Last updated: 17 October 2026
Spinatoshi (www.spinatoshi.com) is operated by Spin Reels S.R.L, registration number 455754, with its registered address at San José, Costa Rica. Spin Reels S.R.L is licensed and regulated under licence CRG / 117 / 15.10.2026 – 15.10.2027, issued in Costa Rica (the “Company”, “we”, “us”).
The Company is committed to preventing money laundering, terrorist financing, fraud and any other financial crime. To comply with applicable laws, regulations and international standards, the Company has established procedures which it follows when providing services to Account Holders. These procedures cover:
Customer Due Diligence Know Your Customer (KYC) Due Diligence (Standard and Enhanced) The Money Laundering Reporting Officer (MLRO) Risk Management and Risk Classification Monitoring of Account Holder Activities Reporting of Unusual Transactions Record Keeping Employee Due Diligence
For any question about this policy, contact us at support@spinatoshi.com.
- Risk Management
1.1 Risk-Based Approach
The Company takes a risk-based approach to its customers in order to detect and deter risks such as money laundering, terrorist financing and other prohibited activity, including fraud.
1.2 Risk Classification
Account Holders are classified as:
Low Risk High Risk
Low Risk. All players are classified as Low Risk at registration. They are subject to standard due diligence, the KYC procedures described in this policy, and ongoing monitoring of account activity.
High Risk. A player is classified as High Risk based on their profile and activity, and becomes subject to Enhanced Due Diligence. A High Risk classification is assigned, among other cases, when:
an automated alert is generated or inappropriate activity is detected on the account; the player is a citizen or resident of a high-risk or non-reputable jurisdiction; the player is, or is suspected to be, a Politically Exposed Person (PEP); the player matches, or possibly matches, a sanctions list; the player is suspected of holding multiple accounts or of colluding with other players; the player’s transactions are unusually large or complex, or inconsistent with their profile.
- Customer Due Diligence and Know Your Customer (KYC)
2.1 Identification and Verification
Knowing our customers is essential to protecting the safety of the Company and of the financial system. An individual may not play for real money unless they have registered and been given a Player Account. Only one Player Account is allowed per person, per family and per shared environment.
To register, an individual must personally provide:
Date of birth, together with valid identification showing that they are over eighteen (18) years of age, or the legal age of majority in their jurisdiction of residence, whichever is higher; First and last name; Full residential address; A valid email address; Payment information; and A username and password.
On registration, a geolocation check is performed on the applicant’s IP address to confirm that the applicant is in a permitted jurisdiction. Applicants from restricted jurisdictions cannot complete registration.
The Company verifies the information provided and may request additional documents. A Player Account may be placed on hold until satisfactory information is received, or closed if the Company determines that the information provided is false or misleading. The Company reserves the right to refuse to open, or to close, any Player Account at its sole discretion after reviewing the KYC information.
2.2 Login Details
Players must not share their login details with any third party. The Company may close an account without refund if login details have been disclosed to a third party.
- Due Diligence
Players who deposit and withdraw only in cryptocurrency are not required to complete verification at registration or for withdrawals, unless one of the cases listed below applies. Standard Due Diligence is carried out:
when cumulative withdrawals reach €2,000 or the equivalent in cryptocurrency, or a single withdrawal is unusually large compared to the player’s activity; when a fiat payment method is used; whenever a risk indicator, AML alert, security concern or suspicion of underage play arises; when requested by the licensing authority or any competent authority; at any other time at the Company’s discretion where there is a justified reason.
3.2 Enhanced Due Diligence (EDD)
When a player is classified as High Risk, the Company applies Enhanced Due Diligence and may request:
a valid passport or driving licence; a selfie of the player holding the identification document; a recent utility bill or bank statement; a bank statement or payment record showing the initial deposit; a bank statement not older than three months from the account to which a withdrawal is to be made; information and evidence on the source of funds and, where appropriate, the source of wealth.
