This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of AccelCore Enterprise Limitada ("we", "us", "our"), operator of DiceSpin (accessible at diccespin.nl), towards preventing financial crime, verifying customer identity, and ensuring that diccespin.nl is not used as a vehicle for money laundering, terrorist financing, or any other unlawful activity. This Policy applies to all registered customers and governs all activity conducted on diccespin.nl. DiceSpin operates under Anjouan licence ALSI-202506031-FI2, issued by the Autonomous Island of Anjouan, and all AML and KYC procedures are maintained in accordance with that licensing framework and internationally recognised standards.

1. Purpose and Scope

The purpose of this Policy is to establish clear, consistent, and enforceable standards for:

• Identifying and verifying the identity of customers before and during their use of diccespin.nl;
• Monitoring customer transactions and behaviour for indicators of money laundering or terrorist financing;
• Detecting, assessing, and reporting suspicious activity to the appropriate authorities;
• Ensuring that DiceSpin's products — including the casino, live casino, and Altenar-powered sportsbook — are used only for lawful recreational purposes;
• Maintaining records that satisfy regulatory and licensing requirements.

This Policy applies to all individuals who register an account on diccespin.nl, regardless of the currency in which they transact (EUR, USD, AUD, CAD, CZK, NOK, PLN, CHF, or NZD) or the payment method they use. It applies equally to all product areas, including slots, table games, live casino, crash games, and the sportsbook.

2. Regulatory Framework and Licensing

DiceSpin is operated by AccelCore Enterprise Limitada, a company incorporated in Costa Rica. diccespin.nl holds a valid gaming licence issued by the Autonomous Island of Anjouan (Licence No. ALSI-202506031-FI2). Our AML and KYC framework is designed to reflect the standards required by our licensing authority and to align with the recommendations of the Financial Action Task Force (FATF), including its Forty Recommendations on combating money laundering and terrorist financing.

Where applicable law or regulatory guidance is updated, DiceSpin will review and revise this Policy accordingly. Customers who continue to use diccespin.nl following any material revision are deemed to have accepted the updated Policy.

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.
• KYC — Know Your Customer: the process by which DiceSpin verifies the identity and assesses the risk profile of its customers.
• CDD — Customer Due Diligence: standard verification measures applied to all customers.
• EDD — Enhanced Due Diligence: additional verification measures applied to higher-risk customers or transactions.
• PEP — Politically Exposed Person: an individual who holds or has held a prominent public position, or a close associate or family member of such a person.
• SAR — Suspicious Activity Report: a formal report submitted to the relevant authority when suspicious activity is identified.
• MLRO — Money Laundering Reporting Officer: the designated individual within DiceSpin responsible for overseeing AML compliance and receiving internal disclosures.
• Source of Funds (SOF) — Evidence demonstrating the origin of the specific funds deposited at diccespin.nl.
• Source of Wealth (SOW) — Evidence demonstrating the origin of a customer's overall financial wealth.

4. Risk-Based Approach

DiceSpin adopts a risk-based approach to AML and KYC. This means that the nature and extent of the verification and monitoring measures we apply are proportionate to the risk of money laundering or terrorist financing associated with each customer and each transaction. Not all customers present the same level of risk, and our procedures reflect this.

Factors that inform our risk assessment include, but are not limited to:

• The customer's country of residence and the associated jurisdiction risk;
• The payment methods used and the volume and frequency of transactions;
• Whether the customer is identified as a PEP or is associated with a sanctioned country, entity, or individual;
• Unusual or inconsistent deposit and withdrawal patterns relative to the customer's stated profile;
• Large single transactions or a rapid accumulation of deposits;
• Requests to change payment methods or bank accounts without clear explanation;
• Withdrawal requests that significantly exceed deposited amounts through means other than gameplay.

Based on the risk assessment outcome, customers will be classified as low, medium, or high risk. The level of due diligence applied will be calibrated accordingly.

