This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of betoranje, operated at casino-betsoranje.nl by JACO V.I.P. LIMITADA, Costa Rica ("betoranje", "we", "us", "our"), to detect, prevent and report financial crime, and explains the identity-verification and due-diligence procedures that apply to every customer who registers and transacts on the platform.

1. Purpose and Scope

betoranje is committed to operating a safe, transparent and legally compliant gaming environment. This Policy applies to all customers of casino-betsoranje.nl, all transactions processed through the platform — whether in fiat currencies (EUR, CAD, NOK, PLN, AUD and others) or in cryptocurrencies (BTC, USDT and others) — and all members of staff and third-party agents who act on our behalf.

The objectives of this Policy are to:

• prevent casino-betsoranje.nl from being used, intentionally or unintentionally, as a vehicle for money laundering, terrorist financing or other financial crime;
• establish clear customer identification and verification ("KYC") procedures;
• define a risk-based approach to customer due diligence ("CDD") and enhanced due diligence ("EDD");
• set out transaction-monitoring standards consistent with the payment limits documented in the cashier;
• ensure that suspicious activity is identified and reported promptly to the appropriate authorities;
• meet the operator-governed compliance standards under which JACO V.I.P. LIMITADA operates.

2. Definitions

• AML — Anti-Money Laundering: a set of laws, regulations and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income.
• KYC — Know Your Customer: the process by which betoranje verifies the identity of its customers before and during the business relationship.
• Money Laundering — the process of concealing the origins of money obtained through criminal activity so that it appears to come from a legitimate source.
• Terrorist Financing — providing or collecting funds with the knowledge that they will be used, in full or in part, to carry out terrorist acts.
• CDD — Customer Due Diligence: the baseline measures applied to verify a customer's identity and assess the associated risk.
• EDD — Enhanced Due Diligence: additional measures applied where a higher risk of money laundering or terrorist financing has been identified.
• PEP — Politically Exposed Person: an individual who is or has been entrusted with a prominent public function.
• SAR — Suspicious Activity Report: an internal or external report filed when a transaction or pattern of behaviour raises suspicion of financial crime.
• MLRO — Money Laundering Reporting Officer: the designated individual responsible for receiving internal SARs and determining whether they must be disclosed to external authorities.

3. Regulatory Framework

betoranje, operated at casino-betsoranje.nl by JACO V.I.P. LIMITADA, Costa Rica, conducts its operations under operator-governed terms. Although a publicly specified gaming licence is not separately listed, betoranje acknowledges its responsibility to apply standards consistent with internationally recognised AML and counter-terrorist-financing ("CTF") principles, including those established by the Financial Action Task Force (FATF) and applicable data-protection legislation. We reserve the right to update this Policy at any time to reflect changes in applicable law, best practice or our own risk assessment.

4. Risk-Based Approach

betoranje applies a risk-based approach ("RBA") to AML and KYC compliance. This means that the depth and frequency of due-diligence measures are proportionate to the assessed risk posed by each customer, product, payment method, currency and geographic profile. Factors that influence our risk assessment include, but are not limited to:

• the customer's country of residence and nationality;
• the payment methods used — including cryptocurrency deposits and withdrawals in BTC and USDT, which carry specific enhanced-monitoring obligations;
• the volume, frequency and size of transactions relative to the documented deposit and withdrawal limits;
• the customer's VIP tier and associated transaction entitlements (e.g. unlimited daily withdrawals at Legend VIP level);
• whether the customer is a PEP or is associated with a sanctioned jurisdiction;
• inconsistencies between a customer's stated source of funds and their transaction behaviour.

Customers are assigned an initial risk rating (Low, Medium, or High) at the point of registration. This rating is reviewed periodically and may be updated at any time in response to new information or changes in transaction behaviour.

5. Customer Due Diligence (CDD)

5.1 When CDD is Triggered

Standard CDD is triggered at the following points:

• upon registration of an account on casino-betsoranje.nl;
• before the first withdrawal of funds;
• when cumulative deposits or withdrawals reach internal thresholds set by our compliance team;
• when the customer's risk profile changes materially;
• when we have reasonable grounds to suspect money laundering or terrorist financing, regardless of transaction size;
• when there is doubt about the veracity or adequacy of previously obtained identification data.

5.2 Identity Verification — Required Documents

To complete standard CDD, customers must provide clear, valid and unaltered copies of the following:

• Proof of Identity (POI): a government-issued photo ID such as a passport, national identity card, or driving licence. The document must show the customer's full legal name, date of birth, photograph and expiry date.
• Proof of Address (POA): a utility bill, bank statement, tax notice or official government correspondence issued within the last three months, showing the customer's full name and residential address.
• Proof of Payment Method: confirmation that the payment method used belongs to the customer — for example, a screenshot of the e-wallet account, a bank statement, or a photo of a card showing the last four digits and the cardholder's name. We accept Visa, Mastercard, Visa Electron, Maestro, Apple Pay, Skrill, Neteller, bank transfer, Bitcoin and USDT.

