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Terms of Use

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Operator: Carlitta N.V.
Last Updated: 09.06.2025

1. Introduction

Carlitta N.V., a company incorporated under the laws of Curaçao and licensed by the Curaçao Gaming Control Board under License № OGL/2024/1516/0841, applies strict Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Proliferation Financing (PF) controls.

These measures are designed to:

  • Protect players and the integrity of the platform
  • Prevent financial crime
  • Ensure compliance with applicable laws and regulations

This Policy is implemented in accordance with:

  • AML/CFT Regulations issued by the Curaçao Gaming Authority (CGA)
  • National Ordinance on the Reporting of Unusual Transactions (NORUT)
  • National Ordinance on Identification when Rendering Services (NOIS)
  • The Kingdom Sanctions Act (Rijkssanctiewet)
  • The Sanctions National Ordinance
  • The FATF 40 Recommendations

Carlitta N.V. maintains a zero-tolerance approach toward money laundering, terrorist financing, and proliferation financing.

2. Purpose of This Policy

This Policy ensures that Carlitta N.V.:

  • Prevents misuse of its platform for money laundering, terrorist financing, or proliferation of weapons of mass destruction
  • Verifies that player funds originate from lawful sources
  • Applies risk-based customer verification procedures
  • Complies with Curaçao AML/CFT regulations and international standards
  • Protects its reputation, players, and systems

3. Definitions

Money Laundering (ML), Terrorist Financing (TF), Proliferation Financing (PF):
Criminal activities defined under applicable law involving unlawful financial transactions.

Know Your Customer (KYC):
The process of identifying and verifying a customer’s identity before or during the business relationship.

Customer Due Diligence (CDD):
Procedures used to verify identity, assess risk, and monitor transactions.

Politically Exposed Person (PEP):
An individual who holds or has held a prominent public function, including close associates and family members.

Sanctions Screening:
The process of checking customers against international sanctions lists (UN, EU, OFAC, etc.).

FIU:
Financial Intelligence Unit Curaçao.

4. Scope of Application

This Policy applies to:

  • All registered players
  • All deposit and withdrawal activities
  • Operational and KYC-related staff
  • Third-party KYC or payment service providers acting on behalf of Carlitta N.V.

5. Age & Jurisdiction Restrictions

Minimum Age Requirement

Access to the platform is strictly limited to individuals aged 18 years or older.

Carlitta N.V. verifies date of birth during registration and KYC review.
Accounts belonging to underage individuals will be terminated.

Prohibited Jurisdictions

Players may not access the platform if located in jurisdictions:

  • Subject to international sanctions (UN, EU, OFAC)
  • Listed by FATF as high-risk jurisdictions
  • Prohibited under Curaçao Gaming Authority regulations
  • Included in Carlitta N.V.’s internal restricted list

Technical enforcement measures include:

  • Geo-IP blocking
  • VPN/proxy detection
  • Payment origin monitoring

Accounts attempting to bypass restrictions may be closed.

6. Account Registration Requirements

To register an account, players must provide:

  • Full legal name
  • Date and place of birth
  • Permanent residential address
  • Nationality
  • Valid email address
  • Mobile number
  • Identity reference number (if applicable)
  • Preferred currency
  • Secure password

Email verification is mandatory before access to deposits or gameplay.

Carlitta N.V. reserves the right to request supporting documents at any time.

7. Know Your Customer (KYC) Verification

Identity verification is mandatory.

Only verified players may access full account functionality.

Required Documents

1. Proof of Identity

Government-issued photo ID:

  • Passport
  • National ID card
  • Driver’s license
  • Residency card

Additionally:

  • A selfie holding the submitted ID
  • Clear visibility of face and document
  • No glare, blur, or obstruction

2. Proof of Address

Issued within the last 6 months:

  • Utility bill
  • Bank statement
  • Lease agreement

3. Document Standards

Documents must:

  • Be in color
  • Show all edges
  • Be legible and unaltered
  • Be free from glare or obstruction

4. Additional Documentation

Carlitta N.V. may request:

  • Proof of payment method ownership
  • Source of Funds (SoF)
  • Source of Wealth (SoW)
  • Certified or notarized copies

Failure to comply may result in account restrictions.

8. Payment Method Verification

Players must:

  • Use only payment methods registered in their own name
  • Avoid third-party payment instruments
  • Accept withdrawals via the original deposit method where possible

Cash transactions are not permitted.

Carlitta N.V. may request documentation to confirm payment ownership.

9. Customer Due Diligence (CDD)

Carlitta N.V. applies risk-based CDD procedures.

All accounts are subject to:

  • Ongoing monitoring
  • Risk reassessment
  • Transaction analysis

Risk classification may change over time.

10. Politically Exposed Persons (PEPs)

PEPs are subject to enhanced due diligence measures, including:

  • Additional identity verification
  • Senior management approval
  • Periodic review

PEP status is continuously monitored.

11. Ongoing Monitoring & Re-verification

Carlitta N.V. may request updated documentation at any time.

Account functionality may be temporarily limited until verification is completed.

Monitoring includes:

  • Behavioral analysis
  • Transaction pattern review
  • Jurisdictional exposure checks

12. Transaction Monitoring

The Company uses automated and manual systems to detect suspicious activity.

Monitoring ensures compliance with Curaçao AML/CFT regulations and industry standards.

13. Sanctions Compliance

All players are screened against:

  • UN Security Council lists
  • EU sanctions lists
  • OFAC lists
  • Other applicable authorities

Accounts linked to sanctioned individuals may be blocked.

Records are retained for:

  • Minimum 5 years after account closure
  • Up to 10 years if required by FIU

14. Sanctions for Non-Compliance

Failure to comply may result in:

  • Account suspension
  • Withdrawal blocking
  • Termination of services
  • Reporting to FIU Curaçao
  • Legal or regulatory action

Carlitta N.V. acts at its sole discretion where necessary to ensure compliance.

15. Payout Management

Withdrawals are processed only after:

  • Identity verification
  • Payment method confirmation
  • Completion of wagering requirements (if applicable)

Funds must be used for genuine gaming activity.

Withdrawals to third-party accounts are strictly prohibited.

16. Player Responsibilities

Players must:

  • Provide accurate information
  • Use only personal identity and payment methods
  • Maintain one account only
  • Cooperate with verification requests
  • Avoid bypassing platform restrictions

Violations may result in account closure and forfeiture of funds.

17. Data Protection & Confidentiality

Carlitta N.V. ensures:

  • Encryption of sensitive information
  • Restricted access to compliance data
  • Secure storage of KYC records
  • Incident response procedures

All data handling complies with applicable privacy laws.

18. Cooperation with Authorities

Carlitta N.V. cooperates with:

  • FIU Curaçao
  • Regulatory bodies
  • Law enforcement agencies

Information may be disclosed under lawful request.

19. Compliance Officer

Carlitta N.V. has appointed a qualified Compliance Officer responsible for:

  • AML/CFT program oversight
  • Transaction monitoring
  • Regulatory liaison
  • Staff training
  • Risk assessments

The Compliance Officer operates independently and reports to senior management.

20. Continuous Improvement

This AML/KYC framework is reviewed:

  • At least annually
  • After regulatory updates
  • Following material risk changes

Controls are continuously improved to remain aligned with international standards.

21. Support & Contact

For AML/KYC-related inquiries, players may contact customer support through official communication channels.

All inquiries are handled confidentially.

Carlitta N.V. remains committed to regulatory compliance, fair play, and maintaining a secure and lawful gaming environment.