GEMWIN

Anti-Money Laundering (AML) & Combating the Financing of Terrorism (CFT)-Compliance Policy

1. Introduction

Gemwin is owned and operated under the oversight of the Government of Curaçao, holding a valid gaming license issued by the Curaçao Gaming Authority (CGA). Gemwin operates in accordance with the applicable laws and regulations of Curaçao, including:

  • The National Ordinance on the Identification of Clients (NOIS)
  • The National Ordinance for the Reporting of Unusual Transactions (NORUT)
  • The AML/CFT Guidelines for Online Gaming Operators issued by the Curaçao Gaming Authority.

This means that Gemwin fully adheres to all anti-money laundering and compliance requirements mandated by the CGA and international standards. We are committed to operating legally and transparently, while protecting our platform from being misused for illicit financial activities.

This AML & CFT Compliance Policy is established to ensure that Gemwin consistently complies with Curaçao laws and best practices in anti-money laundering, in line with the recommendations of the Financial Action Task Force (FATF) and the European Union’s Anti-Money Laundering Directives.

2. Objectives

Gemwin’s AML & CFT Compliance Policy is aimed at the following key objectives:

  • Preventing the use of our platform for money laundering, terrorist financing, or other financial crimes;
  • Protecting the integrity of the financial system and safeguarding legitimate players from the impacts of illicit behavior;
  • Complying strictly with all applicable Curaçao regulations and international AML/CTF standards;
  • Maintaining the brand’s lawful reputation through transparency and accountability; and
  • Cooperating actively with the CGA, the Financial Intelligence Unit (FIU Curaçao), and other competent authorities to contribute to global efforts against financial crime.

3. Definitions

  • Money Laundering (ML): Concealing the origin or ownership of illicit funds to make them appear legitimate.
  • Terrorism Financing (TF): Providing funds or resources to support terrorist activities.
  • Politically Exposed Persons (PEPs): Individuals with prominent public functions, including family or close associates.
  • Ultimate Beneficial Owner (UBO): The natural person(s) who ultimately owns or controls a customer or entity.
  • Third Party: Any customer, vendor, business partner, agent, or governmental entity interacting with Gemwin.
  • Risk-Based Approach (RBA): Identifying and prioritizing ML/TF risks to apply controls proportional to the level of risk.
  • Suspicious Transaction: Any activity inconsistent with a customer’s normal behavior, lacking an economic purpose, or indicative of ML/TF.

4. Control Measures

Gemwin has implemented a comprehensive anti-money laundering and combating the financing of terrorism (AML/CFT) program with strict internal controls to detect and prevent money laundering in accordance with NOIS, NORUT, and CGA AML guidelines. These measures are proportional to the risks associated with online gambling activities including the following: designed in accordance with Curaçao’s legal framework and international AML best practices. In particular, we undertake:

4.1. Identity Verification and KYC

All customers must undergo a Know Your Customer (KYC) process to verify their identity, age, and residential address at the time of registration. Gemwin checks and corroborates personal information against government-issued IDs (national ID, passport, driver’s license, etc.) and other documents such as utility bills or bank statements to verify address when necessary.

4.2. Customer Due Diligence (CDD) and Risk Assessment

Gemwin applies a risk-based approach to customer due diligence. Customers are categorized as low, medium, or high risk based on factors including jurisdiction, transaction behaviour, payment methods, and source of funds indicators.

4.3. Customer Due Diligence (CDD) and Risk Assessment

EDD is automatically applied for high risk customers, including but not limited to Politically Exposed Persons (PEPs), users engaging in large or unusual transactions, and customers using cryptocurrencies. Enhanced Due Diligence (EDD) can include collecting additional identity documents, verifying source of funds/wealth, and intensifying monitoring of their activities.

Customer risk profiles are reviewed periodically and upon the occurrence of trigger events.

