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Home › AML / KYC Policy

This Anti-Money Laundering and Know Your Customer Policy ("Policy") applies to all players registered at Justbit Casino, operated at just-bit.bet by Casbit Group N.V. under Curaçao eGaming Licence No. 8048/JAZ. It sets out our legal obligations, the procedures we follow to verify player identity, and the standards we uphold to prevent financial crime across every product we offer — casino games, live tables, crash games, and sports betting.

1. Introduction and Purpose

Casbit Group N.V. is committed to operating Justbit Casino in full compliance with applicable anti-money laundering ("AML") and counter-terrorist financing ("CTF") legislation, the requirements of our Curaçao eGaming licence, and internationally recognised standards including those published by the Financial Action Task Force (FATF). This Policy has been adopted to:

  • Prevent Justbit Casino from being used as a vehicle for money laundering, terrorist financing, or other financial crime;
  • Establish clear, consistent procedures for verifying the identity of our players;
  • Define the processes by which we monitor account activity and report suspicious behaviour to the relevant authorities;
  • Protect the integrity of the platform and the interests of legitimate players across the 80+ countries we serve.

All staff and third-party service providers with access to player data or transaction information are required to act in accordance with this Policy at all times. The Policy is reviewed and updated periodically to reflect changes in regulation, guidance, or operational practice.

2. Legal Framework

This Policy is underpinned by the following regulatory framework:

  • The terms and conditions of Curaçao eGaming Licence No. 8048/JAZ, granted to Casbit Group N.V.;
  • The National Ordinance on the Reporting of Unusual Transactions and related Curaçao AML/CTF legislation;
  • FATF Recommendations on money laundering and terrorist financing;
  • The Wolfsberg Group principles on anti-money laundering for the financial services sector (applied by analogy);
  • Applicable data protection legislation governing the collection, storage, and processing of personal data submitted during the KYC process.

Where a player is located in a jurisdiction with additional domestic AML requirements, Casbit Group N.V. applies the higher of the two standards.

3. What Is Money Laundering?

Money laundering is the process by which proceeds derived from criminal activity are introduced into the legitimate financial system in a way that obscures their origin. It is typically described in three stages:

  • Placement — criminal funds are introduced into the financial system, for example by depositing cash or converting funds through a payment provider;
  • Layering — the origin of the funds is obscured through a series of transactions designed to create distance from the original source;
  • Integration — the laundered funds re-enter the economy as apparently legitimate assets.

Online gambling platforms can be exposed to all three stages if adequate controls are not in place. Justbit Casino takes a risk-based approach to detecting and disrupting each stage of this process.

4. Risk-Based Approach

We assess AML and CTF risk at both the product level and the individual player level. Our risk categorisation considers the following factors:

  • The payment method used (cryptocurrency, e-wallet, card, bank transfer);
  • The volume and frequency of deposits and withdrawals relative to declared income or occupation;
  • The player's country of residence and any associated jurisdiction risk;
  • Patterns of play that are inconsistent with the purpose of gambling (e.g., depositing large sums and immediately withdrawing without meaningful play);
  • Whether the player is a Politically Exposed Person (PEP) or appears on any sanctions list;
  • The use of multiple payment methods or accounts that may indicate layering activity.

Players are assigned a risk rating of Low, Medium, or High. Enhanced due diligence is applied to all Medium and High-risk accounts. Risk ratings are reviewed whenever a material change in account behaviour is detected or when a player advances to a higher VIP tier.

5. Know Your Customer (KYC) Policy

5.1 Who Must Complete KYC

KYC verification is required in the following circumstances, regardless of the payment method used:

  • When cumulative deposits on an account reach or exceed €2,000;
  • When a withdrawal request is submitted on a fiat-currency account (Visa, Mastercard, Skrill, Neteller, iDEAL, bank transfer) for any amount at or above the minimum withdrawal of €20;
  • When our risk-monitoring systems flag an account for suspicious activity or unusual transaction patterns;
  • When a player requests a withdrawal limit increase beyond the standard non-VIP fiat cap of €5,000 per week or €20,000 per month;
  • When a player progresses to Gold, Platinum, Diamond, or Elite VIP tier and accesses enhanced benefits including personal account managers and sponsored events;
  • At any time we deem it necessary to satisfy our AML, CTF, or licensing obligations.