Documents may be submitted via the secure upload function within the customer account portal on casino-betsoranje.nl. All submitted documents are encrypted and stored in accordance with applicable data-protection principles.

5.3 Age Verification

betoranje strictly prohibits gambling by persons under the age of 18. Age verification is a mandatory component of the KYC process. Where automated checks are inconclusive, manual document review will be carried out. Accounts will be suspended pending age verification, and any funds deposited by a minor will be returned without payment of winnings or bonuses.

5.4 Verification Timescales

We endeavour to complete standard document review within 96 hours of submission, consistent with our standard payout-processing window. Where documents are incomplete or require further investigation, the customer will be notified promptly and given a reasonable opportunity to provide supplementary information. Withdrawal requests — subject to a minimum of €40 and processed within up to 96 hours (faster from Silver VIP tier) — will not be released until verification is complete.

6. Enhanced Due Diligence (EDD)

EDD is applied to customers who present a higher risk of money laundering or terrorist financing. EDD measures are mandatory in the following circumstances:

• the customer is identified as a PEP, or is a family member or close associate of a PEP;
• the customer is resident in, or transacts from, a high-risk or non-cooperative jurisdiction as identified by FATF;
• the customer uses cryptocurrency (BTC or USDT) as a primary deposit or withdrawal method, particularly at the elevated limits applicable to crypto transactions (up to €75,000 per day and €250,000 per month);
• the customer holds or is progressing towards a Legend VIP status, which carries entitlement to unlimited daily withdrawals;
• transaction volumes are inconsistent with the customer's stated occupation, income or source of funds;
• the customer triggers an internal SAR or is flagged by automated monitoring systems.

EDD measures may include, but are not limited to:

• collection and verification of source-of-funds ("SOF") and source-of-wealth ("SOW") documentation (e.g. payslips, tax returns, bank statements, company accounts, inheritance documentation);
• senior management approval before establishing or continuing a business relationship;
• increased frequency of ongoing monitoring;
• independent verification of identity using third-party data sources;
• blockchain analytics for cryptocurrency transactions, including wallet screening and transaction-tracing;
• written explanations from the customer of the purpose and intended nature of the business relationship.

7. Politically Exposed Persons (PEPs) and Sanctions Screening

betoranje screens all customers against recognised PEP databases and international sanctions lists — including those maintained by the UN Security Council, OFAC, the EU and other relevant bodies — at the point of registration and on an ongoing basis. Where a customer is identified as a PEP or as appearing on a sanctions list:

• the account will be placed under immediate review;
• EDD procedures will be applied in full;
• senior management sign-off is required before any transaction is processed;
• where the customer appears on a sanctions list, the account will be suspended and the matter referred to the MLRO for assessment and, where required, external reporting.

8. Transaction Monitoring

betoranje operates a continuous transaction-monitoring programme to identify patterns of activity that may indicate money laundering, terrorist financing or other financial crime. The monitoring programme takes into account the full range of payment methods and currencies accepted on the platform, as well as the published deposit and withdrawal limits, which are as follows:

Automated alerts are generated when transactions deviate materially from a customer's established profile, when structuring behaviour is detected (e.g. multiple deposits just below reporting thresholds), or when rapid cycling of funds between deposit and withdrawal is observed without meaningful gambling activity. All alerts are reviewed by the compliance team and escalated to the MLRO where appropriate.

Specific indicators that will prompt enhanced scrutiny include:

• repeated deposits at or near the maximum per-transaction or daily limit without corresponding play;
• large or frequent cryptocurrency transactions — particularly given the elevated limits of €75,000 per day — without adequate SOF documentation;
• use of multiple payment methods by the same customer without a clear rationale;
• requests for withdrawals shortly after deposits, with little or no gambling activity in between;
• third-party payment patterns, where the originating account or wallet does not appear to belong to the registered customer;
• inconsistent or implausible explanations of the source of funds used to take advantage of high-value bonuses, including the welcome pack (up to €11,500 plus 400 free spins) or the Sports Welcome Pack (up to €25,900).

9. Prohibition on Third-Party Payments

betoranje strictly prohibits deposits or withdrawals made on behalf of third parties. All funds deposited must originate from a payment account held in the customer's own name, and all withdrawals must be returned to the same account or method from which the original deposit was made, wherever technically possible. Where a mismatch is identified between the registered customer and the payment-method holder, the account will be suspended pending further investigation.

