1. Why these checks exist
1.1 The operator is subject to anti-money-laundering, counter-terrorist financing and sanctions law under its licence, and to the conditions the regulator attaches to that licence. These checks are how we meet those obligations. They are not optional for us, and they are not a judgement about you.
1.2 We may not be able to tell you why a particular check was applied, why a transaction was held, or whether a report has been made. Where the law prohibits tipping-off, we will not.
2. Verification tiers
2.1 Every account has a verification tier from 0 to 3. Your tier determines what you may do:
| Tier | What has been verified |
|---|---|
| 0 | Age and jurisdiction declared at registration |
| 1 | A confirmed email address and one approved identity document |
| 2 | Tier 1, and proof of your residential address |
| 3 | Tier 2, and enhanced due diligence including the source of your funds |
What a tier permits depends on your operator. Some rooms require an approved identity before a cash seat is given at all; in others the tier is what we read when a deposit, a withdrawal or a pattern of play is reviewed under section 6 or 7, and we may ask you to raise it before a payment is made. No tier carries a published deposit or withdrawal ceiling today. Ceilings are a licence condition; when your operator's licence sets them they are written here as figures, and you will be told before one applies to your account.
2.2 Your current tier and the status of each document you have submitted are shown in Account → Identity. Raising your tier is at our discretion once the documents for it are approved.
2.3 We may require verification at any tier at any time, including on a change of your details, an unusual pattern of play or of deposits, a first withdrawal, a withdrawal above a threshold, a match against a screening list, or a request from the regulator.
3. What we may ask for
3.1 We accept the following, uploaded from Account → Identity:
- a passport, national identity card or driving licence;
- proof of your residential address, recent enough that a reviewer can rely on it; the reviewer's note tells you if the one you sent is too old;
- a photograph of you holding the document ("selfie"), where we need to confirm that the document is yours.
Enhanced due diligence at tier 3 needs evidence of the source of your funds or of your wealth. Account → Identity does not accept that kind of document, so we tell you what we need and how to send it when we ask for it.
3.2 Each document must be a JPEG, PNG, WebP or PDF of at most 8 megabytes, legible, complete and unaltered. You may have at most five documents awaiting review at once. Uploading the same document again does not create a second review.
3.3 A document is reviewed by a person. You are told the decision and, where it is not approved, the reviewer's note explaining what is needed. You are not told the reviewer's identity, and the document itself is never shown back through the service.
3.4 We do not ask for your password, your authenticator secret, your recovery codes or the private key of any wallet, and we will never ask you to send funds to "verify" an address.
4. Deposits
4.1 Deposits are accepted only from jurisdictions where real-money play is permitted and only in the assets and on the chains the cashier lists. A deposit is credited after the confirmations the cashier shows, at the rate shown, and that rate is recorded.
4.2 Every deposit address is screened before credit against sanctions lists and, where configured, for exposure to known mixing services. A deposit that matches is refused or held. Held funds are not credited to your balance and are dealt with under section 8.
4.3 A large deposit, a run of deposits that adds up to one, or a pattern that appears designed to stay under a threshold, may require evidence of the source of the funds before they are credited or before they can be withdrawn. We do not publish the figure that triggers this, because publishing it would tell a launderer where to stop.
4.4 We do not accept deposits from third parties. A deposit from an address that we determine is not yours, or from an exchange account in another person's name, may be returned to its source less network fees.
5. Play
5.1 The ledger records every movement of value with its reason. Patterns of play consistent with moving value between accounts (chip dumping, soft play, repeated heads-up losses to the same opponent, buy-in and immediate cash-out without play) are flagged for review and treated under the Security & Fair Play policy as well as this one.
5.2 We may restrict play, hold a balance or require verification while a pattern is reviewed. Play-money tables are not subject to this section except where they are used to coordinate real-money abuse.
