Neospin AML Policy

Purpose and Scope

Neospin.com is owned and operated by Metlait SRL, a company incorporated under the laws of Costa Rica with registration number 3-102-911867, registered at El Guayaval, Residencial La Campina Casa Numero Q-11, Cartago, El Guarco, Tejar, 30801, Costa Rica. Metlait SRL is licensed by the Tobique Gaming Commission under E-gaming Licence No. 0000064.

A risk based Anti-Money Laundering and Counter-Terrorist Financing Policy applies across the platform. It sets out the principles and the minimum standard of internal control the Company applies to reduce reputational, regulatory, legal and financial risk, and it operates alongside the Terms and Conditions rather than in place of them.

Verification Authority

Accepting the Terms authorises the Company to carry out checks at its own discretion, or where a third party such as a regulator requires them, in order to confirm a Player’s identity and contact details. These checks are referred to throughout as Verification.

Verification may be repeated at any point in the life of an account. Registration is not the only trigger.

Registration Requirements

Only a registered account holder may play for money. Registration is personal and cannot be completed on behalf of another individual.

The following is required at registration:

• Date of birth, together with valid identification showing the Player is 18 or over, or has reached the legal age of majority in their jurisdiction where that age is higher;
• A copy of a valid passport or other identification document, along with proof of address;
• The Player’s first and last name;
• The Player’s full residential address;
• A valid email address.

Further documentation and additional checks may be requested to confirm the information supplied. An account may stay suspended until satisfactory information is received.

Underage Play

An account may be suspended where eligible age cannot be established.

Where a Player is found to have used the gambling services below the eligible age:

• The account is closed;
• Transactions from that period are annulled and deposited money is returned;
• Bets from that period are cancelled and refunded;
• Winnings accumulated during that period are forfeited, and amounts already withdrawn must be repaid on request;
• A deposit made to the account is not refunded where the closure follows a policy breach.

False or Incomplete Information

Information supplied at registration that proves false, incomplete, inaccurate or misleading, or that fails to correspond with the identity documents provided, constitutes a breach of the Terms. The Company may then close the account, cancel the balance and apply any further measure at its discretion, including refusal of further access to the services.

Review Timelines

Review of KYC documents may take up to 30 working days from the moment the Player has supplied every requested item. The clock starts at the arrival of the final document rather than the first.

Withdrawal requests remain pending while Verification is in progress.

Where the Company cannot reach a Player by phone or email within two weeks of a request, the account is locked and any pending withdrawal is cancelled.

Source of Funds

Documents evidencing source of funds or source of wealth may be requested where transaction patterns, deposit volumes or risk indicators warrant it. Bank statements, income declarations and equivalent records fall within this category.

Deposits must originate from a payment account registered in the Player’s own name. Third party funding is prohibited and triggers the measures set out in the Terms and Conditions.

Monitoring and Reporting

Transaction activity is monitored on a risk basis. Patterns consistent with layering, structuring or the movement of funds without genuine gameplay are escalated for internal review.

Where activity meets the threshold for suspicion, the Company reports it to the relevant authority and may freeze the account and its balance pending the outcome. Notification to the Player is withheld where the law requires it.

Records of identification data, transactions and correspondence are retained for a minimum of five years after an account is closed.

Contact

Questions about this policy go to [email protected]. Data protection enquiries go to [email protected].