AML Policy

Huzzlin Casino, operated by Ludaro Limited, is a subject person under the Maltese Prevention of Money Laundering Act and the Prevention of Money Laundering and Funding of Terrorism Regulations. We follow the FIAU Implementing Procedures Part II for the remote gaming sector.

All players complete identity verification before the first withdrawal. Enhanced due diligence applies to deposits above €2,000 within 30 days, deposits funded from high-risk jurisdictions, and to politically exposed persons (PEPs). Source-of-funds documentation may be requested at any stage.

Suspicious activity is reported to the FIAU. We cooperate with MGA, FIAU and law enforcement requests. Account freezes pursuant to AML obligations are notified to the player only where legally permitted.

Ludaro Limited operates Huzzlin Casino under a formal Anti-Money Laundering policy required by the MGA licence and the EU's Anti-Money Laundering Directives. The policy is designed to prevent the casino from being used as a vehicle for money laundering or terrorist financing. All staff with player-facing responsibilities receive AML training on a regular basis, and the compliance function performs periodic policy reviews to keep pace with regulatory guidance.

Transaction monitoring is automated and runs in real time. The system flags unusual patterns: rapid deposit-and-withdrawal cycles, deposits from multiple payment methods in short succession, transactions that appear to have no connection to gaming activity, and amounts near reporting thresholds. Flagged accounts are reviewed manually by the compliance team before any further action.

KYC operates in three tiers. Tier 1 covers basic identity: email verification and phone confirmation at registration. Tier 2 requires document-level identity verification (photo ID and proof of address) triggered before withdrawals above the platform's standard threshold. Tier 3 applies source-of-funds verification when cumulative deposits or withdrawal amounts reach levels that require enhanced due diligence under AML regulations. The specific trigger thresholds align with MGA guidance and may change as regulatory requirements evolve.

Sanctions screening is applied at registration and at ongoing intervals using commercially available sanctions databases. Players on international sanctions lists (UN, EU, OFAC, and others) are denied accounts or have existing accounts suspended. Enhanced due diligence applies automatically to politically exposed persons (PEPs) and their close associates.

If the compliance team determines that a transaction or account pattern constitutes reasonable grounds for suspicion of money laundering, a Suspicious Activity Report (SAR) is filed with the Financial Intelligence Analysis Unit (FIAU) in Malta. Players are not notified when a SAR is filed, as tipping off is prohibited by law. Accounts under investigation may have withdrawals suspended during the review period without an explanation being given to the account holder.

All KYC documents, transaction records, and compliance communications are retained for a minimum of five years after the end of the customer relationship, in compliance with MGA requirements and EU AML directives. Records are stored securely and access is restricted to authorised compliance and regulatory personnel. KYC queries can be directed to [email protected].

Politically exposed persons (PEPs) are individuals holding or having recently held prominent public positions: heads of state, senior ministers, senior executives of state-owned enterprises, members of parliament, senior military officers, senior judicial officers and central bank directors. Close family members and known associates of PEPs are also classified as PEP-related risks under FATF guidance. Huzzlin Casino screens all new customers against commercial PEP databases during registration. The databases used update daily and draw from authoritative government publications and parliamentary registers across all EU and EEA states. Being identified as a PEP does not automatically result in account rejection. Instead, PEPs and PEP-related persons are subject to enhanced due diligence (EDD): additional source-of-funds documentation, senior management sign-off for account approval, and enhanced ongoing monitoring of transactions. This is a legal requirement under the Fourth Anti-Money Laundering Directive as implemented in Malta law.

Huzzlin Casino operates an automated transaction monitoring system that flags unusual activity patterns for manual review by the compliance team. Deposits or withdrawals above €2,000 in a single transaction trigger an automatic enhanced review. Cumulative transactions exceeding €10,000 in a 30-day period trigger a periodic review of source of funds regardless of individual transaction size. Suspicious transaction patterns that trigger manual investigation include rapid deposit-and-withdrawal sequences with minimal gameplay, structuring (splitting transactions into smaller amounts just below the reporting threshold), and a sudden change in transaction frequency or size inconsistent with the player's established profile. Players who trigger these thresholds will be asked to provide source-of-funds documentation, which may include bank statements, payslips, tax returns or a letter from a financial advisor. The review is conducted confidentially and does not automatically affect the player's ability to continue playing unless evidence of a compliance concern is found.

All Huzzlin Casino customers are screened against three major sanctions regimes at registration and on an ongoing basis. The EU Consolidated List of persons, groups and entities subject to EU financial sanctions is maintained by the European External Action Service and updated continuously. OFAC (the US Treasury's Office of Foreign Assets Control) publishes the Specially Designated Nationals and Blocked Persons list, which Huzzlin screens against for transactions involving US-connected payment instruments and certain high-risk jurisdictions. The UN Security Council Consolidated List covers individuals and entities designated under UN sanctions resolutions, including arms embargo designees and terrorist-financing designees. Sanctions screening runs in real time at account creation and is repeated on a quarterly basis for existing accounts using the latest list versions. A match against any of these lists results in immediate account suspension and reporting to the relevant financial intelligence unit under the casino's Suspicious Activity Report obligations.

Huzzlin Casino applies three levels of customer due diligence based on assessed risk. Standard CDD applies to the majority of players and requires identity verification (government-issued ID) and proof of address (utility bill or bank statement dated within three months). Simplified due diligence may be applied where an individual's risk profile is demonstrably low, for example a player whose account activity is low-volume and who is a resident of a low-risk EU member state. In simplified CDD, the verification documents are still collected but the frequency and depth of ongoing monitoring may be reduced. Enhanced due diligence (EDD) applies to high-risk customers including PEPs, players from high-risk third countries under the FATF grey or black list, and accounts that trigger transaction monitoring flags. EDD requires source-of-funds documentation, senior management approval and more frequent transaction review. The level of CDD applied to an account can change over time as the player's risk profile evolves, and the casino reserves the right to request additional documentation at any point consistent with its AML obligations.

Huzzlin Casino's AML program is overseen by a designated Money Laundering Reporting Officer (MLRO) who holds direct responsibility for the casino's compliance with the Fourth Anti-Money Laundering Directive as implemented in Maltese law. The MLRO reports quarterly to senior management on the overall AML risk environment, the volume and outcome of enhanced due diligence cases, the number of Suspicious Activity Reports (SARs) filed with the Financial Intelligence Analysis Unit (FIAU) in Malta, and any thematic risk trends identified through transaction monitoring. The internal AML training program requires all customer-facing staff to complete annual AML training covering the recognition of suspicious activity patterns, the handling of PEP and sanctions matches, and the process for escalating concerns to the MLRO. Training completion is logged and forms part of the casino's periodic regulatory compliance attestation. Players who are subject to an AML investigation are not informed of the investigation, as tipping off is a criminal offense under anti-money laundering law. However, the outcome of a concluded investigation that does not result in a SAR is communicated to the player where appropriate and in line with legal obligations.