This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of betbluff, operated by Green Champions Leader SRL (Costa Rica) under Anjouan licence ALSI-202502014-FI1, with respect to the detection, prevention, and reporting of money laundering, terrorist financing, and related financial crime. The Policy applies to all registered players at betbluffs.nl and governs every stage of the customer relationship — from account registration through to withdrawal. By registering an account and using our services, you agree to cooperate fully with the procedures described herein.

1. Legal Framework and Regulatory Basis

betbluff is licensed and regulated by the Government of the Autonomous Island of Anjouan under licence number ALSI-202502014-FI1. Our operator, Green Champions Leader SRL, is incorporated in Costa Rica and carries full responsibility for ensuring that betbluffs.nl is operated in accordance with applicable anti-money laundering legislation, international standards published by the Financial Action Task Force (FATF), and the conditions attached to our gaming licence.

The core purpose of this Policy is to ensure that betbluffs.nl is not used — directly or indirectly — as a vehicle for money laundering, the financing of terrorism, fraud, or any other form of financial crime. We maintain a risk-based approach to compliance, calibrating the level of scrutiny applied to each customer relationship according to the risk profile that customer presents.

2. Definitions

• Money Laundering: The process by which the proceeds of criminal activity are made to appear legitimate, typically through a series of placement, layering, and integration steps.
• Terrorist Financing: The provision or collection of funds, by any means, with the intention that they be used to carry out terrorist acts or to support terrorist organisations.
• Know Your Customer (KYC): The process by which betbluffs.nl verifies the identity of its customers and assesses the nature and purpose of each customer relationship.
• Customer Due Diligence (CDD): The standard set of identity and verification checks applied to all customers.
• Enhanced Due Diligence (EDD): Additional, more stringent checks applied where a customer or transaction presents a higher-than-standard risk.
• Politically Exposed Person (PEP): An individual who holds, or has held within the past twelve months, a prominent public function, together with their immediate family members and known close associates.
• Suspicious Activity: Any transaction, pattern of behaviour, or customer circumstance that gives rise to a reasonable suspicion of money laundering or terrorist financing.
• Source of Funds (SoF): The origin of the specific funds used by a customer to deposit at betbluffs.nl.
• Source of Wealth (SoW): The origin of a customer's total wealth or net worth.

3. Appointed Compliance Function

Green Champions Leader SRL has designated a nominated Compliance Officer with overall responsibility for the implementation and oversight of this Policy. The Compliance Officer is responsible for receiving and evaluating internal suspicious activity reports, liaising with regulatory authorities where required, maintaining AML records, and ensuring that all staff with customer-facing or financial responsibilities receive appropriate training. The identity and contact details of the Compliance Officer are held internally and are available to the relevant licensing authority upon request.

4. Risk-Based Approach

betbluffs.nl adopts a risk-based approach to AML and KYC compliance. This means that the nature, depth, and frequency of our due diligence measures are proportionate to the money laundering and terrorist financing risks associated with each customer relationship and each transaction. Risk is assessed across several dimensions:

• Customer risk: Factors include jurisdiction of residence, PEP status, adverse media, and behavioural patterns.
• Product and channel risk: Our platform accepts cryptocurrency payments with a maximum transaction limit of €100,000 per transaction, which carries inherently elevated risk and is subject to additional scrutiny.
• Geographic risk: Customers resident in jurisdictions identified by FATF as high-risk or non-cooperative attract enhanced scrutiny. betbluffs.nl maintains a list of restricted and prohibited jurisdictions, which is reviewed and updated periodically.
• Transaction risk: High-value transactions, rapid cycling of funds, or unusual patterns inconsistent with a customer's stated profile are treated as elevated-risk indicators.

Risk ratings are assigned at onboarding and reviewed continuously throughout the customer lifecycle. A change in a customer's circumstances — for example, a material increase in deposit volumes, a change of payment method, or identification as a PEP — will trigger a re-assessment of that customer's risk rating.

5. Customer Due Diligence (KYC)

5.1 When KYC Is Required

Identity verification is mandatory for all customers at betbluffs.nl. Full KYC must be completed before any withdrawal is processed. In addition, KYC is triggered automatically once a customer's cumulative deposits or withdrawals reach €2,000. betbluffs.nl reserves the right to request verification documents at any earlier stage where we consider it necessary to manage risk — including immediately upon registration at our absolute discretion.