5. Customer Due Diligence (CDD)

5.1 When CDD Is Required

DiceSpin will carry out standard Customer Due Diligence at the following points:

• At registration, before a customer account becomes fully operational;
• Before processing any withdrawal request, regardless of amount;
• When a customer's cumulative deposits reach or are anticipated to reach applicable thresholds;
• When there is any doubt about the accuracy or adequacy of previously submitted identification information;
• When a change in a customer's transaction behaviour triggers a review.

In practice, DiceSpin may allow limited activity on an account prior to full verification in order to improve the customer experience, but no withdrawal will be processed and no substantial funds will be committed until verification is complete. Payout speed on diccespin.nl is 1–3 business days post-verification; this window exists precisely to allow our compliance team to complete necessary checks.

5.2 Identity Verification — Documents Required

As part of standard CDD, customers will be required to submit the following documentation. All documents must be valid, unexpired, clearly legible, and provided in a format that allows our team to verify authenticity.

All payment methods accepted at diccespin.nl — including Visa, Mastercard, Sofort, Trustly, Brite, MiFinity, Jetonbank, Skrill, Neteller, and bank transfer — must be verified as belonging to the registered account holder. Payments from third-party accounts are not permitted under any circumstances.

5.3 Age Verification

DiceSpin operates a strict minimum age policy. No person under the age of 18 may register an account or engage in any real-money activity on diccespin.nl. Age verification is conducted as part of the standard identity verification process. Where initial checks are inconclusive, we will request additional documentation and suspend real-money activity until age is confirmed beyond doubt. Where a customer is found to have been under 18 at the time of registration, the account will be closed immediately, all funds returned to the deposit source, and the matter reported as required.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence will be applied where a customer is identified as higher risk. Circumstances that will trigger EDD include:

• The customer is identified as a Politically Exposed Person (PEP) or a close associate or family member of a PEP;
• The customer is resident in or transacting from a jurisdiction designated as high-risk by the FATF or subject to international sanctions;
• Transaction volumes are inconsistent with the customer's stated occupation, income, or profile;
• The customer's cumulative deposits, losses, or withdrawal amounts exceed thresholds set by our internal risk framework;
• Unusual patterns emerge, such as frequent small deposits designed to remain below reporting thresholds (structuring);
• A customer requests withdrawal of funds shortly after depositing, with minimal gameplay in between.

Under EDD, DiceSpin may request one or more of the following:

• A Source of Funds declaration, supported by documentary evidence such as recent payslips, bank statements, dividend certificates, or proof of sale proceeds;
• A Source of Wealth declaration, with supporting documentation demonstrating the origin of the customer's overall financial assets;
• A signed declaration regarding PEP status and the nature of any public role held;
• Additional identification documents, including certified copies;
• A face-to-face or video-call verification session with a member of our compliance team.

Where a customer fails to respond to EDD requests within a reasonable timeframe, DiceSpin reserves the right to suspend withdrawal processing, restrict account functionality, and ultimately close the account, returning funds to the verified deposit source where it is lawful to do so.

7. Source of Funds and Source of Wealth

Where our risk assessment indicates that a customer's deposits or gambling activity may not be consistent with their apparent financial profile, DiceSpin will request evidence of Source of Funds and, where appropriate, Source of Wealth. This is not an accusation of wrongdoing; it is a standard compliance measure applied across the industry.

Acceptable evidence of Source of Funds includes:

• Recent payslips or employment contracts confirming salary;
• Business accounts, company financial statements, or dividend records for self-employed customers;
• Bank statements demonstrating the transfer of funds from a legitimate source;
• Documentation of proceeds from property sales, investment liquidations, or inheritance;
• Pension statements or annuity records.

Until satisfactory Source of Funds or Source of Wealth evidence is received and accepted by our compliance team, DiceSpin reserves the right to restrict deposits, withhold withdrawals, and limit gameplay.

