Anti-Money Laundering (AML) Policy

Policy for Processing Financial Deposits and Withdrawals

(Anti-Money-Laundering policy of https://csgocasino.gg)

https://csgocasino.gg is owned and operated by Nebula Technologies Ltd. (company reg. no. 000049805), New Horizon Building, Ground Floor, 3 1/2 Miles Philip S. W. Goldson Highway, Belize City, Belize.

CSGOCasino strives to deliver the highest level of security to every player. To do so we use a four-tier account-verification programme, aligned with global AML standards and the requirements of our gaming licence. These tiers combat money-laundering, protect minors and help us understand our customers.

We also apply proportionate technical and organisational measures to control and limit ML risk, dedicating the resources necessary to remain fully compliant with prevailing legislation.

Nebula Technologies Ltd. upholds the AML standards laid down in (inter alia):

EU Directive 2015/849 on the prevention of the use of the financial system for money-laundering;
EU Regulation 2015/847 on information accompanying transfers of funds;
All EU regulations imposing sanctions or restrictive measures on persons, goods or technology, including dual-use goods;
Belgian Law of 18 September 2017 on the prevention of money-laundering and the limitation of cash usage.

1. Definition of Money Laundering

For the purposes of this policy, “money laundering” includes (but is not limited to):

Converting or transferring assets derived from criminal activity in order to conceal their illicit origin or help the perpetrator evade legal consequences;
Concealing or disguising the nature, source, location, movement, ownership or rights of assets known to originate from criminal activity;
Acquiring, possessing or using assets with knowledge, at the time of receipt, that they stem from criminal activity;
Participating in, attempting, aiding, abetting or facilitating any of the above acts.

These provisions apply even when the predicate offence occurred outside Belize.

2. AML Governance at CSGOCasino

The board of directors of Nebula Technologies Ltd. bears ultimate responsibility for AML compliance. Day-to-day implementation is delegated to an Anti-Money-Laundering Compliance Officer (AMLCO), who reports directly to senior management.

3. Policy Changes

Material amendments to this AML policy require approval from the board and the AMLCO before implementation.

4. Verification & KYC Tiers

We apply a step-up KYC model (Levels 0–3). The thresholds and requirements are coded directly into our back-office system as shown below:

export const KYC_LEVELS: { [key: number]: IKYCLevel } = {
  0: {
    name: "None",
    description: "No verification required",
    fields: [],
    documents: [],
    depositLimit: 2000,
    withdrawLimit: 0,
  },
  1: {
    name: "Basic Identity",
    description: "Required for withdrawals",
    fields: ["firstName", "lastName", "dateOfBirth", "address", "country"],
    documents: [],
    depositLimit: 2000,
    withdrawLimit: 2000,
  },
  2: {
    name: "ID Verification",
    description: "Required when total deposits or withdrawals exceed $2,000",
    fields: ["firstName", "lastName", "dateOfBirth", "address", "country"],
    documents: ["id_front", "id_back", "selfie_with_id", "proof_of_address"],
    depositLimit: 50000,
    withdrawLimit: 50000,
  },
  3: {
    name: "Source of Funds",
    description: "Required when total deposits or withdrawals exceed $50,000",
    fields: ["firstName", "lastName", "dateOfBirth", "address", "country"],
    documents: ["id_front", "id_back", "selfie_with_id", "proof_of_address", "source_of_funds"],
    depositLimit: Infinity,
    withdrawLimit: Infinity,
  },
} as const;

Level 0 – No Verification

Players may deposit up to USD 2,000 in total without submitting documentation. Withdrawals are disabled until Level 1 is completed.

Level 1 – Basic Identity

Mandatory before the first withdrawal. Users must supply their first and last name, date of birth, full residential address, country and a valid e-mail address. All data must match the details held by our payment processors; mismatches result in blocked withdrawals and possible forfeiture of lost funds.

Level 2 – ID Verification

Triggered once lifetime deposits or withdrawals exceed USD 2,000 or when a player tips another user more than USD 100. An on-screen wizard guides the user through uploading:

Government-issued photo ID (front & back);
A selfie holding the same ID;
Proof of address (see §6).

Electronic databases are queried to corroborate the information. If the e-check fails, manual review is required and withdrawals remain on hold.

Level 3 – Source-of-Funds Verification

Required once cumulative deposits or withdrawals exceed USD 50,000, or a user tips more than USD 3,000. Acceptable evidence includes (but is not limited to): payslips, audited accounts, inheritance documentation, investment statements or other proof clearly demonstrating the origin of wealth. Players are notified by e-mail and granted 28 days to supply documentation; failure to comply may lead to account closure.

5. Customer Identification & Verification (KYC)

Accurate identification is essential for AML compliance and the protection of our community. At a minimum we require:

A clear photo of a valid passport, national ID card or driving licence; all four corners must be visible and text legible. Copies must be in Latin characters (an English-language passport is preferred).
A selfie of the customer holding the same ID next to their face.

Additional information may be requested at Nebula’s discretion or that of our payment providers.

6. Proof of Address

Address verification is normally carried out via two independent electronic databases. If either check fails, we request one of the following dated within the past three months:

Utility bill (electricity, water, gas – not mobile-phone);
Bank or credit-card statement;
Government correspondence (e.g., tax, health-service or social-security letter).

Documents must be high-resolution, with all edges visible and text readable.

7. Source of Funds

To combat financial crime we may at any time request evidence that the funds used on CSGOCasino derive from lawful activity. Examples include:

Business ownership records and relevant bank statements;
Employment income (recent payslips);
Inheritance documentation;
Investment-portfolio statements;
Family-wealth disclosures.

If a satisfactory explanation is not provided, we may suspend or terminate the business relationship.

8. Risk Management

Global ML risk varies by jurisdiction. CSGOCasino categorises countries into three risk bands and may initiate KYC without prior notice based solely on geolocation.

8.1 Enterprise-Wide Risk Assessment (EWRA)

We conduct an annual EWRA to identify inherent AML risks across our products, customer types, transaction patterns, delivery channels and geographic reach.

8.2 Ongoing Transaction Monitoring

First Line of Control – Payment Processors. We work exclusively with PSPs that apply robust AML programmes, filtering the majority of suspicious deposits at source.
Second Line of Control – Internal KYC. Our verification tiers and transaction-monitoring rules flag unusual behaviour. Where fraud or ML is suspected, funds may be frozen indefinitely and regulators notified.

9. Record-Keeping

Customer-identification records are retained for at least six years after the relationship ends.
Transaction records are retained for at least ten years after execution or account closure.

All records are stored securely in encrypted online and offline archives.

10. Data Security

Customer data is protected by rigorous technical and organisational measures and will never be sold or shared with third parties except:

When the customer gives explicit consent;
Upon lawful request by competent authorities; or
Where disclosure is necessary to fulfil our AML obligations.

Nebula adheres to the principles of the EU Data Protection Directive 95/46/EC (and its successors).

11. Contact

Questions or complaints regarding this AML & KYC Policy:

E-mail: [email protected]