Until KYC verification is complete, withdrawals will not be processed. Deposits may continue to be accepted up to the applicable threshold, but funds cannot be released until identity has been confirmed.

5.2 Standard Identity Documents

At the standard CDD level, customers will be asked to provide the following:

• Proof of Identity (one of the following): Valid government-issued passport; National identity card; Driving licence with photograph. The document must be current (not expired), clearly legible, and show the customer's full name, date of birth, and photograph.
• Proof of Address (one of the following, dated within three months): Utility bill (gas, electricity, water, or fixed-line telephone); Bank statement or credit card statement; Official government correspondence.
• Selfie verification: A photograph of the customer holding their identity document alongside a handwritten note bearing their betbluffs.nl username and the date of submission, where requested by our compliance team.

5.3 Proof of Payment Method

Depending on the payment method used, we may request verification of the account or wallet from which deposits are made:

• LuxonPay / MiFinity / Cashlib: A screenshot or statement confirming ownership of the account, showing the customer's name and relevant account details.
• Cryptocurrency wallets: Confirmation of wallet ownership may be requested, including transaction history screenshots or a micro-transaction test. Given that crypto transactions at betbluffs.nl may reach up to €100,000 per transaction, wallet verification will be applied rigorously at higher transaction volumes.

5.4 Document Submission and Processing

Documents should be submitted via the secure upload facility in your account dashboard or, where specified, directly to our compliance team by email. Our compliance team aims to review and process submitted identity documents within 24 hours of receipt. If additional documents are required, we will notify you promptly. VIP members benefit from prioritised processing of both KYC documents and withdrawals as part of the fast-payout arrangement applicable to their membership tier.

All documents submitted are stored securely in accordance with our Privacy Policy. Document data is retained for the period required by applicable law and the conditions of our gaming licence.

5.5 Failure to Complete KYC

If a customer fails to provide the requested documents within a reasonable timeframe specified by our compliance team, betbluffs.nl reserves the right to:

• Suspend deposit and wagering activity on the account;
• Withhold withdrawal processing until verification is complete;
• Close the account and return any uncontested balance of verified funds, subject to applicable checks;
• File a suspicious activity report with the relevant authority where circumstances warrant.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied where a customer's risk profile is assessed as high. EDD may be triggered by any of the following circumstances:

• 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 classified as high-risk by FATF;
• Deposit or wagering volumes are materially inconsistent with the customer's stated income, occupation, or financial profile;
• The customer is using cryptocurrency as their primary payment method at high transaction volumes (approaching or at the €100,000 transaction ceiling);
• The customer's lifetime winnings exceed €30,000, triggering the monthly instalment payment schedule;
• Adverse media or intelligence is identified in relation to the customer or associated individuals;
• The customer's behaviour exhibits patterns consistent with known money laundering typologies.

Under EDD, a customer may be required to provide one or more of the following in addition to standard CDD documents:

• Source of Funds declaration and supporting evidence (e.g., payslips, bank statements covering a minimum of three months, dividend statements, sale of asset documentation);
• Source of Wealth declaration and supporting evidence;
• Enhanced identity verification, which may include video call verification;
• Detailed explanation of specific transactions or patterns of play;
• Evidence of tax compliance or business ownership where funds derive from self-employment or a business.

betbluffs.nl may place temporary limits on deposits, withdrawals, or wagering activity while an EDD review is in progress. We will endeavour to conduct EDD reviews expeditiously and to minimise disruption to customers who can satisfactorily evidence their position.

7. Politically Exposed Persons (PEPs)

betbluffs.nl screens all customers against recognised PEP databases at the point of registration and on an ongoing basis. A customer identified as a PEP, or as an immediate family member or known close associate of a PEP, will automatically be subject to EDD regardless of their transaction volumes or other risk indicators. Senior management approval is required before a business relationship is established or continued with a PEP. PEP status alone does not disqualify a customer from registering at betbluffs.nl, but such relationships require a higher standard of ongoing monitoring and documentation.

8. Sanctions Screening

betbluffs.nl screens all customers against applicable international sanctions lists, including those published by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and other relevant authorities. This screening is conducted at registration and on an ongoing basis as lists are updated. Any customer identified as a designated or blocked person will have their account suspended immediately. Funds held in such accounts will be dealt with in accordance with applicable sanctions law and our regulatory obligations. We will not knowingly conduct business with, or process transactions for, any person or entity subject to applicable sanctions.