Players who fund and withdraw exclusively using cryptocurrency (BTC, ETH, LTC, USDT, DOGE, or other supported crypto assets) and who remain within the standard transaction limits may be eligible to operate a crypto-only account without completing full KYC. However, Casbit Group N.V. reserves the right to request identity documents from any account at any time, and crypto-only accounts are subject to the same transaction monitoring and suspicious activity reporting obligations as all other accounts.

5.2 Documents Required — Standard Verification

To complete standard KYC, players must submit clear, legible copies of the following:

  • Proof of Identity (POI) — a valid, government-issued photo ID: passport, national identity card, or driving licence. The document must show the player's full legal name, date of birth, photograph, and must be in-date;
  • Proof of Address (POA) — a utility bill, bank statement, or official government letter issued within the past three months, showing the player's full name and residential address. PO Box addresses are not accepted;
  • Proof of Payment Method — a screenshot or photograph confirming that the player is the registered holder of the payment method on file. For cards, this includes the card number (with the middle digits obscured), name, and expiry date. For e-wallets, a screenshot of the account dashboard showing the registered name and email address is required. For cryptocurrency wallets, ownership may be confirmed by transacting from the same wallet address used for deposits.

5.3 Documents Required — Enhanced Due Diligence

For accounts classified as Medium or High risk, or where the source of funds requires further clarification, we may additionally request:

  • Proof of Source of Funds (SOF) — recent bank statements (typically covering the preceding three to six months), payslips, tax returns, dividend records, or documentation evidencing the legitimate origin of funds deposited or wagered on the account;
  • Proof of Source of Wealth (SOW) — broader documentation establishing the player's overall financial position, which may include employment contracts, business accounts, inheritance documents, or property sale proceeds where relevant;
  • PEP and Sanctions Declaration — players who are, or who are connected to, politically exposed persons must provide a signed declaration and may be subject to additional scrutiny before account activity is permitted to continue;
  • Video verification — in certain circumstances, we may request a short video call or selfie-with-document submission to confirm that the person presenting documents is the account holder.

5.4 Document Submission Process

Documents may be submitted through the secure verification portal in the player's account dashboard, or by emailing them to our compliance team at the address provided in the verification request. All documents are transmitted over encrypted connections and stored in accordance with our Privacy Policy. We aim to complete standard verification within 24 hours of receiving a complete set of documents. Enhanced due diligence reviews may take longer; we will notify the player if additional time is required.

5.5 Pending Verification

Where a KYC request has been issued and is outstanding, the following restrictions apply until verification is completed:

  • Withdrawal processing will be paused pending receipt and approval of required documents;
  • Deposits may continue at the operator's discretion, subject to the player's risk profile;
  • Bonus entitlements may be suspended;
  • Access to VIP benefits linked to higher tiers may be restricted.

Casbit Group N.V. accepts no liability for delays in processing withdrawals that are caused by a player's failure to provide complete, accurate, and legible documentation in a timely manner.

5.6 Refusal and Account Closure

If a player refuses to provide requested KYC documentation, provides documents that appear fraudulent or materially inconsistent, or fails to respond to a verification request within 30 days, Casbit Group N.V. reserves the right to:

  • Suspend or permanently close the account;
  • Withhold pending withdrawals pending investigation;
  • Report the circumstances to the relevant competent authority where required by law;
  • Forfeit any bonus balances in accordance with our Bonus Terms and Conditions.

Any balance of legitimate origin confirmed following a full investigation will be returned to the player via the original deposit method, subject to applicable transaction limits and verification requirements.

