Aml

Anti-Money Laundering and Counter-Terrorism Financing Compliance

Spinado operates in strict accordance with applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations. We perform customer due diligence (CDD) on all users as part of onboarding and on an ongoing basis proportional to risk. Information supplied for due diligence is processed under Spinado's Privacy Policy. We may conduct public searches and verify information provided to verify identity and financial activity. During the due diligence phase, a user may continue to use the account, but withdrawals and other transfers of real money may be restricted until verification is completed. Spinado reserves the right to request additional information or documentation as necessary, and any communication requesting such information shall not be considered a final determination.

Customer Due Diligence and Know Your Customer

We apply a risk-based approach to verify customers and maintain accurate customer records. Verification status and supporting documents are retained in accordance with regulatory requirements. Data collected for AML purposes may be cross-referenced with public and private sources as allowed by law to establish identity, residency, and the source of funds.

Identity Verification Procedures

• Required documentation may include: government-issued photo identity (passport, national ID, or similar), recent proof of address (utility bill, bank statement) not older than three months, and documentation demonstrating source of funds where required.
• For deposits or withdrawals reaching the equivalent of EUR 500 in aggregate, or where the company reasonably suspects fraudulent activity, additional verification (such as verification of payment methods, or a selfie with an identity document) may be requested.
• Acceptable documentation must be valid and legible; scanned copies are not accepted; we may require original documents or certified copies where permitted by law.
• Outgoing funds may be restricted pending completion of verification; inability to verify may result in account suspension or closure.

Ongoing Monitoring and Transaction Analysis

Spinado conducts ongoing monitoring of account activity and transactional patterns to detect unusual or suspicious behavior. This includes cross-referencing transaction data with other records, maintaining an internal list of high-risk and politically exposed persons (PEP) statuses, and employing fraud prevention controls. Suspected money laundering or related crimes will be reported to the relevant authorities in accordance with applicable laws.

Politically Exposed Persons, Sanctions, and Adverse Media

Spinado does not offer services to persons identified as Politically Exposed Persons (PEPs) where prohibited by law. If a user is determined to be a PEP at any stage, their account will be closed and any remaining real-money balance returned in line with regulatory obligations. If the user disagrees with a PEP determination, they may raise the matter with Spinado through the official compliance channel.

Verification Triggers and Withdrawal Controls

In addition to onboarding, Spinado may require ongoing verification or additional documentation at any time. While verification is being completed, the user’s ability to withdraw funds may be restricted or temporarily suspended. Spinado will provide written notice of required documentation and expected timelines for completion.

Prohibited Jurisdictions

Registration and participation in Spinado services are prohibited where prohibited by applicable law or regulation. Spinado may determine that a user is located in a jurisdiction where access to services is prohibited and may suspend or terminate the account accordingly. The list of restricted jurisdictions may be updated in line with regulatory developments.

Data Privacy, Data Management, and Retention

Spinado, as data controller, collects and processes personal information for AML purposes in accordance with applicable data protection laws. Personal data may include name, contact details, date of birth, identification numbers, and transaction history. Data may be shared with competent authorities as required by law. Personal data will be retained for up to eight (8) years following the end of the relationship or last activity, unless a longer retention period is required by law. Users have rights of access, correction, deletion, and objection where allowed by law, and may withdraw consent where processing is based on consent. Spinado’s Privacy Policy provides further details on cookies, data security, and data subject rights.

Enforcement, Cooperation with Authorities, and Disclosures

Spinado may suspend or restrict a user’s account, block or refuse withdrawals, or terminate the relationship if AML/CTF obligations require. In cases of reasonable suspicion or confirmed violations, Spinado may report or cooperate with regulatory or law enforcement authorities consistent with applicable law. Spinado will disclose information to the extent required by law or to protect Spinado’s rights and the integrity of the platform.

Contact Information for AML Matters

For compliance-related inquiries, requests for verification, or reporting concerns, users should contact Spinado’s AML Compliance team at [email protected] or through official support channels. All requests will be treated in accordance with applicable data protection and privacy laws and Spinado’s Privacy Policy.