This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Mamabet Casino, operated by VENUS DEL ALMA LIMITADA at mama-bet.nl, and the requirements placed on all players who register and transact on the platform. Mamabet Casino is committed to preventing financial crime, protecting the integrity of its operations, and ensuring that its services are not used to launder the proceeds of unlawful activity or to finance terrorism.

1. Legal Framework and Regulatory Basis

Mamabet Casino holds a gaming licence issued under the jurisdiction of Costa Rica and operates under the legal entity VENUS DEL ALMA LIMITADA. Although Costa Rica's licensing framework differs from those of EU member-state gambling regulators, Mamabet Casino voluntarily adopts and enforces AML and KYC standards consistent with internationally recognised best practice, including the principles set out in the Financial Action Task Force (FATF) Recommendations and applicable anti-money laundering conventions.

This Policy applies to every account registered at mama-bet.nl, regardless of the player's country of residence, the currency used (including any of the 21 supported cryptocurrencies), or the payment method chosen. It covers all deposit and withdrawal activity, bonus participation, VIP programme membership, and any other financial transaction conducted through the platform.

2. Scope and Application

This Policy applies to:

• All natural persons who open or attempt to open an account at mama-bet.nl;
• All financial transactions processed through the cashier, including fiat deposits via Visa, Mastercard, Skrill, Neteller, Apple Pay, Google Pay, Revolut, Trustly, Paysafecard, bank transfer, and all cryptocurrency deposits and withdrawals processed via CoinsPaid and CatPay;
• All bonus claims, free spin awards, cashback payments, and Lucky Kitchen VIP Club rewards;
• All sportsbook wagers and live betting activity;
• All third parties acting on behalf of a registered player.

3. Definitions

4. The Three Stages of Money Laundering

Mamabet Casino trains its compliance team to identify all three classical stages of money laundering:

• Placement: The introduction of illicit funds into the financial system — for example, making deposits using proceeds of crime.
• Layering: The movement of funds through multiple transactions to obscure their origin — for example, rapid sequences of deposits and withdrawals, currency conversions between fiat and cryptocurrency, or splitting large amounts across multiple payment methods.
• Integration: The re-entry of laundered funds into the legitimate economy as apparently clean money — for example, requesting a withdrawal to a bank account after cycling funds through the cashier.

Online gambling platforms, including those accepting multiple cryptocurrencies as Mamabet Casino does, can be attractive to those seeking to layer funds. This Policy is designed to detect and disrupt all three stages.

5. Know Your Customer (KYC) Procedures

5.1 Account Registration

Every player must provide accurate and complete personal information when creating an account at mama-bet.nl. This includes full legal name, date of birth, residential address, email address, and any other details requested during the registration process. Players must be at least 18 years of age. Providing false, misleading, or incomplete information is a breach of these Terms and may result in immediate account suspension, forfeiture of funds, and a report to relevant authorities.

5.2 Standard Customer Due Diligence (CDD)

Mamabet Casino reserves the right to request identity verification at any point — including at registration, before processing a withdrawal, upon reaching defined deposit or transaction thresholds, or when suspicious activity is identified. Standard CDD documentation includes, but is not limited to:

• Proof of Identity: A valid government-issued photo document such as a national identity card, passport, or driving licence. The document must be current, clearly legible, and show the player's full name and date of birth.
• Proof of Address: A recent utility bill, bank statement, or official correspondence (dated within the last three months) showing the player's name and residential address as registered on their account.
• Proof of Payment Method: Confirmation that the deposit method is held in the player's own name. For cryptocurrency wallets, the player may be required to confirm wallet ownership. For card payments, a photo or screenshot of the relevant card (with the middle eight digits obscured) may be requested. All payment instruments must be registered in the player's own name — third-party deposits will result in forfeited winnings and account suspension.
• Selfie Verification: A photograph of the player holding their identity document, taken in a manner that allows clear comparison of the face and document details.

5.3 Age Verification

Mamabet Casino operates a strict minimum age policy. No player under the age of 18 may register, deposit, wager, or withdraw. Age verification may be requested at any stage. Where age cannot be confirmed promptly, the account will be suspended and no withdrawals permitted until verification is complete. Any funds deposited by a player found to be underage will be returned, and winnings will be void.

