This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Royal Spinia, operated by Tekuno Technologies S.R.L. and licensed by the Tobique Gaming Commission, in detecting, preventing and reporting financial crime conducted through or in connection with royalspiniacasinoonline.nl. All customers, employees and third-party partners are bound by the standards described herein.
Royal Spinia is committed to operating a safe, transparent and legally compliant gaming environment. Money laundering — the process by which criminally obtained funds are made to appear legitimate — and the financing of terrorism represent serious threats to the integrity of the financial system and to the customers we serve. This Policy establishes the framework through which royalspiniacasinoonline.nl identifies, assesses and mitigates those risks in accordance with applicable laws, regulations and the standards imposed by the Tobique Gaming Commission.
The objectives of this Policy are to:
Royal Spinia holds a valid gaming licence issued by the Tobique Gaming Commission. Tekuno Technologies S.R.L. conducts its operations in compliance with the anti-money laundering and counter-terrorist financing requirements mandated by that licensing authority, as well as with applicable international standards including the recommendations of the Financial Action Task Force (FATF). GDPR compliance is also embedded within our data-handling practices from the outset.
Where national or international legislation applicable to a customer's jurisdiction imposes stricter obligations than those described in this Policy, Royal Spinia will apply the stricter standard.
This Policy applies to:
KYC procedures allow Royal Spinia to confirm that customers are who they claim to be, that they are of legal gambling age, that their source of funds is legitimate, and that they are not subject to sanctions or politically exposed person (PEP) restrictions. Verification is not optional — it is a regulatory and ethical requirement.
KYC verification is triggered automatically before a customer's first withdrawal is processed. Verification may also be required at any point where Royal Spinia's risk-based assessment indicates it is necessary, including but not limited to:
All customers are required to submit the following documents to complete standard identity verification:
| Document Category | Accepted Documents | Requirements |
|---|---|---|
| Government-Issued Photo ID | Passport, national identity card, or driving licence | Must be valid and unexpired; all four corners visible; full name, date of birth and document number clearly legible |
| Proof of Address | Utility bill, bank statement, or official government correspondence | Must be dated within the last six months; must show full name and residential address matching the registered account details |
| Payment Method Verification | Screenshot or photo of the payment account, card (with middle eight digits obscured), or e-wallet account confirmation | Must confirm that the payment method belongs to the registered account holder; third-party payment methods are not permitted |
Documents must be submitted in colour, at a readable resolution, and must not be edited, cropped or digitally altered in any way. Royal Spinia reserves the right to request additional documentation where standard submissions are deemed insufficient.
The Royal Spinia compliance team reviews submitted documents within 48 hours of receipt. Customers will be notified via the email address associated with their account as to whether verification has been approved or whether further documentation is required. Withdrawals remain on hold until verification is successfully completed.
Certain customers or circumstances require a higher level of scrutiny beyond standard KYC checks. Enhanced Due Diligence is applied where:
Under EDD, customers may be required to provide documentation evidencing their source of funds (e.g. payslips, tax returns, proof of business income, inheritance documentation), source of wealth, or the purpose of high-value transactions. Royal Spinia may impose restrictions on deposits and withdrawals pending completion of EDD.
Royal Spinia does not permit gambling by individuals under the age of 18. Age verification is conducted as part of the standard KYC process. Where there is any doubt as to a customer's age, the account will be suspended pending satisfactory verification. Any funds deposited by an underage customer will be returned and the account permanently closed.
Royal Spinia operates a strict policy against third-party deposits and withdrawals. All payment methods used to fund an account must be registered in the name of the account holder. Where a third-party payment is detected, the deposit may be reversed and the account suspended pending investigation. Funds will not be released to a party other than the verified account holder.
Royal Spinia adopts a risk-based approach to AML compliance, applying proportionate controls according to the assessed risk presented by each customer, transaction and product type. Risk assessments take into account factors including the customer's jurisdiction, payment methods used, transaction frequency, deposit and withdrawal volumes, and gaming behaviour patterns.
Customers are assigned a risk category — Low, Medium or High — upon registration and on an ongoing basis as new information becomes available. Risk categorisation determines the level of due diligence applied and the frequency of account reviews.
All financial activity on royalspiniacasinoonline.nl is subject to ongoing monitoring. Royal Spinia employs an AI-powered Threat Analytics system that operates continuously to detect unusual patterns and flag potentially suspicious activity. TLS 1.3 encryption protects all transaction data in transit, and SSL encryption secures personal and financial records at rest, ensuring that monitoring data is handled with the same level of security as customer information.
Transaction monitoring targets, without limitation, the following indicators:
Royal Spinia accepts deposits in Bitcoin (BTC), Ethereum (ETH), Litecoin (LTC) and TRON (TRX) with a minimum deposit of €10. Crypto withdrawals are processed instantly upon confirmation. Given the pseudonymous nature of cryptocurrency, Royal Spinia applies additional scrutiny to crypto transactions, which may include blockchain analytics, enhanced source-of-funds enquiries, and, where appropriate, the application of Enhanced Due Diligence procedures. Customers using cryptocurrency must ensure that wallets used are registered in their own name and are not associated with mixers, tumblers or other obfuscation services. Royal Spinia reserves the right to decline or reverse cryptocurrency transactions where the source of funds cannot be satisfactorily established.