6. Transaction Monitoring

Casbit Group N.V. employs automated transaction monitoring tools alongside manual review procedures to identify patterns of activity that may indicate money laundering, terrorist financing, or other financial crime. The monitoring programme includes, but is not limited to, the detection of the following indicators:

  • Deposits that significantly exceed a player's stated income, occupation, or historical wagering behaviour;
  • Multiple rapid deposits followed immediately by withdrawal requests with minimal or nominal gambling activity in between;
  • Deposits from payment methods registered in a different name to the account holder;
  • Unusual structuring of deposits — for example, a series of deposits made just below a reporting threshold;
  • Requests to withdraw to a different method or account than the one used to deposit;
  • High-value cryptocurrency deposits followed by immediate fiat or alternative cryptocurrency withdrawals;
  • Play patterns that appear designed to convert deposited funds into withdrawable balances with minimal genuine gambling engagement;
  • Accounts showing sudden changes in bet size, frequency, or preferred game type that are inconsistent with prior behaviour;
  • Multiple accounts controlled by the same person or operating from the same device or IP address.

Where monitoring identifies a concern, the account is flagged for review by our compliance team. Depending on the severity of the concern, the review may result in enhanced due diligence, account suspension, or a Suspicious Activity Report (SAR) being filed with the appropriate financial intelligence unit.

7. Suspicious Activity Reporting

All members of Casbit Group N.V.'s compliance team are trained to identify and report suspicious activity. Where a genuine suspicion of money laundering or terrorist financing arises, a SAR will be filed with the relevant competent authority in accordance with our obligations under the applicable legal framework. Casbit Group N.V. strictly observes the legal prohibition on "tipping off" — no player, account holder, or third party will be informed that a SAR has been made or that an investigation is ongoing.

Employees who make a SAR in good faith are protected from any liability arising from that disclosure, in accordance with applicable law.

8. Politically Exposed Persons (PEPs) and Sanctions Screening

All new player accounts are screened at registration, and existing accounts are screened on an ongoing basis, against:

  • Domestic and international PEP databases;
  • Sanctions lists published by bodies including the United Nations Security Council, the European Union, the Office of Foreign Assets Control (OFAC), and HM Treasury's financial sanctions register;
  • Adverse media and negative news databases.

A Politically Exposed Person is defined as an individual who holds or has held, within the preceding 12 months, a prominent public function, as well as their immediate family members and known close associates. PEP status alone does not preclude an individual from holding an account at Justbit Casino; however, all PEP accounts are subject to enhanced due diligence and senior management approval before account opening or continued operation is permitted.

Any account that matches a sanctions list entry will be suspended immediately and reported to the relevant authority. No funds will be released to a sanctioned individual or entity.

9. Payment Method Controls

Justbit Casino supports a range of deposit and withdrawal methods, including Visa, Mastercard, iDEAL, Skrill, Neteller, Google Pay, Apple Pay, Paysafecard, and cryptocurrencies including Bitcoin (BTC), Ethereum (ETH), Litecoin (LTC), USDT, and Dogecoin (DOGE). The following controls apply across all methods:

  • Players may only withdraw using a payment method in their own name. Withdrawals to third-party accounts are not permitted under any circumstances;
  • The withdrawal method must correspond to the deposit method where technically possible. Where a deposit method does not support withdrawals (e.g., Paysafecard, Google Pay, Apple Pay), the player must complete KYC and provide an approved alternative method;
  • The minimum withdrawal across all methods is €20 (or equivalent in supported currency), with the exception of bank transfers where the minimum is €40;
  • Non-VIP fiat withdrawals are capped at €5,000 per week and €20,000 per month. Cryptocurrency withdrawals carry a weekly maximum of €300,000, reflecting the higher liquidity and traceability of on-chain transactions;
  • We do not charge transaction fees on our end. Third-party processing fees of typically 0.5%–2% may apply and are outside our control;
  • Cryptocurrency wallet addresses used for withdrawals are subject to blockchain analytics screening to assess exposure to illicit activity. Withdrawals to wallet addresses associated with sanctioned entities, darknet markets, or high-risk mixing services will be refused and the account flagged for review.

