AML Policy of Metatokens N.V.

For Deposits and Withdrawals.

AML Anti-Money-Laundering policy of

Introduction: is operated by Metatokens N.V. having its office at Zuikertuintjeweg Z/N (Zuikertuin Tower), Curaçao. Company Registration number 164447

Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on For that purpose, a three-step account verification is implemented to ensure the identity of our customers. This process aims to verify the accuracy of registered personal details and to confirm that the deposit methods used are legitimate and not stolen or misused. This verification framework is integral to our efforts in combating money laundering. Additionally, we recognize that safety measures for payment and withdrawal may vary based on nationality and origin. also implements reasonable measures to control and mitigate the risk of money laundering, including the allocation of appropriate resources. is committed to upholding the highest standards of anti-money laundering (AML) in accordance with EU guidelines. Our company emphasizes compliance and mandates that both management and employees enforce these standards to prevent the illicit use of our services for money laundering activities.

The AML program of is designed to align with the following regulations:

EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”

EU: “Regulation 2015/847 on information accompanying transfers of funds”

EU: Various regulations imposing sanctions or restrictive measures against individuals, as well as embargoes on certain goods and technology, including all dual-use goods

BE: “Law of 18 September 2017 on the prevention of money laundering and the limitation of the use of cash”

Definition of Money Laundering:

Money Laundering is understood as:

  • The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
  • The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
  • The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
  • Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for

In accordance with the AML legislation, has appointed the “highest level” for the prevention of ML: The full management of Metatokens N.V. are in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general Management.

AML Policy Changes and Implementation Requirements:

Each major change of AML policy is subject to approval by the general management of Metatokens N.V. and the Anti Money Laundering Compliance Officer.

Three-Step Verification:

Step One Verification:

Step one verification must be completed by every user and customer to initiate withdrawals. This verification is required regardless of the payment method, payment amount, withdrawal amount, withdrawal method, or user/customer nationality. Step one verification involves filling out a document by the user/customer. The required information includes: first name, last name, date of birth, country of usual residence, gender, and full address.

Step Two Verification:

Step two verification must be completed by every user who deposits over 2000 EUR or withdraws any amount. Withdrawals, tips, or deposits will be held until step two verification is done. The user/customer will be directed to a subpage to upload their ID. A picture of the ID must be taken with a paperclip containing a randomly generated six-digit number next to it. Only an official ID is acceptable for verification, with the accepted IDs varying based on the user's country. An electronic check will verify if the information provided in step one matches the document and the ID's name. If the electronic check fails or is not feasible, the user/customer needs to provide confirmation of their current residence, such as a government-issued registration certificate.

Step Three Verification:

Step three verification must be completed by every user who deposits over $5000, withdraws over $5000, or sends another user over $3000. Withdrawals, tips, or deposits will be held until step three verification is done. Users/customers completing step three verification will need to provide a source of wealth.

Customer Identification and Verification (KYC)

The formal identification of customers upon entering into commercial relations is crucial for both money laundering regulations and the KYC policy.

This identification process is based on the following fundamental principles:

  • A copy of your passport, ID card, or driver's license, each displayed alongside a handwritten note containing six randomly generated numbers.
  • A second picture with the user/customer's face is required. The user/customer can blur out any information, except for date of birth, nationality, gender, first name, second name, and the picture, to protect their privacy.
  • Please ensure that all four corners of the ID are visible in the same image and that all details are clearly readable, as specified above. We may request all details if necessary.
  • An employee may perform additional checks as needed based on the situation.

Proof of Address:

Proof of address will be conducted through two different electronic checks, utilizing distinct databases. In the event of an electronic test failure, the user/customer will have the option to provide manual proof.

Accepted documents for proof of address include:

  • A recent utility bill sent to your registered address, issued within the last 3 months
  • An official document issued by the government that proves your state of residence

To expedite the approval process, ensure the document is sent with a clear resolution, displaying all four corners of the document and readable text.

Acceptable examples include an electricity bill, water bill, bank statement, or any governmental correspondence addressed to you.

An employee may perform additional checks as needed based on the situation.

Source of Funds

If a player deposits over five thousand euros, a process is initiated to understand the source of wealth (SOW).

Examples of SOW are:

  • Ownership of business
  • Employment
  • Inheritance
  • Investment
  • Family

It is critical that the origin and legitimacy of that wealth are clearly understood. If this understanding is not possible, an employee may request additional documents or proof.

The account will be frozen if the same user deposits an amount over this limit in one go or through multiple transactions that accumulate to this amount. An email will be manually sent to guide them through the process mentioned above, and information will also be provided on the website itself. also requests a bank wire or credit card information to further ensure the identity of the user/customer. This process also provides additional information about the financial situation of the user/customer.

