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AML & KYC Policy

Customer (KYC) Policy

Effective Date: November 05, 2025
Operator: Carlitta N.V., License No. OGL/2024/1516/0841 (Curaçao)

1. Introduction

At pinco-crypto.com, operated by Carlitta N.V., we uphold the highest standards of integrity, security, and regulatory compliance. Our Know Your Customer (KYC) and Anti-Money Laundering (AML) frameworks are built to deter illicit activity and maintain a safe, transparent environment for all users.

Our procedures align with:

  • Curaçao Gaming Authority AML/CFT Regulations
  • National Ordinance on Reporting Unusual Transactions (NORUT)
  • National Ordinance on Identification (NOIS)
  • Kingdom Sanctions Act & Sanctions National Ordinance
  • FATF’s 40 Recommendations

2. Policy Objectives

This KYC/AML Policy aims to:

  • Prevent money laundering, terrorist financing, and proliferation financing
  • Ensure that all funds on the platform are from lawful sources
  • Apply a tiered, risk-based approach to verification
  • Meet Curaçao and international regulatory obligations
  • Protect our customers, systems, and brand reputation

3. Definitions

  • KYC: Verification of a player’s identity through documentation and screening
  • CDD: Customer Due Diligence to assess the legitimacy of a customer
  • ML/TF/PF: Money Laundering / Terrorist Financing / Proliferation Financing
  • PEP: Politically Exposed Person (including close associates)
  • FIU: Financial Intelligence Unit of Curaçao

4. Applicability

This policy covers:

  • All registered customers of pinco-crypto.com
  • Internal teams (KYC, Support, Compliance)
  • Third-party vendors engaged for KYC or payment services

5. Eligibility & Jurisdiction

5.1 Minimum Age

Only individuals 18+ may register. Age verification is mandatory. Accounts identified as underage will be closed and funds may be forfeited.

5.2 Restricted Jurisdictions

Access is blocked from:

  • Sanctioned countries (UN, EU, OFAC)
  • High-risk jurisdictions (FATF-listed)
  • Regions on Carlitta N.V.’s internal restricted list

Geo-IP blocking, VPN detection, and transactional monitoring are enforced.

6. Registration Requirements

To create an account, users must provide:

  • Full legal name
  • Date and place of birth
  • Residential address
  • Nationality
  • Valid email and phone number
  • Identity number (if applicable)
  • Preferred currency and a secure password

Email verification is required. Additional documentation may be requested.

7. Know Your Customer (KYC)

KYC must be completed prior to full account access or any withdrawals.

Accepted Identity Documents

  • Passport
  • National ID card
  • Driver’s license
  • Residence permit

Proof of Address (issued within 6 months)

  • Utility bill
  • Bank statement
  • Lease agreement

Document Standards

  • Full-color, clear, and unaltered
  • All edges/corners visible
  • Certified translations/copies if necessary

Additional Evidence (where applicable)

  • Ownership of payment method
  • Source of funds / source of wealth
  • Certified KYC packages

8. Payment Verification

Key rules:

  • Only personal accounts may be used (no third-party payments)
  • Withdrawals should, where possible, use the same method as deposits
  • Cash transactions are not accepted; only traceable methods are allowed
  • Documentation may be required to confirm ownership

Non-compliance may cause delays or restrictions.

9. Customer Due Diligence (CDD)

CDD levels are risk-based. Enhanced Due Diligence (EDD) applies to higher-risk profiles, including high-value transactions or complex structures.

10. Politically Exposed Persons (PEPs)

PEPs are subject to:

  • EDD screening
  • Senior management approval
  • Ongoing relationship reviews

PEP status is monitored continuously.

11. Re-Verification

Users may be asked to update or re-submit documents at any time. Certain features may remain limited until verification is complete.

12. Ongoing Monitoring

We monitor account behavior through:

  • Periodic document checks
  • Behavioral and risk analysis
  • Alerts for unusual activity

This supports sustained compliance and security.

13. Transaction Oversight

Automated and manual reviews flag:

  • Atypical transaction patterns
  • Structuring/smurfing behavior
  • Activity outside expected profiles

Suspicious cases may be reported to the authorities.

14. Sanctions Screening

All customers are screened against international and local sanctions lists, including:

  • UN Security Council
  • EU and OFAC
  • Curaçao regulatory lists

Accounts linked to sanctioned persons are blocked or terminated.

15. Recordkeeping

We retain relevant records for 5–10 years, including:

  • Identity documents
  • Payment and transaction history
  • Risk assessments
  • Regulatory correspondence

Records are stored securely in compliance with data protection laws.

16. Policy Maintenance

This policy is reviewed regularly in response to:

  • Legal/regulatory changes
  • Emerging risks or new technology
  • Internal audits and findings

17. Sanctions for Non-Compliance

Failure to satisfy KYC/AML requirements may result in:

  • Account suspension or closure
  • Withdrawal blocks
  • Reporting to competent authorities
  • Legal action

18. Withdrawal Conditions

Payouts are processed only after:

  • Full verification is completed
  • Use of the same payment method as deposit (where applicable)
  • Completion of wagering/promotional conditions
  • Adherence to fair-use and traceability standards

Withdrawals to third parties are strictly prohibited.

19. Player Obligations

Players must:

  • Provide accurate, up-to-date information
  • Use only personal identity and financial accounts
  • Cooperate with verification requests
  • Maintain a single active account
  • Refrain from abusing promotions or payment systems

Violations may lead to corrective action or account closure.

20. Transparency & Communication

We notify users when verification is required and provide full guidance via our support team.

21. Data Security

All personal data is:

  • Encrypted and securely stored
  • Accessible only to authorized personnel
  • Managed under strict incident-response protocols

22. Regulatory Cooperation

We cooperate fully with:

  • Curaçao’s FIU
  • Gaming and legal authorities

Where legally required, we may disclose:

  • Identity/KYC documentation
  • Transaction records
  • Compliance reports and findings

23. Compliance Officer

A dedicated Compliance Officer oversees:

  • KYC/AML implementation
  • Internal reporting and audits
  • FIU liaison
  • Team training and risk assessment

This function operates independently and reports to senior management.

24. Contact Us

For KYC or compliance inquiries, contact:
📧 [email protected]

All communications are confidential and handled in line with data protection laws.