Anti-Money Laundering Guidelines
What Is the AML Policy
Rooli Casino maintains an Anti-Money Laundering policy for the purpose of preventing the platform from being used to conceal or legitimize the proceeds of criminal activity, and to ensure that no transaction conducted through the casino contributes, directly or indirectly, to the financing of terrorism. The policy establishes the procedural and operational standards that the casino and its players are required to observe in order to satisfy applicable regulatory obligations and to preserve the integrity of the platform.
Compliance with these standards is a condition of continued access to the platform. All accounts, transactions, and withdrawal requests are subject to the controls described in this policy, regardless of the player's account history or status.
Structure of the AML Guidelines
The casino's AML framework is organized into the following five sections, each addressing a distinct area of compliance responsibility:
- Customer Identification and Verification
- Due Diligence and Risk Assessment
- Transaction Monitoring and Reporting
- Record-Keeping and Data Retention
- Staff Training and Internal Controls
Possible Casino Enforcement Measures
Where the casino identifies activity that is inconsistent with these guidelines, or where a player fails to satisfy applicable compliance requirements, the casino may take one or more of the following measures:
- Suspension of the player account pending further investigation
- Permanent closure of the player account
- Withholding or confiscation of funds held within the account
- Filing of a Suspicious Activity Report (SAR) with the relevant financial intelligence unit
- Referral of the matter to law-enforcement or regulatory authorities
- Refusal to process a withdrawal request until outstanding compliance checks are satisfied
Due-Diligence Levels
The casino applies a risk-based due-diligence framework that scales the intensity of identity and compliance checks to the level of risk presented by each account or transaction. Three distinct levels are in operation, as set out in the table below.
| Level | Name | When It Applies |
|---|---|---|
| SDD | Simplified Due Diligence | Applied where the risk of money laundering or terrorist financing is assessed as demonstrably low — for example, where the account activity is limited in scope and the player's identity is not in question. A reduced set of verification steps is required at this level. |
| SDD | Standard Due Diligence | The baseline level applied to all accounts at registration and at the point of first withdrawal. Requires confirmation of identity, date of birth, and residential address by means of acceptable documentation. This level applies in the absence of specific elevated-risk indicators. |
| EDD | Enhanced Due Diligence | Triggered where elevated risk factors are identified, including but not limited to: high-volume or unusual transaction patterns, inconsistencies between account information and verification documents, designation of the account holder as a politically exposed person (PEP), or other indicators of heightened money-laundering or financing-of-terrorism risk. Additional documentation and source-of-funds evidence may be requested at this level. |
The casino reserves the right to move any account to a higher due-diligence level at any time where new information or transaction activity so warrants. Players are required to cooperate fully with any additional verification requests that arise from such a reassessment.
Transaction Monitoring & Compliance
Withdrawal Playthrough Requirement
As an AML control measure, players are required to wager deposited funds at least once in their entirety before a withdrawal request may be submitted. This requirement ensures that the platform is used for its stated purpose of genuine gaming activity rather than as a mechanism for cycling funds through the cashier. The playthrough requirement applies to all accounts and all deposit methods and operates independently of any bonus wagering conditions that may also be in effect.
Pre-Withdrawal Review Process
Every withdrawal request is subject to a combined review prior to processing. This review draws on both automated algorithmic analysis and manual assessment by the casino's compliance team. The dual-layer approach is designed to identify unusual patterns, discrepancies between deposit and withdrawal behaviour, and other indicators that may warrant further investigation before funds are released. Players should allow for this review process when planning withdrawals and ensure that their KYC documentation is current and approved before submitting a request.
Player-to-Player Transfers
Direct transfers of funds between player accounts are prohibited under all circumstances. This restriction is absolute and is not subject to any exception. Any attempt to conduct or solicit a player-to-player transfer will be treated as a potential compliance breach and may result in account suspension and investigation under the casino's AML procedures.