Last updated: July 28, 2026
AML Officer: Kateryna Veremiienko
3-102-951805 (DBA: DUELDUCK CR LIMITADA) is hereinafter referred to as “the Company.”
The Company adheres to strict codes of conduct in order to protect the Company’s good standing, instil trust with the customers, comply with regulatory requirements and fulfil its ethical responsibility. The Company warrants that it will:
The document may be amended from time to time to ensure that it remains harmonised with amendments to effective legislation and other material developments originating from changes in international standards, especially those emanating from the Anjouan Gaming, Anjouan Offshore Financial Authority, Anjouan Gaming Board or any other applicable governing authorities or regulations. All amendments and/or changes to the document must be approved by the Director of the Company.
This document defines the Fraud Control, Know Your Customer (KYC), Anti Money-Laundering (AML), Counter Terrorist Financing (CTF) and Pay-out Management procedures. The procedure defines:
This procedure applies to all the stages of the customer lifecycle. Different parts of the procedure apply at different stages:
The main sources of the policy are:
The AMLO is responsible for ensuring the KYC, AML and CTF procedures are followed; the prevention of fraud key function holder is responsible for ensuring the Fraud Control Procedures are followed, whilst the AFPD (Anti-Fraud and Payout Department) agents are responsible for the Pay-out Management Procedure, record-keeping, verification, Fraud management procedures and reporting suspicious, ML and TF activity. They are also responsible for ensuring the plan is kept up to date and that employees are aware of the procedure.
Where the AMLO position is not occupied for any reason, its duties will be temporarily performed by the Director or any outsource professionals engaged by the Company.
The Company has an appointed AMLO. Email: [email protected].
This procedure describes the customer registration, account activation, KYC verification, restricted-jurisdiction screening, and ongoing monitoring process applied by the Company.
The purpose of the procedure is to:
For the purposes of this procedure, the terms “customer,” “player,” and “user” refer to the person registering or holding an account with the Company.
Registration, email activation, and KYC approval are separate stages of the onboarding process. Successful email activation does not override KYC, sanctions, responsible gambling, or restricted-country controls. The Company may keep an account inactive or restricted until all mandatory checks have been completed satisfactorily.
Before a customer may play on the website or otherwise access the Services (games), the customer must register an account.
During registration, the customer must provide the following information:
The customer must also expressly declare that:
The information provided during registration must be complete, accurate, and consistent with the documents subsequently submitted by the customer.
A customer must not register an account using false, misleading, incomplete, or third-party information.
The Company reserves the right, at any time, to request any KYC documentation it reasonably deems necessary to verify the identity, location, and risk profile of a user.
The registration system must perform automated checks before an account is accepted.
Customers whose principal mandatory registration details are identical to the details of an existing account are not permitted to register another account. For the purposes of duplicate-account detection, white spaces must not be taken into consideration. This means that adding, removing, or changing spaces in otherwise identical information must not prevent the system from identifying a potential duplicate account.
Where the system identifies identical principal registration details, the new registration must be refused automatically or referred for internal review.
The system must not allow:
A potential duplicate account must be reviewed by the AFPD Department where further investigation is required.
The customer must declare during registration that they are at least 18 years old. This declaration does not replace documentary age verification. The customer’s age must subsequently be confirmed using the date of birth shown in the government-issued identity document.
Where the customer is under 18, appears to be under 18, or provides inconsistent age information, the account must not be approved.
Customers from restricted countries are not permitted to register or access the Services. The system must use available country and IP-location controls to prevent registrations from restricted territories. However, because a customer may attempt to conceal their actual location through a VPN, proxy, or similar technology, an automated IP check must not be treated as the only country-verification control.
The customer’s declared country, IP location, identity document, proof of residence, payment information, and other available indicators must be reviewed where necessary.
An email verification process must be completed following registration.
Immediately after registration, the customer’s account must remain temporarily inactive or otherwise restricted pending email verification. The Company must send a branded activation email to the email address provided by the customer. The activation email must contain a link or other mechanism allowing the customer to confirm that they control the registered email address.
The activation link is valid for a maximum of twenty-four hours.
Where the customer activates the account within the twenty-four-hour period, the email address is treated as verified.
Where the activation link expires, the customer must request another activation email by contacting Customer Support.
Email verification confirms control of the registered email address only. It does not, by itself, confirm the customer’s identity, age, residence, or eligibility to use the Services. Where the platform permits the customer to log in after email activation, access to gaming, deposits, withdrawals, transactions, or other Services may remain restricted until the required KYC checks are completed.
As part of the registration and verification process, the customer must submit the following documentation:
Where the identity document contains relevant information on both sides, the customer must provide copies of both the front and back of the document.
The customer must ensure that the submitted documents and images are sufficiently clear for verification. The relevant names, photographs, dates, document numbers, signatures, addresses, and other required details must be visible.
The identity document must contain the holder’s signature where the relevant document type normally includes a signature. The reviewer must confirm that the signature field is present and visible. Where the document type does not normally contain a signature, the absence of a signature should not automatically result in rejection, provided that the document otherwise satisfies the applicable verification requirements.
The identity document must be valid and must not expire within the following three months. For example, where the document is due to expire in two months, it does not meet the KYC requirements and a replacement document must be requested. The expiry date must be clearly visible and must be recorded or verified in the back-office system.
The Company may request additional documents during registration, before a withdrawal, after a change in account activity, or at any other time where required by applicable law, AML/CTF obligations, sanctions requirements, licensing conditions, or an internal risk assessment.
In addition the Company may verify proof of payment method - Payment Method verification is done through the Payment Method back-office for Low-Risk. Medium or High Risk customers are instead requested any of the following: Credit Card, eWallet screenshot, Voucher, Bank Statement. Document/screenshot of Payment Method is only requested after noticing that it is needed after a failed Payment Method check on the Payment Method’s back-office.
The full name shown on the identity document must match the customer’s name registered in the account.
The reviewer must compare the identity document with:
A material discrepancy in the customer’s name must be clarified before the account is approved.
Where the discrepancy cannot be reasonably explained or resolved, the KYC verification must remain pending or be rejected.
The date of birth shown on the identity document must confirm that the customer is at least 18 years old. The date of birth must also be compared with the date of birth provided during registration.
The account must not be approved where:
Social media checks may also be conducted where there is a suspicion of underage gambling.
The country associated with the identity document and the customer must not be a restricted or prohibited jurisdiction.
The reviewer must assess the country of issuance, the customer’s declared country of residence, and any other relevant geographical information.
The restricted jurisdictions include:
The most recent restricted-country list must always be used. A previously downloaded or locally stored list must not be relied upon where an updated version is available.
When a customer registers or logs in from a restricted country (as per our T&Cs) we block the customer manually and refund his deposit. Winnings are confiscated.
The reviewer must confirm that the visible photograph, document number, name, date of birth, country, signature, and expiry date are internally consistent and sufficiently clear. Where only one side of a two-sided document has been provided, the missing side must be requested before the verification is completed. Where the document details cannot be read, the customer must be asked to provide a clearer copy.
The customer must provide one of the following:
The document must display sufficient information to identify the customer and verify the customer’s residential location. The proof of residence must contain the customer’s full name. The proof of residence must have been issued within the previous three months.
The country shown on the proof of residence must not be a restricted or prohibited jurisdiction. The same restricted-country list used for identity-document verification must be applied to the proof of residence.
The customer must submit a selfie showing themselves holding the same identity document submitted as proof of identity.
The selfie is used to confirm that the person submitting the documents is the person shown in the identity document and that the customer has possession of the submitted document.
Where the document shown in the selfie differs from the document submitted separately, the verification must not be approved until the discrepancy is resolved.
Where the customer’s face, document photograph, or document number cannot be compared due to poor image quality, the customer must be asked to provide a new selfie.
The AFPD and Customer Support Departments must screen customer information for false, suspicious, inconsistent, or risk-relevant information.
The screening must include, where applicable:
Screening must be performed:
Where the customer’s account currency is not EUR, the Company must apply a threshold equivalent to EUR 2,000, unless the relevant authority expressly requires a different threshold.
The EUR 2,000 threshold should be assessed using the applicable internal currency-conversion methodology.
A review at one stage does not prevent the Company from conducting another review later. For example, a customer screened at registration may be screened again at the first withdrawal or when the deposit threshold is reached.
The customer may be approved where:
KYC verification must be considered unsuccessful where the customer fails to satisfy the applicable requirements or where a material issue cannot be resolved.
Reasons may include:
The Company adopts a risk-based approach to Anti Money Laundering and Countering the Financing of Terrorism. This means that measures and monitoring will be applied in accordance with the ML / FT risks posed to the Company. In this manner it can be ensured that resources are directed to the areas which pose the greatest risk of ML / FT.
Each player is categorized into Low, Medium or High category in terms of risk. The categorization is carried out in accordance with the following criteria and added to the player’s files.
| Low | Medium | High | |
|---|---|---|---|
| Documents status | - | Approved | Approved |
| Deposit amount | <€2,000 | Between €2,000 and €4,999 | €5,000 in 24hrs €7,000 in 7 days €15,000 within thirty days |
| Number of deposit methods | Same method | 2 different methods | 3 or more different methods |
The type of verification performed depends on the risk level of the customer. The database of customers is divided in three (3) risk levels, Low, Medium and High, and different levels of verification apply to each level.
The risk levels are set automatically; therefore, a player will be moved from one level to another, based on their activity. AFPD agent may alter a risk level should they consider that the customer belongs to a higher risk or lower level based on their transactional and gaming activity.
Please find below the risk levels description and criteria:
Players meeting the following criteria will be considered to expose the Company to a low risk, and will therefore be assigned to Low Risk accordingly:
However, the account will still be monitored for suspicious behaviour.
Customers posing a Low Risk will undergo initial verification which is done in the following way:
Players meeting the following criteria will be considered to expose the Company to a medium risk, and will therefore be assigned to Medium Risk accordingly:
No further alerts and / or suspicions.
Additionally, the following red flags will be considered for assigning the High Risk category to the customers:
Customers posing a High Risk will undergo EDD (Enhanced Due Diligence) verification:
The manual risk evaluation must be vigilant and consider all indications – financial and non-financial as well as possible problem gambling signs during account assessment and interaction with a customer. More information about Red flags can be found in [Appendix D].
All account registrations will have their registrations details screened and cross-referenced with Acuris’ PEP database as well as the tool’s Sanctions database which includes all of the worldwide and local sanctions databases. The Company reserves the right to use any other PEP and Sanctions tool (“AML Screening Tool”) and/or manual check of the PEP and sanctions lists worldwide. As soon as a notification is received by AML Screening Tool with regards to a PEP / Sanction match, or where such match is found manually, the account will be flagged for the Risk and Fraud department to review.
In case when a positive PEP match confirmed, the special procedure will apply:
In case of a positive Sanction match the following procedure must be followed:
In order to mitigate the ML/TF Risks and to avoid potentially committing one of the principal money laundering offences, the Company shall terminate the business relationship with a customer in the following circumstances:
Additionally, where, in relation to any customer, the Company is unable to apply Customer Due Diligence measures, the business relationship with the customer must be terminated.
The system of fraud controls of the Company stores IP of each player login and active game session, card data - first 6 and last 4 digits of the card used for depositing. Therefore, AFPD agent conducts IP checks of all active depositors for suspicious fraud activity, including but not limited by:
The Company ensures that all employees fulfilling the below functions and roles are trained by qualified professionals in order to ensure that they are aware and knowledgeable of the applicable AML/CFT regulations and licence obligations and their corresponding obligations as a result of their functions and roles.
The Company shall retain records, including documentation and information, for use in an investigation into, or an analysis of, the possibility of Money Laundering (ML) and Terrorist Financing.
These records can be requested by relevant competent authorities as required. The records maintained by the Company are extremely important to competent authorities responsible for analysis, investigation, law enforcement and prosecution since they may constitute evidence of the audit trail and of money flows.
The Company shall maintain records of all documents related to the verification process performed on a customer in relation to all business relationships formed:
Records of identification and verification of customers must be kept for a period of five (5) years after the business relationship with the player has ended.
Records of internal and external reports on suspicious activity should be retained for five (5) years from when the report was made.
Examples of documentary evidence
| Source | Document |
|---|---|
| Savings | Bank statement(s) demonstrating deposit/gifted monies |
| Sale of investments | Statement from investment provider or bank statement showing settlement from investment provider |
| Sale of property | Signed letter from — Solicitor / Advocate or Estate Agent or Contract of Sale / settlement statement |
| Loan | Loan agreement or statement |
| Inheritance | Copy of will, signed letter from solicitor, Grant of Probate or letter from Executor |
| Maturity or surrender of life assurance policy | Closing statement or letter from the policy provider |
| Insurance Claims | Letter from the insurance provider |
| Dividends or Profits from company | Latest audited company accounts / dividend statement |
| Divorce | Copy of court order / judicial separation agreement |
| Other court award (e.g. compensation) | Court order or signed letter from solicitor / advocate |
| Lottery / Gambling win | Evidence from the lottery company / cheque / winning’s receipt |
| Gift | Document showing who gave the gift, when and why (e.g. letter from donor), plus verification or identity of the donor, and information about the source of their wealth |