Colossus Casino AML / KYC Policy

1. Introduction and Legal Basis

Colossus Casino operates as a gambling service provider and is classified as a “designated person” for anti-money laundering (AML) and counter-terrorist financing (CTF) purposes under Irish law. This classification arises from the Criminal Justice (Money Laundering and Terrorist Financing) Acts as applied to gambling service providers operating within Ireland.

This document sets out the obligations of Colossus Casino and the requirements placed on customers in relation to AML and know your customer (KYC) procedures. Compliance with these obligations is mandatory. Failure by a customer to satisfy verification requirements may result in suspension or termination of account access and the withholding of pending transactions.

All staff at Colossus Casino receive mandatory training on AML and CTF legislation, including the recognition and handling of suspicious activity. Internal policies, controls, and procedures are reviewed regularly to reflect changes in applicable law and regulatory guidance.

2. Scope of This Policy

This policy applies to all customers who register an account with Colossus Casino and to all transactions processed through that account. It applies regardless of the amount of any individual transaction, subject to the specific thresholds described in Section 4.

This policy covers the following areas:

• Customer identification and verification
• Customer due diligence and enhanced due diligence
• Source of funds and source of wealth assessment
• Ongoing transaction monitoring
• Record-keeping obligations
• Suspicious transaction reporting

3. Customer Identification and Verification

Colossus Casino is required to identify and verify the identity of each customer before permitting access to real-money activity. Verification must be completed using valid and reliable documentation.

Customers are required to provide the following:

• Proof of identity: A valid government-issued photo identification document, such as a passport or driving licence.
• Proof of address: A document confirming the customer’s residential address, such as a recent utility bill or official government correspondence, issued within the preceding three months.
• Proof of age: Colossus Casino does not permit access to real-money gambling for any person under the age of 18. Age verification is a mandatory component of the onboarding process.

Verification may be conducted through digital identity systems, including document scanning and biometric liveness checks, where applicable. Colossus Casino reserves the right to request additional documentation at any stage of the customer relationship.

4. Customer Due Diligence and Thresholds

Colossus Casino applies a risk-based approach to customer due diligence (CDD). The level of due diligence applied to each customer is proportionate to the assessed risk associated with that customer, their transactions, and their jurisdiction of residence.

The following thresholds apply to customers in Ireland in accordance with applicable regulatory guidance.

Standard CDD Thresholds

Monitoring following a €200 trigger is maintained for a minimum of six months for online accounts.

CDD requires the collection and verification of the customer’s name, date of birth, residential address, and government-issued identification. Where CDD cannot be completed to the satisfaction of Colossus Casino, the relevant transaction will not proceed.

Enhanced Due Diligence

Enhanced due diligence (EDD) is applied to customers assessed as presenting a higher risk of money laundering or terrorist financing. Categories of customers subject to EDD include, but are not limited to:

• Politically exposed persons (PEPs) and their close associates
• Customers exhibiting unusual or inconsistent betting patterns
• Customers involved in high-value transactions
• Customers connected to jurisdictions identified by the Financial Action Task Force (FATF) as high-risk or subject to increased monitoring

EDD may require the provision of additional documentation, including source of funds (SOF) and source of wealth (SOW) information. Colossus Casino will specify the documentation required on a case-by-case basis.

5. Source of Funds and Source of Wealth

Where a customer’s transaction history, account behaviour, or risk profile indicates a need for further scrutiny, Colossus Casino may request evidence of the origin of funds used for gambling activity and, where appropriate, evidence of the customer’s overall financial position.

Customers are required to respond to such requests within the timeframe specified by Colossus Casino. Failure to provide satisfactory documentation may result in the restriction or closure of the account and the suspension of any pending withdrawals pending further review.

6. Ongoing Monitoring

Colossus Casino conducts ongoing monitoring of customer accounts and transactions. Monitoring is designed to detect activity that is inconsistent with a customer’s known profile, stated source of funds, or expected transaction behaviour.

Patterns that may trigger additional review include:

• Large deposits followed by minimal gambling activity and rapid withdrawal requests
• Frequent deposit and withdrawal cycles without corresponding gambling activity
• Structured transactions that appear designed to remain below reporting thresholds
• Sudden and unexplained changes in transaction volume or value
• Activity inconsistent with the customer’s declared occupation or financial profile

Where monitoring identifies activity of concern, Colossus Casino may request additional documentation, restrict account activity, or file a report with the relevant authority.

7. Suspicious Transaction Reporting

Colossus Casino is legally obligated to report transactions or patterns of activity that give rise to a suspicion of money laundering or terrorist financing. Reports are submitted to:

• The Financial Intelligence Unit (FIU) of An Garda Síochána via the GoAML online reporting platform
• The Revenue Commissioners via Revenue’s Online Service (ROS)

Suspicious Transaction Reports (STRs) are submitted in accordance with the procedures and confidentiality requirements prescribed by Irish law. Colossus Casino does not disclose to any customer that a report has been or may be filed in connection with their account. Disclosure of such information to a customer, or to any third party not authorised to receive it, is prohibited under applicable legislation.

8. Record-Keeping

Colossus Casino retains all records relating to customer identification, verification, transactions, due diligence decisions, and compliance actions for a minimum of five years from the date of the relevant transaction or the end of the customer relationship, whichever is later. Records are maintained in a form that permits their retrieval and production to competent authorities upon request.

9. High-Risk Jurisdictions

Customers connected to jurisdictions identified by FATF as high-risk or subject to enhanced monitoring are subject to additional due diligence requirements. Colossus Casino reserves the right to restrict or decline account registration or transactions where a customer’s jurisdiction of residence or the origin of funds presents an unacceptable level of risk under this policy.

10. Integration with Responsible Gambling Obligations

AML and KYC procedures at Colossus Casino are implemented in conjunction with responsible gambling obligations. Behavioural monitoring conducted for AML purposes may also identify indicators of problem gambling. Where such indicators are identified, Colossus Casino will take steps in accordance with its Responsible Gambling Policy, which operates independently of and in addition to this AML / KYC Policy.

11. Customer Obligations

By registering an account with Colossus Casino, customers acknowledge and accept the following obligations:

• To provide accurate, complete, and current information at the time of registration and upon request at any subsequent point
• To submit required verification documents within the timeframes specified by Colossus Casino
• To notify Colossus Casino of any material change to their personal or financial circumstances that may affect their risk profile
• To cooperate fully with any due diligence or investigation process initiated by Colossus Casino

Provision of false, misleading, or fraudulent documentation constitutes a serious breach of these terms and may result in immediate account closure, forfeiture of any pending balances subject to legal review, and referral to the relevant authorities.

12. Policy Review

This policy is reviewed periodically to ensure continued compliance with applicable Irish and European AML legislation, regulatory guidance, and FATF recommendations. Updates to this policy take effect upon publication and apply to all existing and new customer accounts.