5.4 Enhanced Due Diligence (EDD)

Enhanced Due Diligence will be applied where a player:

• Is identified as, or appears to be, a Politically Exposed Person (PEP) or a close associate or family member of a PEP;
• Deposits or withdraws amounts that are unusually large relative to their stated profile;
• Exhibits transaction patterns consistent with layering or structuring;
• Requests withdrawals to accounts or wallets not previously used for deposits;
• Is resident in or transacts from a jurisdiction considered high-risk under FATF guidance;
• Activates high cashback levels or VIP-tier withdrawal increases that significantly raise their financial exposure on the platform;
• Attempts to withdraw large sums shortly after depositing with minimal or no gaming activity.

EDD may require the player to provide documentation evidencing source of funds, source of wealth, employment status, income, or business ownership. Examples of acceptable source-of-funds documentation include recent payslips, tax returns, bank statements, business accounts, inheritance documentation, or contracts of sale. Mamabet Casino may also conduct independent open-source checks, including adverse media screening and sanctions list searches.

5.5 Source of Funds and Source of Wealth

For players depositing significant amounts — or where transaction behaviour raises questions about the legitimacy of funds — Mamabet Casino will request evidence of both source of funds and source of wealth. This requirement applies equally to fiat and cryptocurrency transactions. Players making cryptocurrency deposits should be aware that on-chain transaction analysis may be used to assess the history and risk profile of incoming funds. Funds originating from wallets associated with darknet markets, ransomware, fraud, or other illicit activity will be refused and the account suspended.

5.6 Ongoing Monitoring

KYC is not a one-time exercise. Player accounts are subject to continuous monitoring throughout their lifetime. Mamabet Casino will re-verify a player's identity, address, or financial profile if circumstances change — for example, if a player reaches a new VIP tier with elevated withdrawal limits, if the payment methods on file change, or if an account shows a significant change in deposit or withdrawal patterns. Account documents may be requested to be refreshed periodically to ensure they remain current and valid.

5.7 Consequences of Non-Compliance with KYC Requests

Players who fail to respond to KYC requests within the timeframe specified by the compliance team, or who provide documentation that cannot be verified, will have their accounts suspended. Pending withdrawals will be held until verification is complete. If verification remains outstanding for a prolonged period, or if it becomes apparent that the player has provided fraudulent documents, the account will be permanently closed. In such cases, Mamabet Casino reserves the right to withhold funds pending investigation and, where required, to report the matter to relevant authorities.

6. Payment Method Integrity

Mamabet Casino operates a strict same-method withdrawal policy. The payment method used to deposit determines the method through which withdrawals are processed — fiat deposits are returned via a fiat method; cryptocurrency deposits are returned in cryptocurrency. This policy reduces the risk of third-party fraud and assists in maintaining a clear audit trail.

Key payment rules with AML relevance include:

• All payment instruments — cards, e-wallets, bank accounts, cryptocurrency wallets — must be registered in the player's own name. Third-party payments are strictly prohibited.
• All deposits must be wagered at least once (×1 playthrough) before a withdrawal may be requested. This requirement is in place in part to deter the platform from being used as a pass-through mechanism for funds.
• Paysafecard deposits may be subject to additional verification given the anonymous nature of prepaid vouchers.
• Cryptocurrency deposits are processed via CoinsPaid and CatPay. Players depositing cryptocurrency may be required to verify wallet ownership and may be subject to blockchain analytics screening.
• Standard accounts are subject to the following withdrawal limits: €5,000 per day, €10,000 per week, and €20,000 per month. VIP levels within the Lucky Kitchen VIP Club raise these limits. Wins above €50,000 may be paid in monthly instalments; the maximum single win is €500,000.
• Withdrawals may be subject to an extended anti-fraud review of up to seven business days where compliance checks are required. Normal processing time is up to two business days.

7. Risk-Based Approach

Mamabet Casino applies a risk-based approach to AML and KYC. Not all players present the same level of risk, and the intensity of due diligence is calibrated accordingly. Players are assigned an internal risk rating — low, medium, or high — based on factors including:

• Country of residence and nationality;
• Deposit volumes and frequency;
• Withdrawal patterns relative to deposit history;
• Payment methods used (noting that cryptocurrency and prepaid instruments may carry elevated risk profiles);
• VIP tier and associated financial exposure;
• Results of PEP and sanctions screening;
• Adverse media findings;
• Any prior suspicious activity flags on the account.