9. Ongoing Monitoring

The AML and KYC obligation does not end at onboarding. betbluffs.nl conducts continuous monitoring of all customer accounts throughout the lifecycle of the relationship. This monitoring includes:

• Automated transaction monitoring against defined risk thresholds and behavioural baselines;
• Review of deposit and withdrawal patterns relative to the customer's stated profile;
• Monitoring of game play for patterns inconsistent with genuine recreational gambling (e.g., deliberate loss strategies, rapid cycling of deposits and withdrawals with minimal wagering);
• Periodic re-screening against PEP and sanctions databases;
• Periodic review and refresh of KYC documentation, particularly where a customer's risk profile has changed or where documents are approaching expiry;
• Manual review of accounts flagged by automated systems or internal reports.

Our monitoring system applies specific attention to cryptocurrency transactions, given the higher transaction ceilings available — up to €100,000 per transaction — and the pseudonymous nature of some crypto assets. All crypto activity is subject to blockchain analytics tools to identify wallet addresses associated with illicit activity.

10. Suspicious Activity Reporting

All employees and contractors of betbluffs.nl who identify or suspect money laundering, terrorist financing, or any other financial crime are required to report their suspicion to the designated Compliance Officer without delay, using the internal reporting procedures established for this purpose. Internal reports must be made promptly and must contain sufficient detail to allow the Compliance Officer to evaluate the suspicion. Employees must not "tip off" the subject of a suspicious activity report — disclosing the existence of a report or investigation to the customer concerned, or to any associated party, is strictly prohibited.

The Compliance Officer will evaluate each internal report and determine whether it is necessary to file a Suspicious Activity Report (SAR) or equivalent disclosure with the appropriate authority. Records of all internal reports and the decisions made in respect of them are maintained securely.

11. Red Flags and Suspicious Activity Indicators

The following non-exhaustive list identifies behaviours and circumstances that may give rise to suspicion and will trigger review:

• A customer depositing funds and then withdrawing them rapidly, with little or no genuine wagering activity in between;
• A customer wagering in a manner designed to generate a near-certain return (e.g., covering all outcomes in a live event) rather than for genuine entertainment;
• Deposits that are structurally split into amounts just below the €2,000 KYC trigger threshold;
• Multiple accounts registered with similar personal details or from the same device or IP address;
• A customer providing inconsistent, implausible, or contradictory information about their identity, occupation, or source of funds;
• A customer expressing undue concern about the KYC process or seeking to avoid or delay verification;
• Large cryptocurrency deposits from wallets that cannot be verified or that are flagged by blockchain analytics tools;
• Sudden and unexplained increases in deposit volumes inconsistent with the customer's prior history and stated profile;
• Third-party deposits — that is, funds received from a payment method not registered in the customer's own name;
• Winnings exceeding €30,000 where the customer's depositing history does not support a plausible path to that outcome;
• Requests to change withdrawal destination to a different payment method from that used for the original deposit (noting that our policy is that withdrawals must return to the same method as the deposit).

12. Third-Party Payments

betbluffs.nl operates a strict policy that withdrawals are processed exclusively to the same payment method used to make the corresponding deposit. This applies without exception to all fiat and cryptocurrency payment methods available on the platform, including LuxonPay, MiFinity, Cashlib, and all eight supported cryptocurrencies (Bitcoin, Bitcoin Cash, Ethereum, Litecoin, USDT on Ethereum and TRON, and USD Coin on Ethereum and Solana). The same-source withdrawal rule is a core anti-money laundering control, designed to prevent the layering of funds through our cashier. Deposits made from payment accounts that cannot be verified as belonging to the registered customer will not be accepted, and any funds received from a third party may be frozen pending investigation and returned to their source.

13. Large Wins and Instalment Payments

In accordance with our payment terms, any single win exceeding €30,000 is paid out in monthly instalments rather than as a single lump sum. This policy is applied consistently and serves, among other purposes, as a control point at which enhanced scrutiny of the underlying transaction can be applied. Progressive jackpot wins are paid in full as a single payment and are not subject to the instalment arrangement. In either case, winnings will not be released until KYC verification is fully complete and any applicable due diligence reviews have been concluded to the satisfaction of our compliance team.

