This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of AccelCore Enterprise Limitada ("we", "us", "our"), operator of dicespin (dicespins.org), to detect, prevent, and report money laundering, terrorist financing, and related financial crime. dicespin operates under Anjouan licence ALSI-202506031-FI2 (verifiable at verification.anjouangamingboard.org) and is committed to full compliance with applicable laws, licensing conditions, and international best-practice standards. All players, staff, and business partners are bound by this Policy.
1. Definitions
- AML — Anti-Money Laundering: the body of law, regulation, and procedure designed to prevent the concealment of illegally obtained funds.
- KYC — Know Your Customer: the process by which dicespin verifies the identity, address, source of funds, and source of wealth of its players.
- Money Laundering (ML) — the process of making criminally derived proceeds appear legitimate, typically through placement, layering, and integration.
- Terrorist Financing (TF) — the provision or collection of funds intended to be used to carry out terrorist acts or to support terrorist organisations.
- Politically Exposed Person (PEP) — an individual who holds, or has held within the preceding twelve months, a prominent public function, or a close family member or known associate of such a person.
- Suspicious Transaction Report (STR) — a formal report submitted to the relevant authority when dicespin suspects that funds are connected to money laundering or terrorist financing.
- Enhanced Due Diligence (EDD) — additional scrutiny applied to higher-risk players beyond standard KYC requirements.
- MLRO — Money Laundering Reporting Officer: the designated senior individual responsible for overseeing AML/KYC compliance at dicespin.
2. Scope and Application
This Policy applies to all individuals who register and play at dicespins.org, regardless of nationality, country of residence, or currency used. It applies across all product verticals offered on the platform, including casino games from our library of 8,650+ titles, the Altenar-powered sportsbook, live casino tables, and all other services accessible via dicespins.org. It governs transactions in all accepted currencies: EUR, USD, AUD, CAD, CZK, NOK, PLN, CHF, and NZD.
This Policy also applies to all employees, agents, contractors, and third-party service providers who perform functions on behalf of AccelCore Enterprise Limitada in connection with dicespins.org.
3. Legal and Regulatory Framework
AccelCore Enterprise Limitada is incorporated in Costa Rica (registration number 3102926243) and holds gaming licence ALSI-202506031-FI2 issued by the Anjouan Gaming Board. dicespin conducts its AML and KYC activities in accordance with:
- The conditions and requirements of Anjouan licence ALSI-202506031-FI2;
- The Financial Action Task Force (FATF) Recommendations on combating money laundering and terrorist financing;
- International standards applicable to online gaming operators, including those relating to customer due diligence, record-keeping, and suspicious activity reporting;
- Costa Rican corporate law applicable to AccelCore Enterprise Limitada as the legal entity operating the site.
4. Risk-Based Approach
dicespin adopts a risk-based approach (RBA) to AML and KYC compliance. This means that the level of due diligence applied to any individual player is proportionate to the assessed risk that the player, product, transaction, or jurisdiction presents. The RBA allows us to allocate compliance resources efficiently whilst ensuring that higher-risk situations receive the scrutiny they require.
Risk factors considered when assessing a player's profile include, but are not limited to:
- Country or jurisdiction of residence;
- Deposit volumes, frequency, and patterns relative to stated income or occupation;
- Withdrawal patterns, including requests to withdraw funds shortly after deposit with minimal or no play;
- Payment methods used and consistency of those methods;
- PEP or sanctions-list status;
- Adverse media coverage or prior reported financial crime involvement;
- Unusual betting patterns or stake sizes inconsistent with play history;
- Rapid switching between products (e.g. moving funds between casino wallet and sportsbook without substantive play).
Risk levels are categorised as Low, Medium, or High. Players assessed as High risk are subject to Enhanced Due Diligence before continued play is permitted.
5. Customer Due Diligence (CDD)
5.1 When CDD is Triggered
dicespin will initiate Customer Due Diligence procedures in the following circumstances:
- At the point of account registration, for all new players;
- Before processing any withdrawal, regardless of amount;
- When cumulative deposits, withdrawals, or net activity exceed internal thresholds set by the MLRO;
- When a player's behaviour or transaction patterns give rise to suspicion;
- When any transaction or series of transactions appears unusual, inconsistent with prior activity, or otherwise indicative of ML or TF;
- When the MLRO determines that a periodic review of an existing player's profile is necessary;
- Where there is any doubt about the veracity or adequacy of previously obtained identification information.
