Vincispin maintains an AML/CTF framework designed to prevent money laundering and the financing of terrorism in all activities conducted through its platform. This policy sets out the controls, processes, and governance by which Vincispin identifies, assesses, monitors, and mitigates AML/CTF risk in relation to customer onboarding, transactions, and ongoing relationships.
This policy applies to all Vincispin customers, employees, contractors, agents, and service providers involved in customer due diligence, transaction monitoring, and reporting obligations. It covers all products and channels offered by Vincispin, including digital accounts, payments, and gaming transactions, regardless of location, where permitted by applicable law.
Vincispin operates in compliance with applicable anti-money laundering and counter-terrorist financing requirements as defined by its licensing and supervisory regime. The policy aligns with recognised international standards, including risk-based customer due diligence, record-keeping, and reporting obligations. Board oversight and a designated Compliance Officer are responsible for maintaining, testing, and updating AML controls in response to regulatory developments and risk conditions.
Onboarding at Vincispin requires verification of identity and assessment of risk before enabling full account functionality. The process is conducted on a risk-based basis, escalating to enhanced due diligence where warranted by the customer profile or geographic risk.
Vincispin employs automated and manual monitoring to identify unusual or unexpected activity. The policy includes explicit per-transaction and aggregate thresholds intended to manage risk while supporting legitimate user activity.
EDD is applied where customers present elevated AML/CTF risk, including but not limited to high-value activity, unusual patterns, or high-risk geographies. EDD measures may include:
Vincispin conducts ongoing screening against sanctions lists, politically exposed persons, and known adverse media. When a customer is identified as a PEP or presents elevated risk due to media or event indicators, Vincispin applies enhanced scrutiny and may request additional information or documentation and may temporarily restrict activity until risk is mitigated.
Vincispin maintains records relating to customer identities, verification results, risk assessments, transaction data, and communications for a minimum period mandated by applicable law and licensing requirements. Records include copies or images of submitted documents, verification dates, and the rationale for risk classifications or approvals. Data is stored securely and access is restricted to authorised personnel in accordance with data protection obligations.
The Compliance Officer has overall responsibility for the design, implementation, and ongoing operation of this policy. Business units, support functions, and IT staff support AML controls through proper customer due diligence, transaction monitoring, reporting, and data protection. Clear ownership exists for escalation of suspicious activity, adverse findings, and regulatory inquiries.
Vincispin provides ongoing training to employees and contractors on AML/CTF obligations, red flag indicators, and the proper handling of suspicious activity. Training is updated in response to regulatory changes and evolving risk patterns and is completed within defined timeframes after onboarding and on a periodic basis thereafter.
Suspected or actual suspicious activity or transactions must be reported promptly through internal channels and, where legally required, to the appropriate competent authority. Vincispin cooperates with law enforcement and supervisory bodies and shares information to the extent permitted by law and data protection obligations for the purpose of preventing financial crime.
This AML/CTF policy is reviewed at least annually and more frequently when regulatory changes, risk conditions, or business developments require. Updates are approved by the Board and communicated to all staff with mandatory compliance training where applicable.