Higher-risk players are subject to more frequent review, lower thresholds for EDD triggers, and more intensive transaction monitoring. Risk ratings are reviewed regularly and updated in response to new information.

8. Suspicious Activity Monitoring and Reporting

8.1 Indicators of Suspicious Activity

The compliance team at Mamabet Casino monitors accounts for a range of behavioural indicators that may suggest money laundering or other financial crime. These include, but are not limited to:

• Depositing large sums and withdrawing most of the balance with minimal gaming activity;
• Structuring deposits in amounts just below internal verification thresholds;
• Frequent changes of payment method, particularly involving cryptocurrency wallets;
• Requests to withdraw to a method or account not used for deposits;
• Repeated failed withdrawal attempts followed by redeposit;
• Unusual interest in bonus mechanics relative to actual play volume, in a manner inconsistent with genuine gaming behaviour;
• Deposits immediately after a large withdrawal, with no meaningful gaming in between;
• Multiple accounts linked to the same IP address, device, household, or payment method — noting that bonus terms also prohibit this;
• Apparent collusion at live dealer tables or in other multi-player formats;
• Providing documents that appear altered, inconsistent, or otherwise suspicious.

8.2 Internal Reporting

Any member of the Mamabet Casino operations or support team who becomes aware of suspicious activity is required to raise an internal Suspicious Activity Report (SAR) with the MLRO. The MLRO is responsible for reviewing all internal SARs, conducting further investigation as required, and determining whether an external report to competent authorities is necessary.

8.3 Tipping-Off Prohibition

In accordance with standard AML best practice, neither Mamabet Casino staff nor any associated party may inform a player, or any third party, that a SAR has been raised or that an investigation is under way. Doing so — commonly referred to as "tipping off" — is strictly prohibited and may itself constitute a criminal offence under applicable law.

9. Sanctions Screening

Mamabet Casino screens all new registrants and existing players against applicable international sanctions lists, including those published by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and Her Majesty's Treasury (UK). Players who appear on, or are closely associated with individuals on, sanctions lists will have their accounts suspended without notice. Any funds held will be dealt with in accordance with applicable sanctions obligations. Screening is conducted at registration and on an ongoing basis throughout the account lifetime.

10. Politically Exposed Persons (PEPs)

Mamabet Casino does not automatically refuse to accept PEPs; however, any player identified as a PEP — or as a close family member or known associate of a PEP — is automatically subject to EDD and senior management approval before their account may be fully activated. PEP status is assessed at registration and monitored on an ongoing basis. Players who become PEPs after registration must notify Mamabet Casino promptly. The source of funds and source of wealth of PEPs will be subject to heightened scrutiny, and transaction limits and monitoring thresholds may be adjusted accordingly.

11. Cryptocurrency-Specific Controls

Mamabet Casino accepts 21 cryptocurrencies, including Bitcoin (BTC), Ethereum (ETH), Solana (SOL), Dogecoin (DOGE), SHIB, TON, and others, processed via CoinsPaid and CatPay. Cryptocurrency transactions present specific AML challenges due to their pseudonymous nature and the speed with which funds can be moved across borders.

In addition to standard KYC requirements, the following controls apply to cryptocurrency accounts:

• Blockchain analytics tools may be used to screen incoming cryptocurrency transactions for links to high-risk wallets, including those associated with darknet markets, ransomware, fraud, sanctions evasion, or mixing services.
• Funds received from flagged wallets may be frozen pending investigation.
• Players may be required to confirm wallet ownership and to demonstrate that the wallet from which they are depositing belongs to them.
• Cryptocurrency withdrawals will only be processed to wallets previously used for deposits, in line with the same-method withdrawal policy.
• Conversions between cryptocurrency and fiat currency within the cashier are monitored as potential layering activity.

12. Responsible Gambling Interaction with AML

Mamabet Casino operates a responsible gambling programme as part of its overall player protection framework. Whilst responsible gambling and AML are distinct disciplines, they interact in important ways. Players who exhibit signs of problem gambling — such as chasing losses with escalating deposits, erratic withdrawal requests, or distressed communications — are also monitored from an AML perspective, since vulnerability can be exploited by third parties seeking to use player accounts as conduits for laundered funds.