5.2 Standard KYC Documents
To satisfy standard CDD requirements, players will be asked to provide the following documents. Copies must be clear, legible, valid, and unedited. dicespin reserves the right to request certified copies or to use electronic verification services at its discretion.
| Verification Type | Acceptable Documents |
|---|---|
| Proof of Identity (POI) | Valid national passport; national identity card (front and back); government-issued driving licence with photograph |
| Proof of Address (POA) | Utility bill (gas, electricity, water, internet) dated within 90 days; bank statement dated within 90 days; official government correspondence dated within 90 days; municipal tax notice |
| Proof of Banking Option | Photograph or screenshot of payment card showing name and last four digits (middle digits redacted); bank account statement showing account holder name and IBAN/account number; e-wallet account screenshot confirming ownership |
| Proof of Date of Birth | Contained within the POI document listed above; where not legible, a birth certificate may be requested |
All documents submitted must be current and valid. Expired identity documents will not be accepted. Where a document is not in English, dicespin may request a certified translation at the player's expense.
5.3 Verification Timeline
Players are encouraged to complete KYC verification promptly upon registration to avoid delays when withdrawing funds. Withdrawal requests will not be processed until verification is complete. dicespin aims to review submitted documents within one to three business days. If documents are incomplete or of insufficient quality, the compliance team will contact the player by email to request resubmission. The payout speed of one to three business days stated in our cashier documentation runs from the point at which verification is fully and satisfactorily completed.
5.4 Minimum Deposit and Withdrawal Thresholds
As a reference point for transaction monitoring, all players should be aware of the following cashier limits which are relevant to the practical application of CDD:
| Parameter | Amount |
|---|---|
| Minimum Deposit | €20 |
| Minimum Withdrawal | €50 (€3 processing fee, refunded if the withdrawal is not processed) |
| Maximum Withdrawal — Daily | €5,000 |
| Maximum Withdrawal — Weekly | €10,000 |
| Maximum Withdrawal — Monthly | €40,000 |
Any requests that approach or exceed these limits will be subject to enhanced transaction monitoring. Players requesting withdrawals that approach the monthly maximum may be required to provide Source of Funds or Source of Wealth documentation before the withdrawal is authorised.
6. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied to players who present a higher risk of involvement in money laundering or terrorist financing. EDD is not a punitive measure; it is a proportionate compliance response to elevated risk indicators. Players subject to EDD may be asked to provide some or all of the following, in addition to standard KYC documents:
6.1 Source of Funds (SOF)
Source of Funds documentation demonstrates the origin of the specific funds deposited into the player's dicespin account. Acceptable evidence includes:
- Recent payslips or employment contract confirming salary;
- Self-assessment tax returns or business accounts for the self-employed;
- Dividend certificates or investment income statements;
- Pension award letters;
- Bank statements showing the inward credit of funds matching the amounts deposited;
- Proof of property sale, inheritance, or legal settlement (as applicable).
6.2 Source of Wealth (SOW)
Source of Wealth documentation provides a broader picture of how a player accumulated their overall assets. This may include:
- Business ownership documents and audited accounts;
- Evidence of asset sales (e.g. conveyancing documents for property, share sale confirmations);
- Inheritance documentation (e.g. grant of probate, solicitor's letter);
- Evidence of high-value employment or director remuneration over time.
6.3 Politically Exposed Persons (PEPs)
dicespin screens all players against recognised PEP databases at registration and on an ongoing basis. A PEP, or an immediate family member or known close associate of a PEP, will automatically be classified as High Risk and subjected to EDD before their account may be used for real-money play. Senior management approval is required before a PEP account may be activated or continued. PEP accounts are reviewed at least every twelve months.
6.4 Sanctions Screening
dicespin screens all players at registration and on an ongoing basis against internationally recognised sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and His Majesty's Treasury (UK HMT). Any player who matches or is closely associated with a designated individual or entity will have their account suspended immediately, and the matter will be referred to the MLRO for assessment. No funds will be released to a sanctioned individual or entity.
7. Ongoing Monitoring
KYC verification is not a one-time event. dicespin conducts continuous monitoring of player accounts and transaction activity throughout the customer lifecycle. Ongoing monitoring activities include:
- Automated transaction monitoring to flag deposits, withdrawals, or betting patterns that deviate significantly from a player's established profile;
- Periodic review of player risk classifications, with higher-risk accounts reviewed more frequently;
- Re-screening of all players against PEP and sanctions lists at regular intervals and whenever a relevant trigger event occurs;
- Manual review by the compliance team of flagged accounts, unusual activity reports, and customer support escalations;
- Monitoring of the relationship between deposited funds, bonus claims, cashback receipts, and withdrawal requests to identify patterns inconsistent with genuine recreational play.
Specific behaviours that will trigger an immediate review include, without limitation: multiple rapid deposits followed by withdrawal with little or no gameplay; deposits via multiple payment methods not previously associated with the account; large stake increases inconsistent with deposit and play history; and patterns designed to exploit promotional structures such as the daily 10% cashback without genuine engagement.
8. Suspicious Activity Reporting
All dicespin employees and agents are required to report any knowledge or reasonable suspicion of money laundering or terrorist financing to the MLRO without delay. The MLRO is responsible for reviewing all internal reports and, where warranted, filing a Suspicious Transaction Report (STR) with the relevant competent authority in accordance with applicable law and licensing obligations.
It is a serious offence under applicable law to "tip off" a player or any other person that a suspicion has been reported or that an investigation is under way. dicespin staff are strictly prohibited from disclosing any STR or related investigation to the subject of that report or to any third party not involved in the compliance process.
Where an account is under review following an STR, dicespin reserves the right to suspend the account, restrict deposits and withdrawals, and withhold any funds pending the outcome of the investigation and any direction from the relevant authority.
9. Account Suspension and Fund Retention
dicespin reserves the right to suspend or close an account at any stage of the KYC or AML process if:
- A player fails to provide requested documentation within a reasonable period as specified in the compliance team's request;
- Documents provided are found to be false, forged, altered, or otherwise fraudulent;
- A player's identity cannot be satisfactorily verified;
- A player is identified on a sanctions list;
- Transaction monitoring or ongoing review reveals activity consistent with money laundering, terrorist financing, or other financial crime;
- A player provides false or misleading information during registration or at any subsequent point;
- The MLRO determines that continued account activity presents an unacceptable risk to dicespin or to third parties.
Where an account is suspended or closed for AML/KYC reasons, dicespin may be legally obliged to retain funds pending instructions from the relevant competent authority. In such circumstances, dicespin will not be liable for any loss suffered by the player as a result of funds being withheld.
10. Record Keeping
dicespin maintains comprehensive records of all KYC documentation, transaction data, internal suspicion reports, STRs filed, and related communications in accordance with its licensing obligations and applicable law. Records are retained for a minimum of five (5) years from the date of the relevant transaction or the end of the business relationship, whichever is later. All records are stored securely and are accessible to the MLRO and, where lawfully required, to relevant regulatory or law enforcement authorities.
Player data is handled in accordance with dicespin's Privacy Policy, which governs how personal information is collected, processed, stored, and shared.
11. Age Verification
dicespin operates a strict minimum age requirement of eighteen (18) years for all players. Age verification is a mandatory component of the KYC process. No real-money account will be fully activated until the player's date of birth has been confirmed against a valid government-issued identity document. Where there is any reasonable doubt about a player's age, the account will be suspended pending verification. In the event that a minor is found to have accessed the site, all gameplay and funds will be voided and the matter will be reported as required by applicable law and licensing conditions. Parents and guardians are encouraged to use appropriate parental-control tools to prevent underage access to gambling sites, including dicespins.org.