Royal Spinia's published financial limits serve both operational and AML purposes. The standard limits are as follows:
| Limit Type | Standard Amount | Notes |
|---|---|---|
| Minimum Deposit (card / e-wallet) | €20 | Applies to Visa, Mastercard, Skrill, Neteller, bank transfer |
| Minimum Deposit (crypto) | €10 | Applies to BTC, ETH, LTC, TRON |
| Minimum Withdrawal | €50 | Applies to all payment methods |
| Maximum Withdrawal (weekly) | €3,000 | VIP accounts may negotiate higher personalised limits subject to enhanced compliance review |
| Maximum Withdrawal (monthly) | €10,000 | As above for VIP accounts |
Requests to exceed standard limits — available to customers in the Silver, Gold and Platinum VIP tiers — are subject to enhanced due diligence as a condition of the increased limit being granted and maintained.
Any employee or contractor of Tekuno Technologies S.R.L. who identifies or suspects money laundering, terrorist financing or any other form of financial crime must report their concern internally to the designated Money Laundering Reporting Officer (MLRO) without delay. Internal reports must be made regardless of the amount involved and regardless of whether the employee is certain that a crime has occurred — reasonable suspicion is sufficient.
Where the MLRO determines that a Suspicious Activity Report (SAR) or equivalent disclosure is required under applicable law or the requirements of the Tobique Gaming Commission, the report will be filed with the relevant authority promptly and in the prescribed form. Royal Spinia will cooperate fully with any subsequent investigation conducted by law enforcement or regulatory bodies.
It is a serious criminal offence to inform a customer, or any third party, that a suspicious activity report has been made or that they are under investigation. No employee, contractor or agent of Tekuno Technologies S.R.L. may disclose — whether directly, indirectly or by implication — that an SAR has been filed or that an internal investigation is under way. Customers whose accounts are under review will be given only the information necessary to comply with their ongoing KYC obligations.
Royal Spinia screens all customers and beneficial owners against applicable international sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC) and other relevant authorities. Screening is conducted at registration and on an ongoing basis. Where a match is identified, the account will be suspended immediately pending investigation, and any funds held may be frozen in accordance with applicable legal obligations. Tekuno Technologies S.R.L. does not conduct business with individuals or entities that are subject to applicable sanctions.
A Politically Exposed Person is an individual who holds or has held a prominent public function, or who is a close family member or known associate of such a person. PEP status does not in itself preclude a customer from holding an account at Royal Spinia; however, all PEPs are automatically subject to Enhanced Due Diligence, senior management approval prior to establishing or continuing a business relationship, and ongoing enhanced monitoring throughout the relationship. Customers are required to disclose PEP status during registration and to notify Royal Spinia promptly if their status changes.
Royal Spinia maintains comprehensive records in compliance with its obligations under the Tobique Gaming Commission licence and applicable AML legislation. Records retained include, but are not limited to:
Records are retained for a minimum of five years from the end of the customer relationship or the date of the transaction, whichever is later. All records are stored securely in accordance with GDPR and Royal Spinia's Privacy Policy. Access is restricted to authorised personnel on a strict need-to-know basis.
Tekuno Technologies S.R.L. ensures that all employees whose roles involve customer interaction, account management, payments processing or compliance oversight receive appropriate AML and KYC training. Training covers the recognition of suspicious activity, the correct application of this Policy, internal reporting procedures, and the legal consequences of non-compliance. Training is provided upon commencement of employment and is refreshed on a regular basis, with updates provided whenever there are material changes to applicable law or regulatory guidance.
Royal Spinia's responsible gambling framework and its AML controls are mutually reinforcing. Unusual financial activity is frequently associated with problem gambling behaviour, and vice versa. Our AI-powered Threat Analytics system, alongside the account-level tools available to every customer — including deposit limits, loss limits, bet caps, session timers and self-exclusion — enables us to identify and act on patterns that may indicate either financial crime or gambling harm. Where an account review reveals potential gambling-related distress, the responsible gambling team will be notified in addition to any compliance escalation that may be required. Self-exclusion is available as a temporary break or a permanent block and can be activated through the customer's account profile.
Royal Spinia reserves the right to restrict, suspend or permanently close any customer account where:
Where an account is closed as a result of a compliance investigation, Royal Spinia will handle any funds held in the account in accordance with applicable legal requirements and the directions of the Tobique Gaming Commission. Customers will be notified of account closure to the extent permitted by law, and in particular subject to the tipping-off restrictions described in Section 6.3.
This Policy is reviewed at least annually, and whenever there is a material change to the regulatory environment, Royal Spinia's product offering, or the risk landscape in which Tekuno Technologies S.R.L. operates. The most current version of this Policy is always available on royalspiniacasinoonline.nl. Customers are encouraged to review the Policy periodically. Continued use of the platform constitutes acceptance of the current version.
If you have any questions regarding this AML / KYC Policy, or if you wish to submit KYC documentation or raise a compliance-related concern, please contact Royal Spinia's support team:
For responsible gambling support, Gamblers Anonymous is available as an external resource. Royal Spinia's internal responsible gambling tools — including deposit limits, loss limits, bet caps, session timers and self-exclusion — are accessible directly through your account profile settings at royalspiniacasinoonline.nl.
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