Stake Anti-Money Laundering Policy

According to the supplied material, Stake Casino is operated by Medium Rare N.V. The source states that the company was registered in 2017 and refers to a Curaçao gaming licence identified as document number 1668/JAZ.

The supplied policy presents these arrangements as part of the legal and operational framework under which the company provides its gambling services. Licensing requirements, market availability, and gambling rules can change between jurisdictions, so current official information should be checked separately.

The source states that compliance checks begin when a user creates an account. New customers may be subject to identity checks and ongoing review of account transactions to help identify suspicious financial activity.

The supplied material states that Stake provides gambling services rather than operating as a traditional financial institution. It nevertheless describes the company as applying anti-money laundering and counter-terrorist-financing controls within the regulatory framework relevant to its operating jurisdiction.

According to the policy, the platform prohibits use of its services for illegal financial activity, including handling stolen or counterfeit funds, financing terrorist organizations, or attempting to circumvent applicable sanctions.

Main Compliance Measures

• Employees receive training intended to help them recognize money-laundering risks and understand internal compliance procedures.
• A compliance officer is responsible for monitoring financial activity, investigating potentially suspicious transactions, and escalating relevant issues.
• Written AML procedures define the actions expected when potential compliance problems are identified.
• The supplied material also describes periodic independent review of AML controls and their effectiveness.

The supplied policy uses several terms to explain how unlawful financial activity may occur and how it may be detected.

The supplied material states that a Chief Compliance Officer oversees key parts of the AML programme.

• Preparing, approving, and implementing updates to the AML Policy.
• Communicating with external regulators or other relevant authorities when required.
• Investigating potentially suspicious user activity.
• Organizing staff training on money-laundering risks and compliance procedures.

The policy describes Know Your Customer as an identity and financial-profile verification process used to help detect activity that differs significantly from a customer's expected behaviour or financial circumstances.

According to the supplied information, KYC controls may help identify potentially suspicious activity connected with money laundering, terrorist financing, fraud, or other prohibited conduct.

Customer Due Diligence is described in the supplied material as a process for identifying the customer and evaluating the level of financial or compliance risk associated with their activity.

During registration or later verification, information may be requested such as the user's name, date of birth, physical address, citizenship, and identification documents.

The information may then be used to create a risk profile. According to the supplied policy, a higher risk assessment may lead to additional restrictions, enhanced review, or refusal of service.

CDD Process

In addition to monitoring activity after registration, the supplied policy describes restrictions intended to prevent access by users who may fall within prohibited or sanctioned categories.

• Access may be restricted when a user is detected in a prohibited jurisdiction.
• Users may be screened against sanctions restrictions associated with the United States, European Union, or other relevant jurisdictions.
• Registration may be unavailable for individuals located in countries from which the operator does not accept customers.

Enhanced Due Diligence is described as a more detailed level of verification used when a customer or transaction presents elevated risk indicators.

The process may involve closer examination of a user's identity, financial background, location, or source of funds before the account can continue to operate normally.

The supplied material states that third-party providers may be used where necessary to verify the accuracy of information submitted during enhanced checks.

The supplied policy presents account blocking or restriction as a precautionary measure that may be used when suspicious activity, verification problems, or jurisdictional concerns are identified.

The supplied material states that transactions may be analysed for patterns or indicators associated with suspicious or unlawful activity.

Monitoring can include reviewing payment size, frequency, previous account behaviour, unusual transaction patterns, and the jurisdictions connected with deposits or withdrawals.

Transaction Screening Tools

The supplied material specifically states that Chainalysis may be used when reviewing certain transactions. If a transaction or wallet is assessed as presenting elevated risk, additional verification or account restrictions may be applied.

The supplied policy describes additional measures intended to identify attempts to bypass standard compliance controls.

• Device-based tools may be used to identify connections between multiple accounts and help detect prohibited multi-account activity.
• Time-zone information may be compared with expected location information to identify possible inconsistencies involving restricted jurisdictions.
• Third-party suppliers, consultants, or compliance partners may themselves be reviewed to assess reliability and performance of contractual obligations.

According to the supplied policy, employees receive ongoing training intended to keep them informed about evolving money-laundering methods and changes in compliance requirements.

Training is described as covering how to identify potentially suspicious activity, how to respond when concerns are detected, and which internal or external channels should be used when escalation is required.

The supplied material states that suspicious activity identified through the platform may be investigated and reported when required under the applicable AML and counter-terrorist-financing framework.

Relevant concerns may be escalated through the company's compliance structure and, where required, communicated to appropriate external authorities or regulators.