8. Ongoing Monitoring

KYC is not a one-time exercise. DiceSpin maintains continuous monitoring of customer accounts and transactions throughout the customer lifecycle. Monitoring activities include:

• Real-time transaction screening against sanctions lists and databases of known financial criminals;
• Automated alerts triggered by unusual deposit frequency, deposit amounts, or withdrawal patterns;
• Periodic review of existing customer profiles to ensure that documentation remains current and that risk ratings remain appropriate;
• Behavioural analysis to detect signs of structuring, layering, or integration of illicit funds;
• Review of gameplay patterns that appear commercially irrational or inconsistent with recreational gambling (for example, deliberately low-risk wagering designed to convert funds rather than to play);
• Cross-referencing of player activity against our cashback and bonus data — including the 10% Daily Cashback and the casino welcome bonus — to identify any patterns suggesting abuse or financial crime.

Where monitoring identifies a potential concern, the matter is escalated to the MLRO for review. The MLRO will determine whether a Suspicious Activity Report should be filed.

9. Suspicious Activity Reporting

DiceSpin is committed to reporting suspicious activity promptly and accurately. Where our MLRO determines that there are reasonable grounds to suspect that funds are derived from criminal activity, or that a transaction is connected with money laundering or terrorist financing, a Suspicious Activity Report will be submitted to the competent authority in accordance with applicable requirements.

Indicators of suspicious activity that may give rise to an SAR include, but are not limited to:

• A customer depositing large amounts and requesting withdrawal after minimal play;
• Multiple deposits from different payment methods, particularly across different currencies;
• A customer expressing confusion about their own account balance or history, suggesting they may not be the true beneficial owner;
• Deposits immediately following a new account registration with no prior engagement;
• Use of payment methods that obscure the origin of funds;
• A customer who is unable or unwilling to provide satisfactory KYC documentation when requested;
• Transfers between accounts or attempts to split funds across multiple accounts;
• Any direct or indirect reference to illegal activity by the customer.

Staff involved in AML and KYC processes are trained to recognise these indicators. Internal disclosures are made to the MLRO, who holds sole authority to determine whether an external SAR is appropriate. The "tipping-off" prohibition applies: no customer will be informed that a report has been or may be made, as doing so could constitute a criminal offence under applicable law.

10. Politically Exposed Persons (PEPs) and Sanctions Screening

DiceSpin screens all customers, at registration and on an ongoing basis, against relevant PEP databases and international sanctions lists, including those maintained by the United Nations, the European Union, OFAC, and HM Treasury. Screening is conducted using automated tools and is supplemented by manual review where required.

Where a customer is identified as a PEP, or as a close associate or immediate family member of a PEP:

• Enhanced Due Diligence will be applied automatically;
• Senior management approval will be required before the business relationship is established or continued;
• The source of funds and source of wealth must be verified to our satisfaction before any withdrawal is processed;
• The account will be subject to heightened ongoing monitoring.

Where a customer or a transaction is matched against a sanctions list, the account will be suspended immediately pending review. Where a confirmed sanctions match is identified, DiceSpin will take all steps required by applicable law, which may include freezing funds and making a report to the relevant authority. No funds will be processed in contravention of sanctions obligations.

11. Record Keeping

DiceSpin maintains comprehensive records of all customer identification documents, due diligence assessments, transaction data, monitoring outputs, and SAR decisions. Records are retained for a minimum of five years from the date of the relevant transaction or from the date of the end of the customer relationship, whichever is later, in accordance with standard industry practice and regulatory expectation.

Records are stored securely and are accessible only to authorised compliance personnel and, where legally required, to regulatory and law enforcement bodies. All data handling is conducted in accordance with our Privacy Policy.

12. Account Verification and Withdrawal Processing

No withdrawal from diccespin.nl will be processed until the account holder has completed identity verification to the satisfaction of our compliance team. This applies regardless of the withdrawal method selected, the amount requested, or the currency involved. The minimum withdrawal at DiceSpin is €50, and verified withdrawals are processed within 1–3 business days.

The withdrawal fee of €3 applies per transaction; this fee is refunded if the withdrawal is not successfully processed. Maximum withdrawal limits are €5,000 per day, €10,000 per week, and €40,000 per month. These limits form part of our transaction monitoring framework and help us detect patterns that may be inconsistent with recreational gambling.

Where a withdrawal request triggers an AML concern — for example, because the amount requested significantly exceeds net deposits, or because the withdrawal method differs from the deposit method without clear explanation — the request will be held pending review and the customer may be asked to provide additional documentation before the payment is released.

