This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of KORNELITY S.R.L. ("the Company", "we", "us", "our"), the operator of Duckysino Casino at duckysiino.nl, with respect to the prevention of money laundering, terrorist financing, and other financial crime. The Company holds a Tobique Gaming Commission licence (No. 38) and a Curaçao licence (OGL/2025/7124/1678) and is committed to operating in full compliance with the requirements attached to both regulatory authorities. All registered players and prospective players of Duckysino are subject to this Policy as a condition of accessing the platform.
Money laundering is the process by which criminally obtained funds are introduced into, moved through, or extracted from legitimate financial systems so as to conceal their true origin. Terrorist financing involves the provision or collection of funds, by any means, with the intention or knowledge that they are to be used to carry out a terrorist act. Both represent serious criminal offences and direct threats to the integrity of licensed gambling operations.
This Policy applies to:
The Company's AML and KYC procedures are designed to ensure that Duckysino is not used as a vehicle for money laundering, terrorist financing, fraud, or any other form of financial crime. Compliance with this Policy is mandatory and non-negotiable.
The Company operates under the dual-licence structure referenced on duckysiino.nl and ensures that its AML and KYC procedures meet or exceed the standards set by both licensing bodies:
The Company also has regard to internationally recognised standards, including the recommendations of the Financial Action Task Force (FATF), when designing and updating its compliance framework.
KYC verification is a regulatory requirement and a practical safeguard. By confirming a player's identity, age, address, and payment method ownership before processing a withdrawal, the Company ensures that funds are released only to the legitimate account holder, that no person under the legal minimum age is participating, and that the source of funds is consistent with the player's stated profile. Duckysino is committed to conducting KYC checks in a proportionate, efficient, and respectful manner.
KYC verification will be initiated in any of the following circumstances:
The Company reserves the right to request KYC documentation at any stage of the customer relationship, including at the point of registration, and to suspend or restrict account activity pending the satisfactory completion of verification checks.
As stated on duckysiino.nl, the standard set of documents required for identity verification comprises the following three categories:
| Document Category | Accepted Examples | Requirements |
|---|---|---|
| Proof of Identity | Passport; national identity card | Must be government-issued, valid (not expired), and show the player's full name, date of birth, photograph, and document number clearly |
| Proof of Address | Utility bill; bank statement; official government correspondence | Must show the player's full name and residential address; must be dated within the last three months |
| Proof of Payment Method | Screenshot or photograph of the card, e-wallet account, or crypto wallet used to deposit | Must confirm that the payment method belongs to the registered account holder; card screenshots should show the name and first six / last four digits only — the middle digits may be obscured for security |
Certain situations require Enhanced Due Diligence beyond the standard three-document check. EDD may be applied where:
EDD measures may include, but are not limited to, requests for source of funds documentation (such as payslips, tax returns, or bank statements), source of wealth declarations, enhanced transaction monitoring, and senior management review before funds are released.
The Company aims to complete standard KYC verification within approximately 48 hours of receiving a complete and legible set of required documents on the occasion of a player's first withdrawal, consistent with the timeline stated on duckysiino.nl. Withdrawals will remain pending until verification is successfully completed. If submitted documents are unclear, expired, or incomplete, the Company will notify the player and request resubmission; the 48-hour window restarts upon receipt of satisfactory replacements.
During an active KYC review, the Company reserves the right to place a temporary hold on withdrawal processing. Deposits and gameplay may continue subject to the Company's risk assessment, though the Company may also restrict deposit activity where a review raises material concerns.
As stated in Duckysino's cashier policy, the name registered on the player's account must match the name associated with their payment method. Withdrawals will only be processed back to the same payment method used for the corresponding deposit. The Company will not process withdrawals to third-party accounts under any circumstances. Any attempt to use a payment method belonging to another person will be treated as a potential indicator of fraud and will trigger an immediate compliance review.
The Company applies a risk-based approach to AML compliance, meaning that the intensity of monitoring and due diligence applied to any given customer or transaction is proportionate to the assessed risk that customer or transaction poses. Lower-risk customers transacting within standard limits will experience a lighter verification process; higher-risk customers — identified through behavioural signals, transaction patterns, geographic indicators, or other factors — will be subject to stricter scrutiny.
At the point of registration and on an ongoing basis, the Company assesses each customer against a range of risk indicators, including but not limited to:
Customers assessed as higher risk will be assigned enhanced monitoring parameters and may be required to provide additional documentation before limits are extended or withdrawals processed.
The Company maintains automated and manual transaction monitoring systems designed to detect patterns consistent with money laundering or terrorist financing. Monitored indicators include, but are not limited to:
Duckysino accepts Bitcoin, Ethereum, and Litecoin as payment methods, with a minimum deposit of €20 and instant withdrawal processing for verified accounts. Cryptocurrency transactions carry specific AML considerations, and the Company applies the following controls:
The Company screens all customers against applicable international sanctions lists, including those maintained by the United Nations, the European Union, and other relevant authorities, at the point of registration and on an ongoing basis. Any match or potential match against a sanctions list will result in the immediate suspension of the account and escalation to senior compliance personnel. The Company will not establish or maintain a business relationship with any individual or entity subject to applicable financial sanctions.