6. Withdrawals
6.1 A withdrawal is paid only to an address you own and have verified, in an asset and on a chain the cashier supports, and only after every deposit that funded the balance has cleared the checks in section 4.
6.2 Every withdrawal requires your authenticator code, every time.
6.3 A withdrawal to an address you have not withdrawn to before is held for 24 hours before it is sent. This hold is fixed and cannot be shortened by you or by support.
6.4 Every withdrawal is scored on factors including the amount against your history, the age of the destination address, whether it is your first withdrawal, the ratio of deposits to play to withdrawals, your recent withdrawal velocity and the age of your account. A high score routes the withdrawal to review by a person.
6.5 A withdrawal above the amount kept in immediate custody is signed by staff using hardware keys and may take longer. A withdrawal that staff pay by hand, rather than one the service pays automatically, is proposed by one member of staff and approved by another, and the database refuses the record when the same person does both. The platform's own owner is the single exception to that rule, and their decision is recorded in their name.
6.6 The destination address is screened as in 4.2 before the transaction is broadcast. A match is refused and dealt with under section 8.
6.7 We may refuse to pay a withdrawal to an address or asset that would defeat the purpose of these checks (for example, a withdrawal of funds deposited in one asset to an unrelated one where that is not necessary) to the extent the law and our risk rules require.
7. Monitoring and reporting
7.1 We monitor deposits, play and withdrawals for patterns consistent with money laundering, terrorist financing, sanctions evasion, fraud and structuring. Monitoring uses the ledger, the game record, device and session data and screening results, and is reviewed by trained staff.
7.2 Where the law requires, we report suspicious activity to the financial intelligence unit of the country your operator is licensed in. We may be prohibited from telling you that a report has been made, and from processing a transaction while a report is considered. The unit is named in this section once a licence names it.
7.3 We keep the records of every check, decision and report for as long as anti-money-laundering and gambling law requires after the account closes. The Privacy policy says what is kept and why.
7.4 The operator has not yet appointed a named compliance officer, because it does not yet hold a gambling licence. Appointing one is a condition of every licence we would apply for, and the officer's title is published here when the appointment is made. Until then the checks in this policy are performed and this policy is owned by the operator's own staff.
8. Refusal, holds and closure
8.1 We refuse a deposit, hold a balance, refuse a withdrawal or close an account where:
- verification is not completed when required;
- a document is found to be false or altered;
- a deposit or destination address is sanctioned or exposed;
- the source of funds cannot be established;
- a pattern in section 5 or 7 is confirmed;
- the account belongs to a minor or to a person in a prohibited jurisdiction;
- the law or the regulator requires it.
8.2 Funds that are not subject to a legal hold, a sanctions match or a confirmed prohibited practice are returned to you through the withdrawal process to a verified address, after the checks above. Funds that are subject to one of those are held until the matter is resolved or the law directs what is to be done with them. Where the law says nothing about them, they are held until the checks conclude, and are then released to you, or to the source they came from, as far as the law permits. Where a deposit is reversed, recalled or frozen, we may deduct the reasonable cost of dealing with it where the law allows.
8.3 A hold is shown in the cashier as a hold. Support can tell you what is needed to lift it where the law allows us to say.
9. Politically exposed persons and high-risk relationships
9.1 If you are, or become, a politically exposed person, a family member or close associate of one, or a person otherwise designated as higher risk under our risk assessment, you must tell us, and enhanced due diligence at tier 3 applies to the account.
10. Your obligations
10.1 You confirm that the funds you deposit are yours, lawfully obtained, and not the proceeds of crime; that you are not subject to sanctions; that you are not acting for another person; and that you will tell us if any of that changes.
10.2 You agree to provide the documents and information in section 3 when asked, within the time we give, and accept that the account may be restricted until you do.
11. Asking us about a check
If a deposit, a withdrawal or your account is held under this policy, use the form on the Help page. Choose Identity or account verification for a document question and Withdrawal for a held payment. We tell you what we need wherever the law allows us to say.