review procedures;
  • guidance on identifying and reporting suspicious activity.

Compliance Audits

Internal audits may be conducted to assess whether AML procedures are operating effectively and whether identified risks are being handled correctly.

Audit findings may result in updated controls, staff training or changes to verification procedures.

Protection of Customer Information

Personal and financial information collected for verification is stored securely and is not sold to unrelated third parties.

Information may be disclosed where required by law, a valid regulatory request or an investigation concerning fraud, money laundering or other unlawful activity.

SpellWin applies relevant data-protection principles when collecting, processing and retaining customer information.