13. Prohibited Activities

The following activities are strictly prohibited on diccespin.nl and will result in immediate account suspension and, where appropriate, reporting to the relevant authorities:

• Using diccespin.nl to launder funds derived from any criminal activity;
• Providing false, misleading, or fraudulent identification documents;
• Operating multiple accounts or sharing accounts with third parties;
• Making deposits from payment accounts that do not belong to the registered account holder;
• Structuring deposits in a manner designed to evade detection or reporting thresholds;
• Attempting to use diccespin.nl to finance terrorist activities or to transfer funds to or from sanctioned individuals or entities;
• Permitting any third party to use your account for any purpose, including but not limited to depositing, wagering, or withdrawing funds;
• Any attempt to manipulate gameplay, bonuses, or cashback calculations — including the 10% Daily Cashback — in a manner designed to generate artificial returns rather than to engage in genuine recreational gambling.

14. Staff Training and Governance

DiceSpin maintains an internal AML compliance programme that includes:

• Designation of a Money Laundering Reporting Officer (MLRO) with appropriate authority, independence, and access to all relevant data;
• Regular AML and KYC training for all staff involved in customer onboarding, payments, customer support, and compliance;
• Internal policies and procedures that implement the principles set out in this Policy;
• Periodic internal audits and risk assessments to evaluate the effectiveness of the AML programme;
• A clear escalation process for reporting internal suspicions to the MLRO.

Our compliance function operates independently of commercial and marketing departments to ensure that revenue considerations do not compromise AML integrity.

15. Responsible Gambling and AML

DiceSpin recognises that problem gambling and financial crime can intersect. A customer who is gambling beyond their financial means may, in some circumstances, be at increased risk of resorting to illegal funds. Our responsible gambling measures and our AML procedures are therefore complementary. Where a customer's gambling behaviour raises concerns under either framework, both sets of protections will be applied.

Customers who are experiencing difficulties with gambling are encouraged to use the responsible gambling tools available on diccespin.nl, including deposit limits, session limits, and self-exclusion. These tools can be accessed by contacting our support team via Live Chat (powered by Intercom) or by emailing our team at the address provided in our Help Centre.

16. Customer Obligations

By registering an account on diccespin.nl, customers agree to:

• Provide accurate, complete, and up-to-date information at registration and throughout the account lifecycle;
• Notify DiceSpin promptly of any change to their personal details, including name, address, payment methods, or employment;
• Respond promptly and fully to any request for KYC documentation, Source of Funds evidence, or Source of Wealth information;
• Use diccespin.nl solely for lawful recreational gambling purposes, using only funds that belong to them and that derive from legitimate sources;
• Not allow any third party to access or use their account;
• Cooperate fully with any investigation or review conducted by DiceSpin's compliance team.

Failure to comply with these obligations may result in the suspension or permanent closure of the account, the withholding of funds pending investigation, and, where appropriate, the referral of the matter to the relevant authorities.

17. Contact and Escalation

If you have questions about this Policy, your verification status, or any document request you have received, please contact the DiceSpin compliance and support team using the following channels:

• Live Chat: Available directly on diccespin.nl, powered by Intercom
• Email (general support): Available via the Help Centre on diccespin.nl
• Email (loyalty and promotions enquiries): [email protected]

Please note that we are unable to provide specific information about the status of any SAR or ongoing AML investigation. Any queries that relate to compliance holds on withdrawals will be handled by our compliance team and responded to as promptly as our obligations permit.

18. Policy Review

This AML / KYC Policy is reviewed at least annually, or sooner where there is a material change in applicable law, regulatory guidance, or the risk environment in which DiceSpin operates. The most current version of this Policy is always available on diccespin.nl. Customers are advised to review this Policy periodically. Continued use of diccespin.nl constitutes acceptance of the then-current version of this Policy.

Last reviewed: 2026. Operated by AccelCore Enterprise Limitada, Costa Rica. Licence: Anjouan ALSI-202506031-FI2.