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Home › AML / KYC Policy

This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Casbit Group N.V., the operator of Justbit Casino at justbitonline.org, and the requirements placed upon all registered players. The Policy is maintained in accordance with the conditions of our Curaçao eGaming licence (Licence No. 8048/JAZ) and reflects internationally recognised standards for the prevention of money laundering, terrorist financing, and related financial crime.

1. Introduction and Purpose

Justbit Casino is operated by Casbit Group N.V. and has been providing licensed real-money gaming services since 2021. We take our legal and ethical obligations in respect of financial crime prevention seriously. This Policy explains how we identify our customers, monitor account activity, assess risk, and respond when suspicious behaviour is detected.

The primary objectives of this Policy are to:

  • Prevent Justbit Casino and justbitonline.org from being used as a vehicle for money laundering or terrorist financing;
  • Ensure that all players are who they claim to be before funds are released;
  • Comply with the requirements of our Curaçao eGaming licence and applicable anti-money laundering legislation;
  • Protect the integrity of the platform, its games, and the wider financial system.

This Policy applies to all players, regardless of their country of residence, the currency they use, or the payment method through which they transact. It applies equally to fiat deposits and withdrawals and to all cryptocurrency transactions processed through justbitonline.org.

2. Legal Framework and Regulatory Basis

Casbit Group N.V. is incorporated and licensed under the laws of Curaçao. Our gaming operations are conducted under Curaçao eGaming Licence No. 8048/JAZ. This licence requires us to maintain robust AML and KYC controls as a condition of continued authorisation to operate.

In designing and implementing this Policy, we have had regard to:

  • The Financial Action Task Force (FATF) Forty Recommendations and associated guidance for the gambling sector;
  • The Curaçao National Ordinance on the Identification of Clients when Rendering Financial Services;
  • The Curaçao National Ordinance on the Reporting of Unusual Transactions;
  • EU Anti-Money Laundering Directives (applied as best-practice reference standards);
  • International standards relating to counter-terrorist financing (CTF).

Where the standards required by these frameworks differ, we apply whichever is the more stringent. This Policy is reviewed at least annually and updated whenever there is a material change in our regulatory environment or operational risk profile.

3. Scope of Application

This Policy applies to:

  • All registered accounts held on justbitonline.org;
  • All deposit and withdrawal transactions regardless of payment method or currency, including Bitcoin (BTC), Ethereum (ETH), Litecoin (LTC), Tether (USDT), Dogecoin (DOGE), XRP, and all other cryptocurrencies accepted on the platform, as well as fiat transactions in EUR, USD, CAD, NOK, and any other supported currency;
  • All bonus, cashback, rakeback, and VIP reward payments made by Justbit Casino;
  • All sports betting activity conducted through the Justbit Casino sportsbook;
  • All live casino, slot, and instant-game activity where transaction volumes or patterns give rise to concern.

4. Know Your Customer (KYC) Policy

4.1 Why We Conduct KYC

KYC is the process by which Justbit Casino verifies the identity of its players and assesses any risk they may present. It is not an optional step. KYC allows us to confirm that players are of legal age, that they are transacting with funds they legitimately own, and that they are not subject to sanctions or other restrictions that would prohibit us from servicing them.

As stated on justbitonline.org, cryptocurrency players may deposit without having first submitted KYC documentation. However, KYC verification is mandatory before any withdrawal is processed, without exception. Verified accounts additionally benefit from faster processing times and access to higher withdrawal limits as standard.

4.2 When KYC Is Triggered

Verification may be requested at any of the following points:

  • Prior to the processing of any withdrawal request;
  • When a player's cumulative deposits reach a threshold that triggers enhanced due diligence under our internal risk framework;
  • When a withdrawal request exceeds €5,000, which triggers a mandatory re-verification step under our AML compliance rules;
  • When account activity displays patterns consistent with money laundering, bonus abuse, or structuring;
  • When a player is identified as a Politically Exposed Person (PEP) or appears on a sanctions list;
  • At any time our compliance team has reasonable grounds to request further documentation.

We reserve the right to suspend withdrawal processing, restrict account functionality, or withhold bonus payments pending completion of KYC. Players who fail to complete KYC within the timeframe specified in our verification request may have their accounts suspended.

4.3 Identity Verification — Standard Documents

To verify identity, players will be asked to provide at least one document from each of the following categories:

  • Proof of Identity (POI): A valid, government-issued photo ID, such as a passport, national identity card, or driving licence. The document must be current, clearly legible, and show the player's full name, date of birth, and photograph.
  • Proof of Address (POA): A recent utility bill, bank statement, council tax notice, or similar official document dated within the last three months, showing the player's full name and residential address.
  • Proof of Age: Where not sufficiently evidenced by the above, we may request additional documentation to confirm that the player is 18 years of age or older.