Players may set deposit limits, session limits, and self-exclusion periods via their account settings. Where a player is subject to an active self-exclusion or cooling-off period, all financial transactions will be suspended for the duration. Mamabet Casino also participates in third-party responsible gambling schemes; players seeking support may contact organisations such as GamCare, Gamblers Anonymous, or BeGambleAware.

13. Record Keeping

Mamabet Casino maintains records of all KYC documentation, transaction histories, risk assessments, internal SARs, and compliance decisions for a minimum of five years from the date of the relevant event or, in the case of a closed account, from the date of closure. Records are stored securely and are accessible to the MLRO and senior compliance staff. Retention periods may be extended where an investigation, legal proceeding, or regulatory enquiry is ongoing.

14. Staff Training

All employees and contractors at Mamabet Casino who have a role in customer account management, payments, customer support, or fraud detection receive AML and KYC training appropriate to their responsibilities. Training covers recognition of suspicious activity indicators, the internal SAR process, the tipping-off prohibition, sanctions screening obligations, and the specific risks associated with cryptocurrency transactions. Training is delivered at induction and refreshed at regular intervals, with records of completion maintained by the compliance function.

15. Internal Controls and Governance

VENUS DEL ALMA LIMITADA has designated an MLRO who bears overall responsibility for the implementation and oversight of this Policy. The MLRO reports to senior management and is empowered to suspend accounts, request documentation, delay withdrawals, and file reports without prior commercial approval. The compliance function operates independently of the commercial and marketing teams to avoid conflicts of interest.

This Policy is reviewed at least annually, or more frequently where there are material changes to the regulatory environment, the platform's payment methods, the player base, or the risk profile of the business. All material amendments are approved at senior management level before coming into effect.

16. Player Obligations

By registering an account at mama-bet.nl, every player acknowledges and agrees to the following obligations:

• To provide true, accurate, current, and complete information at registration and throughout the lifetime of their account;
• To promptly notify Mamabet Casino of any change in personal details, including name, address, or PEP status;
• To respond to KYC and EDD requests within the timeframes specified;
• To use only payment methods registered in their own name;
• Not to use the platform to launder funds, structure transactions, or otherwise engage in financial crime;
• Not to open multiple accounts or allow another person to use their account;
• To ensure that any funds deposited are legitimately their own and derived from lawful sources.

Breach of any of these obligations may result in account suspension, permanent closure, forfeiture of funds, and a report to the relevant authorities.

17. Consequences of AML/KYC Breaches

Where Mamabet Casino determines — on reasonable grounds — that a player has engaged in, attempted to engage in, or facilitated money laundering or any other form of financial crime, the following actions may be taken:

• Immediate suspension or permanent closure of the account;
• Withholding of all funds pending investigation;
• Forfeiture of any bonus funds, free spins, cashback, or VIP rewards received;
• Voiding of all winnings generated during the relevant period;
• Filing of a report with applicable law enforcement or regulatory authorities;
• Co-operation with any subsequent investigation or legal proceedings, including disclosure of account information and transaction records as required by law.

18. Contact and Escalation

Players with queries relating to this Policy, or who wish to understand the status of a KYC request, may contact the Mamabet Casino compliance team via the 24/7 live chat on mama-bet.nl or by submitting a request through the contact form available on the site. VIP players may also raise queries through the dedicated VIP Telegram channel or via their personal VIP manager where one has been assigned. All compliance correspondence is handled confidentially and in accordance with the record-keeping obligations set out in Section 13 of this Policy.

Mamabet Casino is committed to being transparent with its players about its AML and KYC requirements. Where a request for documentation is made, the team will explain the reason for the request to the extent permitted by law — noting that the tipping-off prohibition may limit what can be disclosed where an active investigation is under way.

19. Policy Updates

Mamabet Casino reserves the right to amend this AML / KYC Policy at any time. Material updates will be communicated to registered players via email or on-site notification. Continued use of mama-bet.nl following any such amendment constitutes acceptance of the revised Policy. The current version of this Policy is always available on the website and supersedes all previous versions.