10. Cryptocurrency-Specific Controls

Justbit Casino accepts cryptocurrency deposits and withdrawals as a core part of its payment infrastructure. Whilst cryptocurrency transactions offer legitimate advantages including speed — BTC withdrawals typically process in 5 to 15 minutes — the pseudonymous nature of blockchain transactions requires specific additional controls:

  • All cryptocurrency transactions are reviewed using blockchain analytics tools to assess transaction risk, including exposure to mixers, tumblers, peer-to-peer exchanges with inadequate AML controls, and addresses linked to known criminal activity;
  • Deposits originating from high-risk wallet addresses may be held pending investigation and may be refused and returned where legally permissible;
  • Crypto-only accounts that operate without completing full KYC are subject to lower de-facto thresholds for enhanced due diligence triggers, given the reduced identity transparency of blockchain-based transactions;
  • Large or unusual cryptocurrency deposits — particularly those involving multiple wallet addresses funding a single account in rapid succession — will be escalated for manual review;
  • Justbit Casino does not accept cryptocurrency assets that our analytics tools identify as having a material proportion of their transaction history linked to illicit sources.

11. Responsible Gaming and AML Intersection

Casbit Group N.V. recognises that problem gambling behaviour can sometimes intersect with or mimic AML red flags, and that protecting vulnerable players is both a duty of care and a compliance obligation. Our responsible gaming controls include deposit limits, session limits, cool-off periods, and self-exclusion options accessible directly from the player's account dashboard. Where a compliance review reveals that a player may be gambling beyond their financial means, the account will be referred simultaneously to our responsible gaming team and our compliance team for a co-ordinated response.

Players experiencing difficulties with gambling are encouraged to contact our 24/7 support team via Live Chat, Email, or Telegram, or to seek assistance from independent organisations such as GamCare, Gamblers Anonymous, or BeGambleAware.

12. Staff Training and Compliance Culture

All Casbit Group N.V. employees whose roles involve player account management, payments processing, customer support, or compliance are required to complete AML and KYC training before commencing their duties and to undertake refresher training at least annually. Training covers:

  • The legal framework governing AML and CTF obligations;
  • How to recognise the red flags of money laundering and terrorist financing in an online gambling context;
  • The internal procedures for escalating concerns to the compliance team;
  • The obligations and protections associated with making a SAR;
  • The prohibition on tipping off and the consequences of non-compliance.

A designated Money Laundering Reporting Officer (MLRO) is appointed by Casbit Group N.V. with responsibility for overseeing the implementation of this Policy, receiving internal disclosures from staff, and determining whether external reports to competent authorities are required.

13. Record Keeping

Casbit Group N.V. maintains records of all KYC documentation, transaction history, risk assessments, and internal and external reports in accordance with applicable legal requirements. Records are retained for a minimum period of five years from the date of the relevant transaction, the end of the business relationship with the player, or such longer period as may be required by law or regulatory authority. All records are stored securely and accessed only by authorised personnel.

14. Data Protection

Personal data collected during the KYC process is processed solely for the purposes of identity verification, AML and CTF compliance, fraud prevention, and the fulfilment of our regulatory obligations. Such data is handled in accordance with Casbit Group N.V.'s Privacy Policy, which is published on just-bit.bet. We do not sell, rent, or otherwise disclose player personal data to third parties except where required by law, to our regulated third-party verification service providers operating under equivalent data protection standards, or to competent authorities in connection with a SAR or regulatory inquiry.

15. Policy Review and Updates

This Policy is reviewed by the MLRO and senior management at least once per year, or more frequently where there is a material change in applicable law, regulatory guidance, or the risk environment in which Justbit Casino operates. The current version of this Policy is published on just-bit.bet and supersedes all previous versions. Continued use of the platform following the publication of an updated Policy constitutes acceptance of the revised terms.

16. Contact

Queries relating to this Policy, or to the KYC verification process, may be directed to our compliance and support team through any of the following channels:

  • Live Chat — available 24/7 via the just-bit.bet website
  • Email — as published in the Contact section of just-bit.bet
  • Telegram — via the official Justbit Casino Telegram channel

Justbit Casino is operated by Casbit Group N.V., licensed under Curaçao eGaming Licence No. 8048/JAZ. Registered address details are available upon request from our compliance team.

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