This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Stellar Ltd, operator of Spinbara Casino at spin-bara-online.fr, to detect, prevent and report money laundering, terrorist financing and related financial crime. Spinbara is licensed under Anjouan ALSI (licence no. 202412012, FI1) and Curaçao eGaming. All players, transactions and accounts on spin-bara-online.fr are subject to the requirements described below.
Stellar Ltd is committed to operating Spinbara in full compliance with applicable anti-money laundering ("AML") legislation and the conditions of its dual licences. This Policy applies to every person who registers an account, deposits funds, places wagers, or requests a withdrawal on spin-bara-online.fr, regardless of the payment method or currency used.
The primary objectives of this Policy are to:
This Policy is designed to reflect best-practice AML/KYC obligations consistent with the Financial Action Task Force (FATF) Recommendations, the conditions of the Anjouan (ALSI) licence (no. 202412012, FI1) and the Curaçao eGaming regulatory framework. Where the laws of any additional jurisdiction in which a player is resident impose stricter obligations, those obligations will take precedence.
Stellar Ltd reserves the right to amend this Policy at any time in response to changes in applicable law, regulatory guidance or internal risk assessment. Material changes will be communicated via spin-bara-online.fr.
Money laundering is the process by which proceeds of crime are made to appear legitimate. It is generally understood to occur in three stages:
Spinbara's controls are designed to interrupt this process at every stage.
Stellar Ltd applies a risk-based approach to AML compliance. Each player account is assessed for risk at the point of registration and continuously thereafter. Risk factors taken into account include, but are not limited to:
Players assessed as presenting a higher risk will be subject to enhanced due diligence ("EDD") measures, which may include requests for additional documentation and closer ongoing monitoring.
KYC verification is mandatory for all players on spin-bara-online.fr. As stated in Spinbara's payment terms, verification is required before the first withdrawal is processed. Players are strongly encouraged to complete KYC promptly after registration to avoid delays when requesting a cashout. Spinbara may also request verification at any point during the lifecycle of an account where a risk trigger is identified.
All players must complete standard CDD, which requires the submission of the following documentation:
EDD is applied in addition to standard CDD where a player is assessed as presenting elevated risk. Circumstances that may trigger EDD include:
EDD measures may include one or more of the following:
A PEP is an individual who holds, or has held within the preceding twelve months, a prominent public function, or who is a close family member or known associate of such a person. Spinbara screens all players against recognised PEP databases. Accounts identified as belonging to PEPs are automatically subject to EDD and require senior management approval before withdrawal requests are processed.
Spinbara screens all players and transactions against applicable sanctions lists, including those published by the United Nations, the European Union, and the Office of Foreign Assets Control (OFAC). Any match against a sanctions list will result in immediate account restriction and notification to the relevant authority. Funds held in such accounts will be frozen pending further investigation.
All documents submitted for KYC purposes must be:
Documents may be submitted via the player's account verification portal on spin-bara-online.fr or by email to [email protected]. Spinbara reserves the right to reject documents that do not meet the required standards and to request resubmission.
Spinbara aims to complete standard KYC reviews within a reasonable time of receiving all required documentation. Delays may occur where documents require further scrutiny or where additional information is requested. Withdrawal processing — including crypto withdrawals, which ordinarily complete in under one hour, and e-wallet withdrawals, which ordinarily complete within 24 to 48 hours — will not commence until verification is satisfactorily completed.
KYC is not a one-time event. Spinbara conducts continuous monitoring of all active accounts to identify changes in risk profile and detect potentially suspicious activity. Ongoing monitoring measures include:
Where ongoing monitoring reveals a change in risk profile, Spinbara may request updated documentation or impose temporary restrictions on account functionality while a review is conducted.
Spinbara's compliance team is trained to identify a range of behaviours that may indicate money laundering or other financial crime. Indicators include, but are not limited to:
Any member of Spinbara's staff or compliance function who identifies a suspicious activity concern must report it to the designated Money Laundering Reporting Officer (MLRO) without delay, using the internal reporting procedures established by Stellar Ltd. Staff are reminded that tipping off a subject of suspicion — that is, informing a player that a report is being made — is strictly prohibited and may itself constitute a criminal offence.
Where the MLRO concludes that a suspicious activity report (SAR) is warranted, a report will be made to the relevant financial intelligence unit or regulatory authority as required under the applicable licensing conditions. Spinbara will co-operate fully with any subsequent investigation by law enforcement or regulatory bodies.
The following persons and activities are strictly prohibited on spin-bara-online.fr:
Spinbara's transaction limits serve both a commercial and a compliance function. Limits applicable at spin-bara-online.fr are set out below.
| Parameter | Amount |
|---|---|
| Minimum deposit | €10–€20 (varies by payment method) |
| Maximum deposit | €5,000 per transaction |
| Minimum withdrawal | €20 |
| Maximum withdrawal | €20,000 per month |
Transactions that approach or exceed internal thresholds will automatically trigger a compliance review. Players who regularly transact at or near the maximum levels may be subject to EDD, including requests for source of funds and source of wealth documentation, regardless of whether a specific suspicious indicator has been identified.
All transactions on spin-bara-online.fr are protected by 256-bit SSL encryption. Spinbara does not store full card details and processes all payment data in accordance with applicable data protection standards.
Spinbara accepts deposits and withdrawals in Bitcoin, Ethereum, Litecoin, USDT, USDC, XRP, BNB, and TRX. Cryptocurrency transactions are subject to the same KYC and AML controls as fiat transactions. In addition:
Stellar Ltd maintains records of all KYC documentation, transaction data, risk assessments, internal reports, and suspicious activity reports for a minimum of five years from the date the business relationship ends or the relevant transaction is completed, in accordance with standard AML best practice and the requirements of Spinbara's licensing authorities. All records are stored securely and access is restricted to authorised personnel.
All personnel engaged in compliance, customer support, payments, and account management functions at Spinbara receive AML/KYC training at induction and on a regular ongoing basis. Training covers recognition of suspicious activity indicators, correct use of internal reporting procedures, obligations under this Policy, and the legal consequences of non-compliance including the prohibition on tipping off.
Spinbara recognises that problem gambling and financial crime can intersect. A player gambling with funds they cannot afford, or exhibiting erratic deposit and withdrawal behaviour, may also present AML risk indicators. Spinbara's responsible gambling tools — including deposit limits, loss limits, self-exclusion, and cooling-off periods — are available to all players and form part of a wider framework of player protection that complements AML monitoring. Players who are concerned about their gambling can contact Spinbara's 24/7 support team via live chat or at [email protected].
Where a player fails to complete KYC verification within a reasonable period, provides false, misleading or fraudulent documentation, or is found to have engaged in conduct prohibited by this Policy, Spinbara reserves the right to take one or more of the following actions:
Spinbara will not be liable for any loss suffered by a player as a result of account suspension or closure where such action is taken in good faith pursuant to this Policy.
Questions relating to this Policy, KYC requirements, or the status of a verification review may be directed to Spinbara's compliance and support team:
This Policy is published by Stellar Ltd, operator of Spinbara Casino at spin-bara-online.fr, and was last reviewed in 2025. Stellar Ltd reserves the right to amend this Policy at any time. Continued use of spin-bara-online.fr following notification of any amendment constitutes acceptance of the revised Policy.
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