All documents must be submitted in a clear, unedited format. Photographs of documents must show all four corners of the document and must not be obscured by glare, cropping, or image filters. Documents submitted in a language other than English may need to be accompanied by a certified translation.

4.4 Payment Method Verification

In addition to identity documents, Justbit Casino may require players to verify the payment methods used on their account. This may include:

  • Cards (Visa / Mastercard): A photograph of the front and back of the card used, with the middle eight digits on the front obscured for security. The name on the card must match the name on the registered account.
  • E-wallets (Skrill / Neteller): Confirmation that the e-wallet account is registered in the same name as the Justbit Casino account.
  • Cryptocurrency wallets: Confirmation that the originating wallet address belongs to the account holder. We do not accept transfers from third-party wallets, cryptocurrency mixers, tumbler services, or anonymous wallet providers.
  • Bank transfers: A copy of the relevant bank statement or a screenshot showing the account holder's name and the relevant transaction.

Justbit Casino applies the principle that funds must be deposited and withdrawn using the same method wherever possible, and always to a payment account registered in the player's own name.

4.5 Source of Funds and Source of Wealth

For players who transact at higher volumes, or whose account activity triggers enhanced due diligence, Justbit Casino may request evidence of the source of the funds used to gamble ("Source of Funds") and, in more significant cases, the broader source of the player's wealth ("Source of Wealth").

Acceptable Source of Funds documentation may include:

  • Recent payslips or employment contracts;
  • Tax returns or self-assessment records;
  • Bank statements showing salary or regular income credits;
  • Evidence of a business ownership, dividend payment, or sale of assets;
  • Inheritance or gift documentation, including the testator's details where relevant;
  • Proof of investment returns, rental income, or pension payments.

We understand that providing such documentation may feel intrusive. It is, however, a legal and regulatory necessity. Failure or refusal to provide Source of Funds documentation when requested may result in withdrawal suspension and, where the circumstances warrant it, a report to the relevant financial intelligence unit.

4.6 KYC for VIP and High-Value Players

Players participating in the Justbit Casino VIP programme — particularly those at Gold, Platinum, Diamond, or Elite tier — will be subject to enhanced due diligence as a matter of course. The significant cashback and level-up reward amounts available through the VIP programme (including monthly cashback up to 20% and level-up bonuses reaching a combined total of €14,000) mean that we have a heightened obligation to confirm the legitimacy of funds and the identity of the account holder.

VIP players may be asked to complete full KYC before accessing tier-specific benefits, including personal manager services, birthday bonuses, and sponsored events. Elite-tier players with access to luxury trips and VIP events in Malta and Cyprus will be subject to comprehensive Source of Wealth checks before participation.

Withdrawals above €5,000, including VIP cashback and tournament winnings, trigger a re-verification step regardless of tier status.

4.7 Data Retention

All KYC documentation submitted to Justbit Casino is stored securely and retained for a minimum of five years from the date of the player's last transaction or account closure, whichever is later. This retention period is consistent with standard AML regulatory expectations. Data is held in accordance with our Privacy Policy and applicable data protection legislation.

5. Anti-Money Laundering (AML) Controls

5.1 What Is Money Laundering?

Money laundering is the process by which the proceeds of criminal activity are disguised to appear as legitimate funds. It typically occurs in three stages: placement (introducing criminal proceeds into the financial system), layering (concealing the trail through a series of transactions), and integration (reintroducing the funds into the legitimate economy). Online casinos are a recognised vehicle for all three stages if proper controls are not in place.

Terrorist financing involves the provision of funds — regardless of whether those funds are themselves criminal in origin — to support acts of terrorism or terrorist organisations. Our AML controls address both money laundering and terrorist financing risk.

5.2 Risk-Based Approach

Justbit Casino applies a risk-based approach to AML compliance. This means that we assess the risk presented by each player and each transaction and calibrate our controls accordingly. Not every player presents the same level of risk, and we do not apply identical scrutiny to all accounts. However, where risk indicators are present, we apply enhanced due diligence without hesitation.

Risk factors that may elevate a player's risk rating include:

  • Country of residence or nationality associated with elevated ML/TF risk per FATF assessments;
  • High deposit or withdrawal volumes relative to stated income;
  • Rapid cycling of funds — depositing and withdrawing without meaningful play;
  • Use of multiple payment methods or payment accounts;
  • Transactions structured in amounts just below verification thresholds (structuring);
  • PEP status or close association with a known PEP;
  • Matches against international sanctions lists;
  • Inconsistency between stated occupation and transaction volumes;
  • Use of cryptocurrency mixing services, privacy coins, or anonymisation tools.