14. Cryptocurrency-Specific Controls

betbluffs.nl accepts eight cryptocurrencies — Bitcoin (BTC), Bitcoin Cash (BCH), Ethereum (ETH), Litecoin (LTC), USDT (on Ethereum and TRON), and USD Coin (on Ethereum and Solana) — with a deposit ceiling of €100,000 per transaction. Given the elevated risk profile that cryptocurrency transactions may present, the following additional controls apply:

• All cryptocurrency deposit addresses are screened using blockchain analytics tools prior to acceptance of funds;
• Wallets flagged as associated with darknet markets, mixers/tumblers, ransomware, theft, or other illicit activity will be rejected and the deposited funds may be held pending investigation;
• Customers transacting in cryptocurrency at higher volumes are subject to accelerated KYC review and may be required to demonstrate source of funds at lower thresholds than the standard €2,000 trigger;
• Cryptocurrency withdrawals are paid to the same wallet address used for the deposit, in line with our same-source withdrawal policy;
• We do not accept privacy coins or other assets designed to obscure the transaction trail.

15. Record Keeping

betbluffs.nl retains all KYC documents, transaction records, account activity logs, and AML-related correspondence for a minimum of five years from the date of the relevant transaction or the date on which the customer relationship ends, whichever is the later. This retention period may be extended where required by applicable law, a regulatory requirement, or ongoing legal proceedings. All records are stored securely with access restricted to authorised compliance and senior management personnel. Records will be made available to the relevant licensing authority, law enforcement agencies, and other competent authorities upon receipt of a lawful request.

16. Staff Training

All personnel involved in customer-facing activity, financial processing, or compliance functions at betbluffs.nl receive AML and KYC training appropriate to their role. Training covers the legal framework governing AML obligations, recognition of suspicious activity indicators, internal reporting procedures, the tipping-off prohibition, and the practical application of this Policy. Training is provided at induction and refreshed at regular intervals, and additionally whenever there is a material change to applicable law, regulatory guidance, or internal policy. Records of training completion are maintained by the Compliance Officer.

17. Responsible Gambling Interaction with AML

betbluffs.nl recognises that problem gambling and money laundering can present overlapping behavioural indicators — for example, a customer who is chasing losses may exhibit patterns that superficially resemble certain money laundering typologies, and vice versa. Our compliance and responsible gambling functions work in close coordination to ensure that customers identified through either process receive the appropriate response. Where a customer's behaviour gives rise to concern on either a responsible gambling or an AML basis, both sets of safeguards will be applied. Players who wish to set deposit limits, cooling-off periods, or self-exclusions may do so at any time; these tools remain available and are independent of any ongoing compliance review.

18. Prohibited Customers and Jurisdictions

betbluffs.nl does not accept registrations from customers resident in jurisdictions where online gambling is prohibited by local law, or from jurisdictions identified by FATF as high-risk and subject to a call for action. A current list of restricted and prohibited jurisdictions is maintained internally and is applied at the point of registration through automated geolocation and IP-checking tools, as well as at the KYC verification stage. Customers who are found to have misrepresented their country of residence at the time of registration will have their accounts closed and any applicable funds dealt with in accordance with our terms and conditions and applicable law.

betbluffs.nl does not open accounts for, or provide services to:

• Persons under the age of 18;
• Persons on applicable sanctions lists;
• Persons who have been self-excluded or excluded by operator action;
• Corporate entities or legal persons (accounts are personal and non-transferable);
• Persons acting on behalf of a third party.

19. Policy Review and Updates

This Policy is reviewed by the designated Compliance Officer on at least an annual basis, and additionally whenever there is a material change in applicable law, regulatory guidance, the conditions of our Anjouan gaming licence (ALSI-202502014-FI1), or the risk environment in which betbluffs.nl operates. Updates to this Policy are published on betbluffs.nl and take effect immediately upon publication. Continued use of the platform following publication of an updated Policy constitutes acceptance of the revised terms.

20. Contact and Reporting

If you have a query relating to the KYC verification process, or if you wish to submit documents for review, please contact our compliance team via the 24/7 live chat facility on betbluffs.nl or by email through the address provided in your account dashboard. Our support team, operating around the clock via Zendesk live chat, will direct KYC-specific queries to the appropriate compliance personnel. Our compliance team aims to acknowledge KYC submissions and respond to verification queries within 24 hours.

If you have concerns about potential money laundering or financial crime in connection with betbluffs.nl, you may contact the Compliance Officer directly via the email address held on record, or you may contact the Government of the Autonomous Island of Anjouan as the relevant licensing authority. betbluffs.nl is committed to cooperating fully with all lawful enquiries from regulatory and law enforcement bodies.