Enhanced Due Diligence is applied in particular:
a) if the player is a citizen of a high-risk country, or the geolocation check indicates residence in a non-reputable or high-risk jurisdiction; b) if the player is suspected of trying to create, or having created, several accounts under different names; c) if the player is suspected of being part of a syndicate colluding to gain an advantage over the Company; d) if the player is, or is suspected to be, a Politically Exposed Person (PEP), or a family member or close associate of a PEP; e) on the discovery of any irregular, suspicious, improper or fraudulent activity; f) at any time at the Company’s sole discretion.
If the Company cannot verify the player’s identity, it may place the account on hold until the information is provided, or close it if the information is found to be false or misleading.
3.3 Sanctions and PEP Screening
All Account Holders are screened at registration, during verification and on an ongoing basis against international sanctions lists (including those published by the United Nations, the European Union, the United Kingdom and the United States OFAC). Possible matches are reviewed by the MLRO. Confirmed matches result in the account being blocked and the case being reported to the competent authority.
- The Money Laundering Reporting Officer (MLRO)
The Company has appointed an MLRO who is responsible for reviewing KYC information and monitoring account activity. In particular, the MLRO:
ensures that staff properly review Player Accounts for the identification and verification of Account Holders; maintains a register of Account Holders; oversees the review and investigation of account activity by designated staff; provides initial and ongoing training so that all relevant staff understand their responsibilities for player identification, activity monitoring, record keeping and reporting of unusual or suspicious transactions; cooperates with all competent administrative, law enforcement and judicial authorities in preventing and detecting crime; ensures that this policy is followed, reviewed and kept up to date.
- Monitoring of Account Holder Activities
Designated staff review and monitor Player Accounts and investigate any irregular activity. Security systems generate automated alerts, which are investigated by the compliance team. Any irregular, suspicious, inappropriate or fraudulent activity, or any attempt at it, results in the player being classified as High Risk and subject to Enhanced Due Diligence.
Accounts are monitored for, among others:
KYC information that is fake, false, incorrect, misleading, non-existent, does not belong to the player or cannot be verified; fictitious names that hide the true beneficial owner; inappropriate gaming or fraudulent activity; irregular play, including zero-risk or opposite (hedged) bets; complex or large transactions, or groups of transactions, which by their nature may be related to money laundering or terrorist financing; attempts to create, or the existence of, multiple accounts under different names; suspected collusion or syndicate play; any fraudulent or unlawful use of the system, including attempts to hack into or circumvent its security measures; the use of automated software, bots or artificial-intelligence tools to play; logins or attempted logins from restricted or high-risk jurisdictions, or through VPNs or proxies used to hide the player’s location. 5.1 Multiple Accounts
Only one Player Account is allowed per person, family or shared environment. If more than one account is created per person, household, building, postal address, phone number, IP address, family, device or shared environment, all related accounts will be closed and no winnings, refunds or deposits will be paid. “Family” includes, but is not limited to, parents, partners, spouses, children, siblings and close relatives.
Where multiple accounts under different names or syndicate play are suspected, all related accounts will be suspended pending investigation. The investigation includes a review of game history, IP and location history (including VPN and proxy databases), device data and other technical indicators. If the Company determines that an Account Holder, or a group of Account Holders, has created multiple accounts or played as part of a syndicate, it will withhold any cash or bonus winnings and reserves the right to withhold deposited funds.
Whenever a withdrawal is requested, the system checks for multiple accounts and for the use of proxies or VPNs. If multiple accounts are found, all of them will be closed and the Account Holder will not be allowed to open a new account.
5.2 Unusual Activity
If an Account Holder’s deposits are flagged as unusual, the Company will investigate and may request further information. The account may be suspended until satisfactory documents are provided. If they are not provided within 30 days, the account will be closed. The MLRO will report the unusual transaction to the competent authority where required.
5.3 Withdrawals
Withdrawal requests. Withdrawals can only be requested from the Player Account. Requests made by any other means will not be processed. Before processing a withdrawal, the Company may request KYC documents to verify the player’s identity.
Funds are returned, wherever possible, to the same payment method and source used for the deposit. If this is not possible, the Company will request additional documents proving the details and ownership of the new withdrawal method. Withdrawals are paid only to the Account Holder. Payments to third parties are not permitted.