Basic Document for Step One:

The basic document will be accessible via the settings page on Every user has to provide the following information:

  • First name
  • Second name
  • Nationality
  • Gender
  • Date of Birth

The document will be generated and saved by an AI. An employee may conduct additional checks as needed based on the situation.

Risk Management:

To address the various risks associated with different regions and levels of wealth around the world, will categorize each nation into three different risk regions.

Region One: Low Risk:

For nations falling under region one, the three-step verification process will be conducted as described earlier.

Region Two: Medium Risk:

For nations in region two, the three-step verification will be applied to lower deposit, withdrawal, and tip amounts. Step one verification remains the same. Step two verification will occur after depositing $1000, withdrawing $1000, or tipping another user/customer $500. Step three verification will be done after depositing $2500, withdrawing $2500, or tipping another user/customer $1000. Users from a low risk region that convert cryptocurrency to any other currency will be treated similarly to users/customers from a medium risk region.

Region Three: High Risk:

High-risk regions will be prohibited. The list of high-risk regions will be regularly updated to adapt to the rapidly changing global landscape.

Additional Measures:

In addition, an AI overseen by the AML compliance officer will actively monitor for any unusual behavior and promptly report it to an employee of

Following a risk-based approach and general experience, human employees will review all checks performed by the AI or other employees. They may recheck, redo, or conduct additional checks based on the situation.

Additionally, a data scientist supported by modern electronic analytic systems will identify unusual behavior, such as depositing and withdrawing without extended betting sessions, attempts to use different bank accounts for deposits and withdrawals, changes in nationality or currency, shifts in behavior and activity, and checks to verify whether an account is being used by its original owner.

A user must use the same method for withdrawal as was used for the initial deposit, and this withdrawal amount should match the initial deposit amount to prevent money laundering.

Enterprise-wide Risk Assessment

As part of its risk-based approach, has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to and its business lines.

The AML risk policy is determined after identifying and documenting the risks inherent to its business lines, including the services the website offers, the users to whom services are offered, transactions performed by these users, delivery channels used, geographic locations of operations, customers and transactions, and other qualitative and emerging risks.

The identification of AML risk categories is based on' understanding of regulatory requirements, expectations, and industry guidance. Additional safety measures are taken to address the risks associated with the global online environment.

The EWRA is reassessed annually.

Ongoing Transaction Monitoring

AML Compliance ensures that an ongoing transaction monitoring is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

1) The First Line of Control: collaborates exclusively with trusted Payment Service Providers, all of whom have effective AML policies in place. This prevents the majority of suspicious deposits onto {LEGAL_DOMAIN_NAME$ from occurring without proper execution of KYC procedures on potential customers.

2) The Second Line of Control: establishes a network that requires due diligence on transactions whenever there is contact with the customer, player, or authorized representative. This includes requests for financial transactions or services on the account.

The three-step verification with adjusted risk management should provide all necessary information about all customers of at all times. All transactions must be overseen by employees, watched by the AML compliance officer, who is overseen by the general management.

Transactions submitted to the customer support manager, possibly through their Compliance Manager, must also undergo due diligence.

Determining the unusual nature of transactions essentially depends on subjective assessment, considering the customer's knowledge (KYC), financial behavior, and transaction counterparties.

These checks will be performed by an automated system, while an employee crosschecks them for additional security.

Transactions observed on customer accounts where understanding the lawful activities and origin of funds is difficult must be rapidly considered atypical, as they cannot be directly justified.

Any staff member must inform the AML division of any atypical transactions observed that cannot be attributed to a known lawful activity or source of income of the customer.

3) The Third Line of Control:

As a last line of defense against AML, will manually check all suspicious and higher-risk users to fully prevent money laundering. In case of fraud or money laundering, authorities will be informed.

Reporting of Suspicious Transactions on

In its internal procedures, provides precise instructions for its staff members on when and how to report suspicious transactions.

Reports of atypical transactions are analyzed by the AML team using a methodology described in the internal procedures.

Based on the examination results and gathered information, the AML team:

  • Decides whether to report to the FIU (Financial Intelligence Unit) as required by legal obligations under the Law of 18 September 2017.
  • Decides whether to terminate business relations with the customer.


The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures available on the Intranet site of

Record Keeping

Data obtained for identification purposes must be retained for at least ten years after the business relationship ends.

Transaction data records must be retained for at least ten years after transactions are carried out or the business relationship ends.

This data will be securely stored, encrypted, both offline and online.


The internal audit conducts regular missions and reports on AML activities.

Data Security

All data provided by users/customers will be kept secure and not shared or sold to others. Data may only be shared with the AML authority of the affected state if legally compelled or to prevent money laundering. will adhere to all guidelines and rules of the data protection directive (Directive 95/46/EC).

Contact Us:

If you have any questions about our AML and KYC Policy or if you have any complaints about our AML and KYC Policy or the checks conducted on your account and person, please feel free to contact us:

  • By email: