This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of VENUS DEL ALMA LIMITADA ("the Operator", "we", "us", "our"), the company behind Mamabet, operated at mama-bet.nl, with respect to the prevention of money laundering, terrorist financing, and financial crime. All registered players ("you", "your") are subject to this Policy as a condition of using our services. We reserve the right to amend this Policy at any time; the current version is always available at mama-bet.nl.

1. Legal Framework and Regulatory Basis

Mamabet is owned and operated by VENUS DEL ALMA LIMITADA, a company incorporated in Costa Rica and licensed under Costa Rican law to offer online gambling services. Although our primary licence is issued in Costa Rica, the Operator voluntarily adopts internationally recognised anti-money laundering ("AML") standards — including those set out by the Financial Action Task Force (FATF) — as the foundation for all customer due diligence, monitoring, and reporting procedures. These standards reflect best practice across the global iGaming industry and form an integral part of our commitment to operating a safe, transparent, and responsible platform.

Money laundering is the process of making illegally obtained funds appear legitimate. Terrorist financing involves the use of funds, whether from legal or illegal sources, to support terrorist activity. Both practices cause serious harm to society, and Mamabet maintains a zero-tolerance approach to either being facilitated through its platform.

2. Scope of This Policy

This Policy applies to:

• All individuals who register an account at mama-bet.nl;
• All deposits and withdrawals processed through the platform, whether by fiat payment methods (Visa, Mastercard, bank transfer, Apple Pay, Google Pay) or by any of the 21 supported cryptocurrencies;
• All promotional activity, including welcome bonuses, weekly reload bonuses, free spins, freebets, cashback, and VIP rewards;
• All staff, agents, and third-party service providers acting on behalf of the Operator.

3. Our AML Risk Approach

The Operator applies a risk-based approach to AML compliance. This means we assess the money-laundering risk associated with each customer relationship and transaction and apply proportionate controls. Factors we consider when assessing risk include, but are not limited to:

• The customer's country of residence and nationality;
• The source of funds and the payment methods used;
• The volume, frequency, and pattern of deposits and withdrawals;
• Whether the customer is a Politically Exposed Person (PEP) or is subject to sanctions;
• Unusual or inconsistent account activity relative to the customer's declared profile;
• The speed and size of withdrawals relative to recent deposits;
• Use of multiple cryptocurrencies or switching between coins without apparent reason.

Customers identified as higher risk are subject to Enhanced Due Diligence (EDD) measures, which may include additional document requirements, expanded source-of-funds verification, and closer ongoing monitoring.

4. Know Your Customer (KYC) Programme

4.1 Why We Collect Your Information

KYC procedures allow us to verify that you are who you say you are, that you are of legal age to gamble, that your funds come from a legitimate source, and that your account is not being used to launder money or fund criminal activity. KYC is also fundamental to our Responsible Gambling commitments, enabling us to identify vulnerable players and intervene appropriately.

4.2 KYC Provider

Mamabet conducts identity verification through Sumsub, a specialist identity verification platform. The process is designed to be quick and straightforward. Under normal circumstances, verification is completed within 24 hours of document submission. You will be guided through the process when you request your first withdrawal.

4.3 When KYC Is Required

KYC verification is mandatory before any withdrawal is processed. We may also request identity documents at any point during your account lifecycle where we have reasonable grounds to do so, including but not limited to:

• Prior to processing your first withdrawal request;
• When cumulative deposits exceed internal risk thresholds;
• When account activity triggers an automated or manual risk flag;
• When a player requests an increase to their withdrawal limits above the standard weekly limit of €10,000;
• When we are required to perform Enhanced Due Diligence;
• At any point we deem it necessary for compliance purposes.

4.4 Standard KYC Documents

To complete standard verification, you must provide the following:

Documents must be submitted in colour. Black-and-white copies, screenshots, or heavily compressed images may be rejected. We reserve the right to request original documents where digital copies cannot be verified to our satisfaction.

4.5 Source of Funds Verification

In addition to identity verification, we may require you to demonstrate the legitimate origin of the funds held in or deposited to your Mamabet account. This requirement may be triggered by high-value transactions, rapid cycling of funds, or any other activity that is inconsistent with your stated profile. Acceptable source-of-funds documentation includes, but is not limited to:

• Recent payslips or an employer's letter confirming salary;
• Bank statements covering a period specified by our compliance team;
• Evidence of business ownership or trading income (e.g., company accounts, tax returns);
• Documentation relating to an inheritance, property sale, or investment return;
• Any other documentation the Operator reasonably requests to satisfy itself as to the legitimacy of your funds.

Failure to provide satisfactory source-of-funds documentation will result in the suspension of withdrawal rights and may lead to permanent account closure.

4.6 Cryptocurrency Transactions and KYC

Mamabet supports 21 cryptocurrencies, processed through CoinsPaid and CatPay. Cryptocurrency deposits and withdrawals are subject to the same KYC standards as fiat transactions. Additionally, players should be aware of the following:

• Crypto deposits may only be withdrawn via the same cryptocurrency rail — fiat and crypto payment paths cannot be mixed;
• We may request on-chain transaction evidence to verify the source of cryptocurrency funds;
• Wallets identified as associated with mixing services, darknet markets, or other high-risk entities may be refused;
• Blockchain analytics tools may be used to assess the risk profile of incoming cryptocurrency transactions.

5. Customer Due Diligence (CDD) Levels

5.1 Standard Due Diligence (SDD)

Applied to the majority of customers at registration and when processing routine transactions. Involves collection of name, date of birth, address, email address, and verification of identity and address documents as described in Section 4.4.

5.2 Enhanced Due Diligence (EDD)

Applied to customers who present a higher risk profile. EDD may involve one or more of the following measures in addition to standard checks:

• Detailed source-of-wealth and source-of-funds documentation;
• Additional identity verification steps through Sumsub;
• Senior management approval before account activity resumes;
• Increased frequency of ongoing monitoring;
• Temporary or permanent withdrawal restrictions pending investigation.

5.3 Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds or has held a prominent public function, as well as their immediate family members and close associates. All PEPs are automatically classified as high-risk customers and subject to EDD. PEPs may be permitted to hold an account at mama-bet.nl only following explicit senior management approval and subject to enhanced ongoing monitoring.

5.4 Sanctions Screening

All customers are screened against international sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and the United Kingdom's Office of Financial Sanctions Implementation (OFSI). Any match, or close match, against a sanctions list will result in the immediate suspension of the account pending investigation. Where a confirmed sanctions match is identified, the account will be closed and any relevant authorities notified as required by law.

6. Ongoing Monitoring

KYC is not a one-time event. The Operator conducts continuous monitoring of all active accounts, including:

• Automated transaction monitoring that flags unusual deposit and withdrawal patterns;
• Periodic review of customer profiles to ensure information remains accurate and up to date;
• Assessment of cumulative transaction volumes against declared financial profiles;
• Detection of structuring behaviour — the practice of breaking up large transactions into smaller amounts to avoid triggering verification thresholds;
• Review of bonus activity to identify patterns consistent with bonus abuse or money laundering;
• Monitoring of VIP-level accounts, which may transact at higher volumes due to increased weekly withdrawal limits.

Where ongoing monitoring reveals activity that cannot be explained to our satisfaction, we will request additional information from the account holder. Accounts may be suspended during any investigation.

7. Suspicious Activity and Internal Reporting

All members of the Operator's staff are trained to recognise indicators of money laundering or suspicious activity. The Operator has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for receiving internal reports of suspicious activity, investigating those reports, and making disclosures to the relevant authorities where required.

Indicators of suspicious activity that may trigger an internal report include, but are not limited to:

• Large deposits followed immediately by withdrawal requests with minimal or no gameplay;
• Use of multiple payment methods or cryptocurrencies in a single session without plausible explanation;
• Withdrawal requests exceeding the standard weekly limit of €10,000 for unverified or recently verified accounts;
• Deposits and withdrawals that consistently match in amount, suggesting pass-through use of the platform;
• Reluctance to provide KYC documentation without adequate explanation;
• Use of VPN or anonymisation tools to obscure the account holder's true location;
• Third-party payments — deposits funded from an account not held in the player's own name.

Mamabet operates a strict policy against tipping off. This means that where a suspicious activity report has been submitted, we are legally prohibited from informing the subject of that report. Accordingly, an account may be suspended or restricted without explanation in circumstances where disclosure would constitute tipping off.

8. Prohibited Activities

The following activities are strictly prohibited at mama-bet.nl and will result in immediate account suspension, forfeiture of funds where lawfully permitted, and reporting to the relevant authorities:

• Depositing funds derived from criminal activity of any kind;
• Using the platform as a conduit to transfer funds between third parties;
• Providing false, misleading, or incomplete information during registration or KYC;
• Attempting to circumvent withdrawal limits through the use of multiple accounts;
• Making deposits from payment accounts held in a name other than your own;
• Using cryptocurrency mixing, tumbling, or obfuscation services prior to depositing funds;
• Opening accounts on behalf of another person (nominee accounts);
• Any form of collusion, bonus abuse, or exploitation of the platform for financial gain unrelated to genuine gambling.

9. Withdrawal Procedures and AML Controls

All withdrawal requests at Mamabet are subject to the following conditions:

Withdrawals are reviewed by our payments and compliance teams before processing. We reserve the right to delay a withdrawal request where additional verification is required or where a transaction has been flagged for review. In such cases, we will endeavour to contact you promptly to request any further information needed.

Where a withdrawal request is declined on AML grounds, we will notify you that the request cannot be processed at this time, subject to any tipping-off restrictions described in Section 7.

10. Bonuses, Promotions, and AML Considerations

Promotional activity at Mamabet — including the casino welcome package (up to €1,500 plus 150 free spins), the sports freebet (300% up to €500), weekly reload bonuses, Friday cashback (up to 20%), and VIP level-up rewards — is subject to AML oversight. The Operator monitors bonus activity to detect patterns inconsistent with genuine play.

Players should be aware of the following:

• Bonuses require wagering requirements to be met (x40 for casino bonuses; x10 for sports freebets) before withdrawal, reducing the platform's attractiveness as a money-laundering vehicle;
• Cashback rewards of up to 20% are credited as cash with no wagering requirement — these are subject to the same withdrawal verification procedures as any other funds;
• The Store, where loyalty points may be exchanged for free spins and cash bonuses, is monitored for unusual redemption patterns;
• Multi-accounting to claim duplicate bonuses is prohibited and may constitute fraud as well as an AML risk;
• Players who deposit significantly in excess of their gambling activity — for example, depositing €5,000 to claim a sport deposit freebet and immediately requesting withdrawal — may be subject to EDD and source-of-funds checks.

11. Record Keeping

The Operator retains all KYC documentation, transaction records, account activity logs, and internal compliance reports for a minimum period of five (5) years from the date of the transaction or the date on which the customer relationship ends, whichever is later. Records are stored securely and may be disclosed to competent authorities upon lawful request. This retention obligation applies regardless of whether an account has been closed, suspended, or deactivated.

12. Staff Training

The Operator ensures that all relevant staff members receive regular training in AML and KYC obligations, including how to identify suspicious activity, how to submit an internal report to the MLRO, and what constitutes tipping off. Training is reviewed and updated periodically to reflect changes in applicable standards and emerging money-laundering typologies within the online gambling sector.

13. Third-Party Processors and Service Providers

Mamabet works with regulated third-party payment processors, including CoinsPaid and CatPay for cryptocurrency transactions, and Sumsub for identity verification. All third-party providers are assessed for their own AML and data-protection compliance prior to onboarding. The Operator remains responsible for the overall AML framework and does not outsource its compliance obligations.

14. Data Protection

Personal data collected for KYC and AML purposes — including identity documents, selfies, proof of address, and financial records — is processed solely for the purposes described in this Policy and in accordance with our Privacy Policy, available at mama-bet.nl. We will not sell or share your personal data with third parties except where required for identity verification, fraud prevention, AML screening, or by operation of law. Data is stored securely and subject to access controls appropriate to its sensitivity.

15. Responsible Gambling and AML

AML compliance and responsible gambling are closely linked at Mamabet. Identity verification through Sumsub helps us ensure that all players are of legal age and playing within their financial means. Where KYC or source-of-funds checks reveal that a player may be experiencing financial difficulty, our responsible gambling team may be informed. Players who display signs of problematic gambling behaviour may be subject to additional account restrictions. For responsible gambling tools and self-exclusion options, please refer to our Responsible Gambling Policy at mama-bet.nl.

16. Cooperation with Authorities

The Operator will cooperate fully with any competent authority, law enforcement agency, or regulatory body that makes a lawful request for information relating to a customer's account or transactions. Where we are required by law to freeze, withhold, or return funds pending investigation, we will do so without prior notice to the account holder. Mamabet does not accept liability for any loss arising from account restrictions imposed in good faith for AML compliance purposes.

17. Contact and Reporting

If you have questions about this Policy or wish to submit information relevant to our AML procedures, you may contact our compliance team through any of the following channels:

• Live chat: Available 24/7 at mama-bet.nl
• Email: As listed in the Contact section of mama-bet.nl
• Telegram: As listed in the Contact section of mama-bet.nl

This Policy was last reviewed and updated in 2025. VENUS DEL ALMA LIMITADA reserves the right to amend this Policy at any time without prior notice. Continued use of mama-bet.nl following any amendment constitutes acceptance of the revised Policy.