Review before payment. Before any withdrawal, the Company reviews the account for irregular activity, such as:
deposits without wagering, or deposits made only to receive free spins or bonuses. A player must wager at least the amount of each deposit once before withdrawing; multiple accounts under different names; collusion between players.
If any of the above is found, the Company may withhold the funds and request Enhanced Due Diligence documents, or investigate further and decide to:
suspend the account until sufficient verification is received; immediately block the player’s access to the system or to the account and withhold the funds held in it; close the account and withhold the funds held in it, and report the activity to the competent authorities as described below.
- Cryptocurrency Transactions
Spinatoshi accepts deposits and withdrawals in selected cryptocurrencies through a third-party payment provider. The following rules apply:
Account currency. Player Accounts are held in euro (EUR). Cryptocurrency deposits are converted to EUR at the rate shown before the deposit is confirmed, and withdrawals in cryptocurrency are converted from EUR at the rate applicable when the withdrawal is sent. The rate and any network fee are shown to the player before confirmation. Same method. Withdrawals in cryptocurrency are, wherever possible, made in the same cryptocurrency and network used for the deposit, to a wallet controlled by the Account Holder. Verification. The identity, address and age (over 18) of players using cryptocurrency are verified as described in the Customer Due Diligence section. Technical data. The Company collects and stores device and connection data (such as IP address and browser and device information) at registration, login, deposit and withdrawal, to make sure that deposits, wagers and withdrawals belong to the same player. Segregation and solvency. Player funds are held separately, and the Company provides proof of player balances and of solvency to the licensing authority on request. Volatility. The value of cryptocurrencies can change significantly depending on the market. Players are reminded of this in the Terms and Conditions.
Because of anti-money laundering rules, players may only deposit funds in order to play. Accounts used to deposit and withdraw without genuine play will be frozen pending investigation. The Company is not a financial institution and does not pay interest on balances. The Company may restrict certain payment methods in selected countries or for certain players. New payment methods are announced on the website and by email, and this policy and the Terms and Conditions are updated accordingly.
- Security Review
The Company may at any time verify the identity, age and registration details provided by the Account Holder, and check their use of the services for any breach of the Terms and Conditions or of applicable law. By registering, the applicant authorises the Company to make any relevant enquiries and to use and disclose information to third parties as needed for these checks. Third parties may be used to verify age, identity, address and payment information and to check the information against public or private databases. By accepting the Terms and Conditions, Account Holders consent to the use, recording and disclosure of the information provided, which may be recorded by the Company or by third parties acting on its behalf.
Audits may be carried out from time to time at the Company’s discretion or for regulatory, security or other business reasons. During a review, the Account Holder may be restricted from withdrawing funds or from accessing certain services.
- Reporting of Unusual Transactions
Where the Company has not received sufficient verification, or knows, suspects or has reason to suspect that a transaction:
(i) involves funds derived from illegal activities, (ii) is intended to conceal funds derived from illegal activities, or (iii) involves the use of the Company’s system to facilitate criminal activity,
the transaction will be reported to the Financial Intelligence Unit of Costa Rica (Unidad de Inteligencia Financiera, Instituto Costarricense sobre Drogas) and/or any other competent authority. The MLRO is responsible for reporting and keeps a record of every case where it was decided that a report was not necessary, together with the justification for that decision.
- Record Keeping
The Company keeps records of all relevant documents in a secure, separate system for at least five (5) years after the end of the business relationship. Records are kept in a way that allows the competent authorities to reconstruct a full audit trail of each transaction, including amounts, currencies and the nature of the transaction. Where required by law and permitted by the competent authorities, the Company may provide copies of these records.
- Employee Due Diligence
The Company’s employees must be of unquestionable integrity. All applicants must submit a curriculum vitae, at least two references and relevant educational or professional certificates, which are reviewed and verified before employment. Employees receive AML training when they join and at regular intervals afterwards.
- Contact
For any question about this AML Policy, please contact us at support@spinatoshi.com.
Spin Reels S.R.L · Registration number 455754 · San José, Costa Rica · Licence CRG / 117 / 15.10.2026 – 15.10.2027