10. Cryptocurrency-Specific Obligations

betoranje accepts Bitcoin (BTC) and USDT as both deposit and withdrawal currencies and offers a dedicated crypto welcome bonus of 200% up to 3,000 USDT. Given the specific risks associated with virtual assets — including pseudonymity, cross-border transfer speed and the potential for mixing — the following additional measures apply to all cryptocurrency transactions:

• wallet addresses provided by customers are screened against known high-risk or blacklisted addresses using blockchain-analytics tools;
• customers whose crypto transactions originate from, or are destined for, mixing services, privacy coins or darknet-associated wallets will be subject to immediate account review;
• SOF and SOW documentation is required at lower thresholds for crypto users than for fiat-only customers;
• the Travel Rule — requiring the sharing of originator and beneficiary information for qualifying transfers — is applied in accordance with FATF guidance and to the extent required by applicable operator standards;
• large single crypto withdrawals (approaching the €75,000 daily limit) will not be processed until EDD is satisfactorily completed.

11. Suspicious Activity Reporting

All employees and agents of betoranje who identify suspicious activity in the course of their duties are required to file an internal Suspicious Activity Report with the MLRO without delay and without tipping off the customer concerned. The MLRO will assess each internal SAR within a reasonable timeframe and determine whether an external report to the relevant financial intelligence unit ("FIU") or competent authority is required under applicable law.

betoranje maintains a zero-tolerance approach to tipping off: no employee, contractor or agent may disclose to a customer or any third party that an SAR has been filed or that a suspicious-activity investigation is under way. Any breach of this obligation may result in immediate termination of employment or engagement and may itself constitute a criminal offence.

12. Record Keeping

betoranje retains all KYC documentation, transaction records and related compliance correspondence for a minimum of five (5) years from the date on which the business relationship ends, or from the date of the individual transaction where no ongoing relationship exists. Records are stored securely and may be made available to competent authorities upon lawful request. Customers have rights regarding their personal data in accordance with our Privacy Policy, available on casino-betsoranje.nl.

13. Staff Training and Awareness

All staff members with customer-facing, payment-processing or compliance responsibilities receive regular AML/KYC training. Training covers the recognition of suspicious behaviour, the correct escalation procedures, the requirements of this Policy, and any changes in applicable law or regulatory guidance. Training records are maintained and reviewed by senior management on an ongoing basis.

14. The Money Laundering Reporting Officer (MLRO)

betoranje has appointed a designated MLRO who is responsible for:

• receiving and assessing all internal SARs from staff;
• determining whether external disclosure to the competent authority is required;
• maintaining and updating this Policy;
• overseeing the day-to-day operation of the AML/KYC programme;
• providing regular AML compliance reports to senior management.

Customers and staff may contact the compliance function via the support channels available on casino-betsoranje.nl: 24/7 live chat or email, with assistance available in both English and Dutch.

15. Account Suspension, Restriction and Closure

betoranje reserves the right to suspend, restrict or permanently close any customer account where:

• the customer fails to provide required KYC documentation within a reasonable timeframe;
• documents submitted are found to be false, altered or otherwise fraudulent;
• the customer is identified as a sanctioned individual or entity;
• transaction patterns give reasonable grounds to suspect money laundering or terrorist financing;
• the customer refuses to provide SOF or SOW information when requested;
• the account is found to have been used in breach of this Policy or any other term of service published on casino-betsoranje.nl.

Where an account is suspended pending investigation, pending withdrawals may be held until the investigation is complete. betoranje will not be liable for any loss arising from the lawful exercise of these powers.

16. Responsible Gambling and AML Interaction

betoranje recognises that problem gambling and financial crime can share common indicators, such as unexplained large deposits, erratic betting patterns or sudden escalation in stakes. Our responsible gambling tools — including deposit limits, session limits, self-exclusion and reality-check features available on casino-betsoranje.nl — work in conjunction with our AML monitoring to identify customers who may be at risk, both financially and in terms of compliance exposure. Where a customer presents indicators of both problem gambling and potential financial crime, both the responsible-gambling team and the MLRO will be notified, and appropriate action will be taken under the relevant policies.

17. Bonus Abuse and Financial Crime

The misuse of promotional offers — including the five-deposit welcome pack (up to €11,500 and 400 free spins), the crypto bonus (200% up to 3,000 USDT), daily cashback (up to 45%), instant rakeback (up to 25%) and the Sports Welcome Pack (up to €25,900) — to launder funds constitutes a serious breach of this Policy. betoranje monitors bonus-related transactions with particular care. Where the pattern of deposits and withdrawals in connection with bonus activity is inconsistent with genuine gambling activity, the account will be flagged for compliance review, bonuses will be voided, and the matter may be reported to the relevant authority.

18. Policy Review

This Policy is reviewed at least annually or whenever there is a material change in applicable law, regulatory guidance or the risk profile of betoranje's operations. The most current version is always published on casino-betsoranje.nl. Continued use of the platform following publication of an updated Policy constitutes acceptance of the revised terms.

19. Contact

If you have any questions about this AML / KYC Policy, please contact betoranje via:

• Live chat: available 24/7 at casino-betsoranje.nl
• Email: via the support address listed in the Help section of casino-betsoranje.nl
• Languages: English and Dutch

betoranje is committed to maintaining the integrity of its platform and protecting all customers from the harms associated with financial crime. We thank our customers for their cooperation with our verification and monitoring procedures.