5.3 Transaction Monitoring

All transactions on justbitonline.org are subject to automated and manual monitoring. Our systems are designed to detect patterns consistent with money laundering activity, including but not limited to:

  • Deposits followed immediately by withdrawals without meaningful gaming activity;
  • Repeated deposits close to the minimum threshold (€10 for cards and most methods; €20 for Skrill and Neteller) in patterns that suggest structuring;
  • Unusually large single deposits relative to a player's historical behaviour;
  • Withdrawal requests significantly in excess of net gaming losses;
  • Multiple failed withdrawal attempts followed by a successful one to a different account;
  • Activity inconsistent with a player's stated source of funds or wealth;
  • Cryptocurrency deposits from wallet addresses associated with illicit activity.

Weekly withdrawal limits are set at €300,000 for cryptocurrency and €5,000 for card, e-wallet, and bank transfer methods. Any transaction or series of transactions approaching or exceeding these thresholds will be subject to additional scrutiny.

5.4 Sanctions Screening

Justbit Casino screens all players against relevant international sanctions lists, including those maintained by the United Nations Security Council, the European Union, the Office of Foreign Assets Control (OFAC) of the United States Treasury, and the United Kingdom's Office of Financial Sanctions Implementation (OFSI). This screening occurs at registration and is repeated on an ongoing basis.

If a player is identified as a sanctioned individual or entity, their account will be suspended immediately and the matter referred to our compliance team. No transactions will be processed for sanctioned persons.

5.5 Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds, or has held within the past twelve months, a prominent public function, such as a head of state, government minister, senior judicial or military officer, senior executive of a state-owned enterprise, or an important political party official. This definition also extends to immediate family members and known close associates of such individuals.

Where a player is identified as a PEP, Justbit Casino will apply enhanced due diligence measures as standard. This includes requiring senior management approval before establishing or continuing a business relationship, taking reasonable measures to establish the source of wealth and source of funds, and conducting enhanced ongoing monitoring of the relationship. PEP status alone does not automatically disqualify a player from using Justbit Casino, but it does trigger a higher level of scrutiny.

5.6 Cryptocurrency-Specific AML Measures

Justbit Casino accepts a range of cryptocurrencies including Bitcoin, Ethereum, Litecoin, USDT, DOGE, and XRP. The pseudonymous nature of cryptocurrency transactions creates specific AML risks, and we apply the following controls accordingly:

  • Blockchain analytics tools are used to assess the risk profile of incoming cryptocurrency transactions, including screening for wallet addresses associated with darknet markets, ransomware, fraud, or other illicit activity;
  • Deposits originating from high-risk wallet addresses may be declined or held pending investigation;
  • Cryptocurrency withdrawals are processed exclusively to wallet addresses belonging to the verified account holder; third-party cryptocurrency withdrawals are not permitted;
  • The use of cryptocurrency mixing, tumbling, or anonymisation services is prohibited; accounts found to be using such services will be reviewed and may be suspended;
  • Despite the speed at which cryptocurrency withdrawals are processed (5 to 15 minutes for verified accounts), all outgoing cryptocurrency transactions are subject to AML screening prior to release.

6. Suspicious Activity Reporting

Where Justbit Casino's compliance team forms a suspicion, or has reasonable grounds to suspect, that a player or transaction is connected to money laundering or terrorist financing, a Suspicious Activity Report (SAR) or equivalent report will be filed with the competent financial intelligence unit under Curaçao law. We are legally prohibited from informing the player that such a report has been made ("tipping off").

In connection with an active suspicion, we may:

  • Suspend the processing of any pending withdrawal;
  • Freeze or restrict the player's account;
  • Request additional documentation from the player;
  • Retain funds in the account pending the outcome of any investigation;
  • Cooperate fully with any law enforcement or regulatory inquiry.

Where a SAR has been submitted and a player's account has been suspended, we will not be liable to the player for any delay in processing withdrawals or for any restriction placed on account functionality during the period of investigation.

7. Prohibited Activities and Restricted Jurisdictions

The following activities are strictly prohibited on justbitonline.org and will result in account suspension, forfeiture of funds, and reporting to the relevant authorities where appropriate:

  • Using Justbit Casino to launder the proceeds of crime or to finance terrorism;
  • Opening an account using false, incomplete, or misleading identity information;
  • Using a payment account registered in the name of a third party;
  • Receiving funds from, or sending funds to, another player's account for the purpose of obscuring the origin or destination of those funds;
  • Structuring deposits or withdrawals to circumvent verification thresholds;
  • Accessing Justbit Casino from a jurisdiction in which online gambling is prohibited or where we do not hold the requisite authorisation to operate.