Where a player's transaction activity — including deposits, withdrawals, and bonus utilisation — is inconsistent with their stated profile, or where the cumulative value of their activity exceeds thresholds set in the Company's internal risk framework, the Company will request source of funds and/or source of wealth documentation. Players may be asked to provide:
Failure to provide satisfactory source of funds documentation within a reasonable timeframe will result in account suspension and the withholding of pending withdrawals pending further review.
Where the Company's compliance team identifies a transaction or pattern of behaviour that gives rise to knowledge, suspicion, or reasonable grounds for suspicion of money laundering or terrorist financing, the Company will file a Suspicious Activity Report (SAR) or equivalent report with the relevant authority as required under applicable law. The Company's compliance personnel are trained to recognise the indicators of suspicious activity and are obligated to escalate concerns promptly.
In accordance with applicable "tipping off" provisions, the Company will not disclose to a customer that a SAR has been filed, or that they are under investigation, where such disclosure might prejudice a regulatory or law enforcement investigation. The Company reserves the right to delay, suspend, or refuse any transaction that is the subject of a suspicious activity report without providing a detailed explanation to the customer concerned.
Duckysino's bonus and promotional programme — including the three-deposit welcome package of up to €2,500 and 250 Free Spins, Sunday reload bonuses, weekly cashback of up to 25%, the Highroller Bonus, rakeback of up to 18%, and tournament prize pools — is subject to AML monitoring in the same way as standard cashier transactions. The Company will not pay out bonus-derived funds where the account in question is under a KYC or AML review, and all bonus wagering requirements must be met through bona fide gameplay before withdrawal eligibility is established.
The Company actively monitors for bonus abuse patterns — including multi-accounting, use of bonus funds without genuine play intent, and coordinated exploitation of promotional structures — which may also indicate broader financial crime risk. Where such activity is identified, the Company reserves the right to void bonuses, withhold withdrawals, and close accounts.
The standard weekly withdrawal limit on Duckysino is €3,000. VIP players may withdraw up to €20,000 per week. Wins exceeding €15,000 may be paid in monthly instalments of up to €15,000 per month. Any request to increase withdrawal limits — whether through progression to VIP status or otherwise — will trigger a review of the player's KYC status and, where applicable, source of funds documentation. Limits will not be increased until the Company is satisfied that the enhanced due diligence requirements applicable to higher-value accounts have been met.
| Player Tier | Standard Weekly Withdrawal Limit | EDD Required for Limit Access |
|---|---|---|
| Standard | €3,000 | Standard KYC |
| VIP | Up to €20,000 | Enhanced Due Diligence applicable |
| Large single win (over €15,000) | Up to €15,000 per month (instalments) | Enhanced Due Diligence applicable |
The Company maintains records of all customer due diligence documentation, transaction histories, and compliance decisions for a minimum period as required by the applicable regulatory frameworks under which it is licensed. Records are stored securely and are made available to regulatory authorities upon request. Retention of records encompasses:
The Company ensures that all personnel with access to customer accounts, transaction data, or compliance-sensitive information receive appropriate AML and KYC training commensurate with their role. Training covers the recognition of suspicious activity indicators, the correct escalation procedure for flagged transactions, the prohibition on tipping off, and the legal obligations that attach to the Company's licence conditions. Training is reviewed and updated regularly to reflect changes in regulatory guidance and emerging typologies.
The Company designates a nominated compliance officer responsible for overseeing the implementation of this Policy, coordinating with regulatory authorities, and ensuring that internal AML controls remain fit for purpose. The compliance officer has the authority to suspend accounts, withhold transactions, and escalate matters to external authorities as the situation demands.
Players who register and transact at duckysiino.nl accept the following obligations as a condition of their account:
Where a player fails to complete KYC verification within a reasonable timeframe, provides false or misleading documentation, or is found to have engaged in activity consistent with money laundering, fraud, or other financial crime, the Company reserves the right to take any or all of the following actions:
The Company will not be liable to a player for any loss, inconvenience, or reputational impact arising from account suspension or fund withholding where such action is taken in good faith pursuant to this Policy or the requirements of the applicable regulatory framework.
The Company recognises that problem gambling and financial crime risk can, in some circumstances, intersect — for example, where a player deposits funds well beyond their apparent means, or where account activity is inconsistent with recreational gambling behaviour. The Company's responsible gambling programme and its AML monitoring framework operate in parallel, and signals identified through either strand may be escalated through both channels where appropriate. Players seeking assistance with gambling-related concerns may contact the Duckysino support team at any time via 24/7 live chat, email at [email protected], or by telephone on +4901516458215.
This Policy is reviewed on a regular basis to ensure that it reflects current regulatory requirements, evolving financial crime typologies, and any changes to the Duckysino platform, its payment infrastructure, or its licence conditions. The most current version of this Policy is always available at duckysiino.nl. Continued use of the platform following any update constitutes acceptance of the revised terms. Players with questions regarding this Policy are encouraged to contact the compliance team via the support channels listed above.
Operator: KORNELITY S.R.L. | Platform: duckysiino.nl | Licences: Tobique Gaming Commission No. 38; Curaçao OGL/2025/7124/1678 | Contact: [email protected]