12. Responsible Gambling and AML Interaction
dicespin recognises that problem gambling and financial vulnerability can create conditions that are relevant to AML risk. A player who is depositing beyond their apparent means, or whose stated occupation and income are inconsistent with their gaming activity, may require both responsible gambling intervention and AML review. These two processes are managed in parallel by the relevant teams and are not mutually exclusive.
Players who wish to set deposit limits, take a cooling-off period, or self-exclude may do so via the responsible gambling tools available within their account settings or by contacting support via Live Chat (powered by Intercom) or by emailing the support team. Self-exclusion and deposit-limit requests are implemented promptly and will not be overridden by any commercial consideration.
13. Staff Training
All employees of AccelCore Enterprise Limitada who are involved in the operation of dicespins.org, including customer support, payments, and compliance personnel, receive AML and KYC training appropriate to their role. Training covers the recognition of suspicious activity, the escalation procedure for internal reporting, the legal consequences of tipping off, and the sanctions-screening and PEP-identification processes. Training is conducted at induction and refreshed on a regular basis, or whenever there is a material change to applicable law, regulation, or internal procedure. Records of training completion are maintained by the MLRO.
14. The Money Laundering Reporting Officer (MLRO)
AccelCore Enterprise Limitada has appointed a designated Money Laundering Reporting Officer who holds overall responsibility for AML and KYC compliance at dicespins.org. The MLRO's responsibilities include:
- Overseeing the day-to-day operation of this Policy;
- Receiving and assessing all internal suspicious activity reports;
- Making decisions on whether to file STRs with competent authorities;
- Maintaining and updating AML/KYC procedures in response to regulatory developments;
- Supervising staff training and ensuring adequate compliance resources are in place;
- Liaising with the Anjouan Gaming Board and other relevant authorities as required.
Internal AML/KYC queries and suspicious activity reports should be directed to the MLRO via the designated internal compliance channel. Players with questions about their verification status may contact the dicespin compliance team by emailing [email protected] or via Live Chat at dicespins.org.
15. Third-Party Banking Options and Correspondent Risk
dicespin accepts deposits and processes withdrawals via a range of payment methods in the currencies listed (EUR, USD, AUD, CAD, CZK, NOK, PLN, CHF, NZD). All payment methods accepted by dicespin are assessed for AML risk prior to being made available in the cashier. Players are required to use payment methods registered in their own name; third-party payments — where funds are sent to or received from a payment method not belonging to the registered account holder — are strictly prohibited. Any transaction identified as involving a third-party payment method will be subject to immediate investigation and may result in account suspension and fund retention pending the outcome of that investigation.
Players may not use gambling accounts as a mechanism to transfer funds between payment methods. Where a deposit is made and withdrawn with little or no genuine play, this may be treated as an indicator of money laundering or payment-method manipulation, and the account will be referred to the MLRO.
16. Bonus and Promotional Integrity
dicespin's promotional offering — including the 200% casino welcome bonus up to €1,000, the 100% sports free bet up to €200, and the daily 10% cashback credited as real withdrawable cash by 11:00 UTC each morning — is available exclusively to genuine players engaging in bona fide recreational gambling. Any attempt to exploit promotional structures, including the daily cashback, in a manner consistent with bonus abuse, collusion, or money laundering will be treated as a serious breach of these terms. dicespin's transaction monitoring systems are calibrated to detect patterns of play that appear designed to generate withdrawable funds through promotional mechanisms rather than through genuine wagering activity. Accounts identified in this way will be subject to full KYC and AML review, and any outstanding bonuses or cashback credits may be voided pending that review.
17. Policy Review and Updates
This AML/KYC Policy is reviewed by the MLRO at least annually and updated whenever there is a material change to applicable law, regulation, licensing conditions, or internal risk assessment. AccelCore Enterprise Limitada reserves the right to amend this Policy at any time. The current version of this Policy is published at dicespins.org and supersedes all previous versions. Players are advised to check this page periodically. Continued use of dicespins.org following the publication of an updated Policy constitutes acceptance of the revised terms.
If you have any questions regarding this Policy or your verification requirements, please contact the dicespin compliance team via Live Chat at dicespins.org or by emailing [email protected]. We aim to respond to all compliance-related enquiries within one to three business days.