Justbit Casino serves players in over 80 countries. However, certain jurisdictions are excluded from our services. Players are responsible for ensuring that online gambling is lawful in their jurisdiction before registering. We reserve the right to refuse service, close accounts, and return deposits to players found to be accessing the platform from a restricted territory.

8. Player Obligations

By registering an account on justbitonline.org, players agree to:

  • Provide accurate, complete, and up-to-date personal information at registration and whenever it changes;
  • Submit KYC documentation promptly when requested, and in any event before any withdrawal is processed;
  • Only deposit funds that belong to them and that have been obtained through lawful means;
  • Not use payment methods registered to third parties;
  • Not use any anonymisation technology — including VPNs, proxies, or Tor — to disguise their true location or identity when accessing the platform;
  • Cooperate fully and honestly with any compliance review or verification request made by Justbit Casino.

Failure to comply with these obligations may result in the suspension or closure of the player's account, the withholding or forfeiture of balances, and the reporting of the account to the relevant authorities.

9. Employee Training and Internal Controls

Casbit Group N.V. maintains a designated Money Laundering Reporting Officer (MLRO) who is responsible for the oversight and implementation of this Policy, for receiving and assessing internal suspicion reports, and for making external disclosures to the relevant financial intelligence unit where required.

All employees and contractors with access to player account data or transaction records receive AML and KYC training appropriate to their role. Training covers the recognition of suspicious activity indicators, the correct procedure for escalating concerns, and the legal consequences of tipping off. Training records are maintained and made available to regulators on request.

Internal controls are reviewed regularly and are subject to independent audit. Any identified weaknesses are addressed promptly.

10. Responsible Gambling and AML Interaction

Justbit Casino recognises that problem gambling and money laundering can, on occasion, present overlapping indicators. Unusually high deposit volumes, for example, may be a sign of either gambling harm or of illicit fund placement. Our compliance and responsible gambling teams work in conjunction to ensure that customers showing signs of either concern receive appropriate intervention.

Players can access responsible gambling tools directly through their account, including deposit limits, session limits, and self-exclusion. If you believe your gambling is causing you harm, please contact our 24/7 support team via Live Chat, email, or Telegram. Our support team is available at all times and will direct you to the appropriate tools and external support organisations.

We will not knowingly accept deposits from, or pay winnings to, a player who has self-excluded or whose account has been flagged as requiring responsible gambling intervention.

11. Verification Timelines and Withdrawal Impact

We are committed to processing withdrawals quickly. Cryptocurrency withdrawals for verified accounts are processed within 5 to 15 minutes. E-wallet withdrawals are processed within 1 to 12 hours. Card withdrawals are processed within 24 to 48 hours. Bank transfers take up to 48 hours.

These timelines apply to accounts that have completed KYC. Where a verification request is pending, withdrawal processing will be paused until the request is satisfied. The following specific triggers apply:

Trigger Action Required
First withdrawal request (unverified account) Full KYC must be completed before processing
Withdrawal exceeding €5,000 Mandatory re-verification step under AML compliance rules
Account flagged for enhanced due diligence Source of Funds documentation required before processing
PEP identified Senior management approval and enhanced due diligence required
Sanctions match identified Account suspended; matter referred to compliance team
Suspicious activity detected Account review initiated; withdrawal held pending outcome

Justbit Casino will not charge players for any delays caused by legitimate compliance procedures. However, where delays arise from a player's failure to submit documentation promptly, we cannot guarantee the processing timelines stated above.

12. Contact and Compliance Enquiries

If you have a question about this Policy, about a KYC request made to you, or about a decision affecting your account, you may contact Justbit Casino through any of the following channels:

  • 24/7 Live Chat: Available directly on justbitonline.org
  • Email: Via the contact address listed in the Help section of justbitonline.org
  • Telegram: Via the official Justbit Casino Telegram channel

Our compliance team will respond to verification-related enquiries as promptly as possible. For urgent matters affecting a pending withdrawal, we recommend using Live Chat in the first instance.

13. Policy Updates

This Policy will be reviewed at least once per calendar year and whenever there is a material change in our regulatory obligations, business operations, or risk environment. The current version of this Policy is available at all times on justbitonline.org. Continued use of the platform following the publication of an updated Policy constitutes acceptance of the revised terms.

Casbit Group N.V. reserves the right to amend this Policy at any time without prior notice, subject to the requirements of our Curaçao eGaming licence and applicable law.

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