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

Customer (KYC) Policy

Effective Date: June 9, 2025
Operator: Carlitta N.V., License No. OGL/2024/1516/0841 (Curaçao)

1. Introduction

At pinco.inc, operated by Carlitta N.V., we are committed to the highest standards of integrity, security, and regulatory compliance. Our Know Your Customer (KYC) and Anti-Money Laundering (AML) policies are designed to prevent illicit financial activity and ensure a safe, transparent environment for all users.

Our procedures comply with:

  • Curaçao Gaming Authority AML/CFT Regulations
  • National Ordinance on Reporting Unusual Transactions (NORUT)
  • National Ordinance on Identification (NOIS)
  • Kingdom Sanctions Act & Sanctions National Ordinance
  • FATF’s 40 Recommendations

2. Policy Objectives

Our KYC/AML Policy is designed to:

  • Prevent use of our platform for money laundering, terrorist financing, or arms proliferation
  • Ensure that all user funds originate from lawful sources
  • Apply tiered, risk-based verification practices
  • Fulfill both Curaçao and international regulatory obligations
  • Protect our customers, systems, and brand integrity

3. Definitions

  • KYC: Verification of player identity using documentation and screening
  • CDD: Customer Due Diligence, used to assess customer legitimacy
  • ML/TF/PF: Money Laundering, Terrorist Financing, Proliferation Financing
  • PEP: Politically Exposed Person (government officials, associates)
  • FIU: Financial Intelligence Unit of Curaçao

4. Applicability

This policy applies to:

  • All customers registered on pinco.inc
  • Internal departments (KYC, support, compliance)
  • Third-party providers handling KYC or payments

5. Eligibility & Jurisdiction

5.1 Minimum Age
Only individuals aged 18 or older may register. Age verification is mandatory. Underage accounts will be closed, and any funds may be forfeited.

5.2 Restricted Jurisdictions
Access is prohibited from:

  • Sanctioned countries (UN, EU, OFAC)
  • High-risk jurisdictions (FATF listed)
  • Regions on Carlitta N.V.’s internal restricted list

Geo-IP blocking, VPN detection, and transaction monitoring are enforced.

6. Registration Requirements

To create an account, users must provide:

  • Full legal name
  • Date and place of birth
  • Residential address
  • Nationality
  • Valid email and phone number
  • Identity number (if applicable)
  • Preferred currency and secure password

Email verification is mandatory. Additional documents may be requested.

7. Know Your Customer (KYC)

KYC is required before full account access or withdrawals.

Accepted Identity Documents:

  • Passport
  • National ID card
  • Driver’s license
  • Residence permit

Proof of Address (Issued within 6 months):

  • Utility bill
  • Bank statement
  • Lease agreement

Document Criteria:

  • Full-color, legible, unaltered
  • All corners visible
  • Translations or certified copies if needed

Additional documents may include:

  • Payment method ownership
  • Source of funds/wealth
  • Certified KYC packages

8. Payment Verification

Key Rules:

  • Only personal accounts allowed — no third-party transactions
  • Withdrawals must match the deposit method (where applicable)
  • No cash transactions; only traceable methods permitted
  • Documentation may be requested to verify ownership

Non-compliance can result in delays or account restrictions.

9. Customer Due Diligence (CDD)

CDD procedures vary by player risk level. Enhanced Due Diligence (EDD) applies to high-risk accounts, including high-value transactions or complex profiles.

10. Politically Exposed Persons (PEPs)

PEPs undergo additional scrutiny:

  • EDD checks
  • Approval from senior management
  • Ongoing relationship reviews

PEP status is continuously monitored.

11. Re-Verification

Players may be asked to update or re-submit documents at any time. Certain services may be restricted until verification is complete.

12. Ongoing Monitoring

We monitor account activity through:

  • Continuous document review
  • Behavior and risk analysis
  • Alerts for suspicious transactions

This ensures compliance and account security over time.

13. Transaction Oversight

Automated and manual systems identify:

  • Unusual transaction patterns
  • Structuring behavior
  • Transactions outside expected profiles

Suspicious activity may be reported to authorities.

14. Sanctions Screening

All users are checked against international and local sanctions lists, including:

  • UN Security Council
  • EU and OFAC lists
  • Curaçao regulators

Accounts tied to sanctioned individuals are blocked or terminated.

15. Recordkeeping

We retain all relevant records for 5–10 years, including:

  • Identity documentation
  • Payment and transaction logs
  • Risk assessments
  • Regulatory communications

All records are securely stored in compliance with data protection laws.

16. Policy Maintenance

Our policy is reviewed regularly in response to:

  • Legal or regulatory changes
  • New risk patterns or technology
  • Internal audits and findings

This ensures ongoing compliance and best practices.

17. Sanctions for Non-Compliance

Failure to meet KYC/AML requirements may result in:

  • Account suspension or termination
  • Withdrawal blocks
  • Reporting to regulatory authorities
  • Legal proceedings

18. Withdrawal Conditions

Withdrawals are only processed after:

  • Full verification completion
  • Use of same payment method as deposits
  • Fulfillment of wagering or promotional conditions
  • Adherence to fair use and traceability standards

Withdrawals to third parties are strictly prohibited.

19. Player Obligations

Players are expected to:

  • Provide accurate, updated information
  • Use only personal identity and financial accounts
  • Cooperate with verification processes
  • Maintain a single active account
  • Avoid abuse of promotions or financial systems

Violations may lead to corrective actions or account closure.

20. Transparency & Communication

We notify users when verification is required and provide full guidance and assistance through our support team.

21. Data Security

All personal data is:

  • Encrypted and securely stored
  • Accessed only by authorized staff
  • Managed under strict incident response protocols

22. Regulatory Cooperation

We fully cooperate with:

  • Curaçao’s FIU
  • Gaming and legal authorities

When legally required, we may disclose:

  • Identity documents
  • Transaction history
  • Compliance audits and findings

23. Compliance Officer

A dedicated Compliance Officer oversees:

  • KYC/AML enforcement
  • Internal reporting and audits
  • FIU coordination
  • Team training and risk assessments

This role functions independently and reports directly to senior management.

24. Contact Us

For KYC or compliance-related queries, please reach out to:
📧 [email protected]

All communications are treated confidentially and in accordance with data protection legislation.