Anti-money laundering policy
Ludaro Limited AML and counter-financing of terrorism framework, aligned with EU AML Directives and MGA requirements.
1. Policy overview
Ludaro Limited maintains an anti-money laundering (AML) and counter-financing of terrorism (CFT) programme designed to detect, prevent, and report suspicious activity. Ludaro Limited's programme is compliant with the EU Fourth and Fifth AML Directives, Malta's Prevention of Money Laundering Act, and Malta Gaming Authority AML guidelines.
2. Customer due diligence (CDD)
Standard CDD applies to all customers at registration (Tier 1) and before withdrawal (Tier 2). CDD measures include: identity verification, date of birth verification, and verification of the payment method used. Documents are verified through Onfido, the certified KYC partner.
3. Enhanced due diligence (EDD)
EDD is triggered when any of the following conditions are met:
- Cumulative deposits exceed €2,000 since account opening
- A single transaction exceeds €1,000
- The customer is identified as a Politically Exposed Person (PEP)
- The customer is from a high-risk jurisdiction as defined by the FATF
- Unusual transaction patterns are detected by the operator's monitoring system
EDD measures include source-of-funds documentation, enhanced monitoring of subsequent transactions, and in some cases a direct conversation with the customer to understand the origin of funds.
4. Source-of-funds triggers
Source-of-funds documentation is requested when cumulative deposits exceed €2,000. Accepted documentation: bank statements (three months), payslips (two months), accountant certification for business income, or a signed declaration for inheritance or property proceeds. Failure to provide documentation within seven days results in account suspension and withdrawal restriction until documentation is received and assessed.
5. Sanctions and PEP screening
All customers are screened against EU, OFAC, and UN sanctions lists at registration and on an ongoing basis. Customers identified as Politically Exposed Persons are subject to EDD automatically, regardless of deposit levels. Screening is conducted through the operator's compliance technology partner and is updated in real time against sanctions list changes.
6. Transaction monitoring
The operator's transaction monitoring system runs automated rules covering:
- Rapid deposit-and-withdrawal patterns with minimal play
- Multiple deposits from different payment methods in a short period
- Transactions inconsistent with stated financial profile
- High-frequency low-bet play designed to generate withdrawal eligibility with minimal risk
Alerts generated by the monitoring system are reviewed by the operator's compliance team within 24 hours. Where a pattern cannot be explained, the MLRO is notified for formal assessment.
7. MLRO and reporting
Ludaro Limited has a designated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for assessing suspicious activity reports (SARs) generated internally and for filing reports with the Financial Intelligence Analysis Unit (FIAU) of Malta when required. The MLRO role cannot be delegated beneath senior management level.
8. Record retention
All CDD documents, transaction records, and SAR filings are retained for a minimum of five years from the date of the last transaction or account closure, whichever is later. Records are stored in encrypted form with access restricted to compliance and senior management staff.
9. Training
All customer-facing and compliance staff complete AML training at induction and annually thereafter. Training covers recognition of suspicious patterns, escalation procedures, and legal obligations under the Prevention of Money Laundering Act. Training completion is logged and auditable.
AML FAQs
Why has my account been suspended for verification?
Account suspension for verification is triggered when the operator's monitoring system flags unusual activity or when EDD thresholds are met. Upload the requested documents in the Verification area; the review takes up to 24 hours.
What documents satisfy source-of-funds requirements?
Bank statements (three months), recent payslips (two months), an accountant letter for business income, or a signed declaration for inheritance, property sale proceeds, or similar. Contact support if you are unsure which applies to your situation.
Are my financial documents stored securely?
Yes. All documents are encrypted at rest and in transit. Access is restricted to compliance staff only. Documents are retained for five years per AML regulations and then securely deleted.
What is a PEP check?
A Politically Exposed Person (PEP) check identifies individuals who hold or have recently held prominent public positions. PEP status triggers enhanced due diligence regardless of deposit amounts. This is a legal requirement under EU AML Directives.
10. Risk-based approach
Ludaro Limited's AML programme is built on a risk-based approach as required by the EU AML Directives. This means Ludaro Limited allocates compliance resources proportionately to the level of risk presented by each customer and transaction. Lower-risk customers undergo standard CDD. Higher-risk customers, including PEPs, high-deposit customers, and customers from high-risk jurisdictions, undergo EDD with additional monitoring.
Risk factors that elevate a customer's risk rating include:
- Country of residence listed on FATF's high-risk or monitored jurisdictions list
- Profession or public role indicating PEP status
- Payment method associated with elevated anonymity (e.g., certain prepaid instruments)
- Transaction patterns inconsistent with stated financial profile
- Prior flagging by the operator's automated monitoring system
Risk ratings are reviewed at least annually and updated in response to triggering events such as a change in transaction behaviour, a change in the customer's stated profession, or a change to national risk assessments. Customers are not informed of their individual risk rating.
11. Correspondent relationships and third-party reliance
Where Slotspice relies on third-party CDD (such as the identity verification conducted by Onfido), Slotspice satisfies itself that the third party is subject to equivalent AML regulations and supervision. Slotspice retains ultimate responsibility for the CDD outcome; reliance on a third party does not transfer regulatory liability.
Slotspice's payment processor relationships are reviewed annually to confirm that each processor maintains AML controls consistent with Slotspice's own standards. Processors that cannot demonstrate adequate controls are removed from the payment menu.
12. Annual AML review
The AML policy is reviewed annually by the MLRO and approved by senior management. The review considers: regulatory updates, changes to the MGA's AML guidelines, findings from internal audits, FIAU guidance notices, and any SAR patterns identified during the year. Material changes to the policy are communicated to all relevant staff within 30 days of approval.
Step-by-step customer due diligence
The following describes the standard CDD procedure applied to all new Slotspice accounts. This procedure is mandatory and cannot be bypassed or shortened for any customer regardless of deposit size or account status.
Step one at registration: the customer provides their full name, date of birth, residential address, email address, and phone number. This data is recorded and stored securely. The customer also confirms they are over 18 and resident in an eligible jurisdiction.
Step two before the first withdrawal: the customer uploads a government-issued identity document (passport, national ID card, or driving licence) and a selfie holding the same document. The submission is automatically forwarded to Onfido for machine-assisted verification followed by human review if the automated check flags any anomaly. Review time is up to four hours on business days.
Step three when EDD is triggered: the customer is contacted by email with a request for source-of-funds documentation. The email explains exactly which documents are required and why. The customer has seven days to respond. If no response is received, the account is suspended and withdrawal capability is restricted until documentation is provided and reviewed.
All CDD records are stored in a secure, access-restricted document management system. Documents are not shared with third parties except where required by law, such as in response to a formal request from the FIAU or another competent authority.
Operator obligations and your rights around AML records
Slotspice is required under Maltese AML legislation to retain records related to customer due diligence, transactions, and suspicious activity reports for a minimum of five years following the end of the business relationship or the date of the transaction, whichever is later.
Records retained include CDD documents such as identity and address verification; transaction records including all deposits and withdrawals with dates, amounts, and payment methods; correspondence related to enhanced due diligence requests; and SAR documentation where applicable.
These records are stored in a secure, access-controlled system. Access is limited to compliance personnel, the MLRO, and senior management. Records are not accessible to customer-facing staff except where required to complete a specific compliance task under supervision.
You have a right under GDPR to access most of your personal data, subject to exemptions that apply where disclosure would prejudice AML investigations or law enforcement. Requests to access AML-specific records are assessed individually by the Data Protection Officer and the MLRO jointly. If access to specific records is denied, you will be notified of the legal basis for the refusal.