4.4. Transaction Monitoring and Review

We employ advanced technology systems to monitor transactions in real time and on a periodic basis, helping to automatically detect patterns indicative of suspicious behavior. Red flags include players depositing large sums with minimal gameplay followed by withdrawals (large deposits, little play), rapid withdrawals shortly after deposits, frequent deposit-and-withdrawal cycles, or structured transactions designed to evade reporting thresholds.

Our system will automatically alert if it detects transactions exceeding certain thresholds (for example, cumulative transactions above a value equivalent to ANG 4,000, per Curaçao regulations) or any activity that appears to be structuring to avoid detection. Our compliance team reviews these alerts manually to decide on appropriate action, such as temporarily freezing the account or requesting additional information from the player.

4.5. Suspicious Transaction Reporting (STR/SAR)

As part of our legal obligations, Gemwin will promptly report any suspicious activity or transaction to the Curaçao Financial Intelligence Unit (FIU) or the relevant authority. We strictly adhere to the requirement of no tipping-off, meaning we do not inform the customer if they are under investigation or being reported. This ensures investigations are not compromised and that we fully cooperate with authorities in addressing the incident.

4.6. Record-Keeping and Data Security

All customer KYC records, transaction information, and AML related reports are securely retained in our system for a minimum of 5 years or longer, as required by law. Gemwin ensures compliance with data protection laws, including GDPR where applicable, and ensures that personal data is disclosed to authorities only upon lawful request. We also employ stringent information security measures (such as data encryption, access controls, and regular vulnerability assessments) to prevent any data leaks or unauthorized access.

4.7. Compliance Officer and Staff Training

Gemwin has appointed a senior AML Compliance Officer (also known as the Money Laundering Reporting Officer (MLRO)) who is responsible for overseeing our entire AML/CFT framework. The MLRO has direct access to senior management and has the authority to submit STRs to the FIU Curaçao without undue influence.

Mandatory training is provided to all employees on AML policies and risk indicators. Training is documented and refreshed periodically to ensure our team remains compliant and vigilant in our anti-money laundering efforts.

5. User Obligations

In order to maintain a safe and compliant gaming environment, we require users at Gemwin to fulfill the following obligations:

  • Provide Accurate Information
  • Identity Verification (KYC)
  • Legitimate Source of Funds
  • Personal Account which is non-transferable
  • No Player-to-Player Transfers
  • Monitor Your Account Activity
  • Abide by Terms and Laws

6. Role of Monitoring System

Gemwin’s transaction monitoring system plays a central role in our AML/CFT framework. Automated monitoring tools are configured using a risk-based methodology and configured in accordance with CGA guidance and recognized industry standards.

The system continuously analyzes transactional and behaviour data to detect deviations from expected patterns and known money laundering methods. Alerts generated by the system are reviewed promptly by compliance staff under the supervision of the MLRO.

The monitoring framework is reviewed regularly and updated to reflect changes in regulator expectations, emerging risks, and operational experience. AML/CFT reporting will support management oversight and regulatory reporting obligations.

7. Cooperation with Law Enforcement

Gemwin cooperates fully with the Curaçao Gaming Authority, FIU Curaçao, and other competent authorities. Upon lawful request, we will provide relevant records, transaction data, and customer information in a timely and controlled manner.

All disclosures are logged, legally justified, and conducted in compliance with data protection requirements. company prioritizes responsiveness to regulatory inquiries and enforcement actions.

8. Commitment to Transparency

Gemwin is committed to transparency in its operations, regulatory disclosures, and communications with users. Licensing information, and material compliance updates are made publicly available.

Financial transactions are clearly recorded, and all verification and withdrawal processes are communicated transparently. Gemwin maintains open and cooperative communication with regulators and promptly addresses any regulatory findings or recommendations.

Through these measures, Gemwin affirms its commitment to lawful, transparent, and responsible gaming operations under the regulatory oversight of Curaçao.

9. Review

Gemwin is committed to ensuring that its AML & CFT Compliance Policy and related procedures remain effective and fully aligned with applicable Curaçao laws and regulatory expectations. This policy is subject to a formal review at least annually or following regulatory updates or material changes occurring, whichever comes first.