AML / KYC Policy | betoranje

This Anti-Money Laundering and Know Your Customer Policy ("Policy") governs all accounts registered and operated through bets-oranje.com. betoranje is operated by JACO V.I.P. LIMITADA, a company incorporated in Costa Rica, and this Policy has been in effect since September 2025. betoranje is committed to preventing financial crime, protecting the integrity of its platform, and ensuring that its services are not used — knowingly or otherwise — to facilitate money laundering, terrorist financing, or any other form of financial misconduct. All players, regardless of the currency or payment method they use, are subject to the procedures described in this document.

1. Purpose and Scope

The purpose of this Policy is to set out the obligations of betoranje and its players with respect to identity verification, source-of-funds checks, transaction monitoring, and the reporting of suspicious activity. It applies to every individual who registers an account at bets-oranje.com, makes a deposit, requests a withdrawal, or otherwise interacts with the financial infrastructure of the platform — including players using fiat currencies (EUR, CAD, NOK, PLN, AUD) and those transacting in cryptocurrencies (BTC, USDT and other supported digital assets).

JACO V.I.P. LIMITADA operates betoranje under its own internal compliance framework. Where this Policy refers to regulatory standards, those references reflect international best-practice guidelines, including the Financial Action Task Force (FATF) Recommendations, which inform our internal procedures even where a specific national licensing authority is not named.

2. Definitions

AML — Anti-Money Laundering: the set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.
KYC — Know Your Customer: the process by which betoranje verifies the identity of its players before, during, or after they conduct financial transactions.
CDD — Customer Due Diligence: standard checks carried out to establish and verify a player's identity and the source of their funds.
EDD — Enhanced Due Diligence: additional checks applied to higher-risk players, large transactions, or accounts flagged by our monitoring systems.
PEP — Politically Exposed Person: an individual who holds or has held a prominent public function, together with their immediate family members and known close associates.
SAR — Suspicious Activity Report: an internal report raised when a transaction or pattern of behaviour gives rise to suspicion of money laundering or terrorist financing.
MLRO — Money Laundering Reporting Officer: the designated compliance officer responsible for receiving internal SARs and deciding whether to escalate them externally.

3. Money Laundering — Overview of the Risk

Money laundering typically occurs in three stages: placement (introducing illicit funds into the financial system), layering (obscuring the trail through complex transactions), and integration (re-introducing funds as apparently legitimate assets). Online gaming platforms can be exposed to all three stages if robust controls are not maintained. betoranje recognises this risk and has built its compliance programme accordingly.

Terrorist financing presents a related but distinct risk: funds used to finance terrorism may originate from entirely legitimate sources but are directed towards criminal ends. betoranje's monitoring systems are calibrated to detect both money laundering and terrorist-financing patterns.

4. Our AML and KYC Programme

betoranje's compliance programme rests on four pillars: customer identification and verification, ongoing transaction monitoring, risk-based assessment, and internal reporting. Each pillar is described in the sections below.

4.1 Customer Identification Programme (CIP)

Every player who registers an account at bets-oranje.com must provide accurate and complete information at the point of registration. The minimum information collected at sign-up includes:

Full legal name
Date of birth
Country of residence
Valid email address
Contact telephone number (where requested)

By submitting this information, the player confirms that it is truthful and up to date. betoranje reserves the right to request updated information at any point during the account lifecycle. Providing false or misleading information constitutes a material breach of our Terms and Conditions and may result in immediate account closure and forfeiture of any pending withdrawals.

4.2 Identity Verification (Know Your Customer)

Verification documents may be requested before a player's first withdrawal is processed, when deposits or cumulative activity reach defined internal thresholds, when a player's behaviour triggers a risk alert, or at any time betoranje deems appropriate in the interests of compliance. Players will be notified via email or live chat that verification is required, and their withdrawal requests will be held pending until the process is complete.

Standard KYC documentation comprises three categories:

Category	Acceptable Documents	Purpose
Proof of Identity (POI)	Valid passport; national identity card; driver's licence (with photo)	Confirms the player's full name, date of birth, and photograph
Proof of Address (POA)	Utility bill; bank statement; official government correspondence — dated within 90 days	Confirms the player's residential address
Proof of Payment Option (POPM)	Photo of payment card (with middle digits obscured); e-wallet account screenshot; crypto wallet address confirmation	Confirms ownership of the deposit method used

Documents must be submitted in colour, must be legible and unaltered, and must be valid at the time of submission. betoranje supports verification document uploads through the account dashboard on bets-oranje.com. If documents are unclear or insufficient, our compliance team will contact the player to request alternatives.

betoranje aims to process submitted KYC documents promptly. Players should allow for reasonable processing time from the date of submission. The standard withdrawal timeline of up to 96 hours — as described on our main cashier page — begins only after verification has been successfully completed.

4.3 Age Verification

betoranje operates a strict policy of zero tolerance for underage gambling. No player under the age of 18 may register an account or place any wager at bets-oranje.com. Age verification is carried out as part of the standard KYC process. Where there is any reasonable doubt about a player's age, we will restrict account access — including the ability to deposit or withdraw — until satisfactory proof of age has been provided. If verification confirms that a player is under 18, the account will be permanently closed, all funds will be returned to their source (less any applicable processing costs), and all winnings will be forfeited.

5. Risk-Based Approach

betoranje applies a risk-based approach to customer due diligence. This means that the level of scrutiny applied to any individual account is proportionate to the risk that account presents. Risk factors assessed include, but are not limited to:

Country of residence or citizenship (with higher risk assigned to jurisdictions identified by FATF as high-risk or under increased monitoring)
Volume and frequency of deposits and withdrawals relative to stated income or occupation
Use of cryptocurrency, which — while fully supported at betoranje — warrants additional monitoring given the pseudo-anonymous nature of blockchain transactions
Patterns of play inconsistent with recreational gambling (e.g., depositing large sums and immediately withdrawing with minimal gameplay)
PEP status or association with sanctioned individuals or entities
Multiple accounts, shared device identifiers, or shared payment methods across accounts

5.1 Standard Due Diligence

Standard CDD applies to the majority of betoranje players. It involves the collection and verification of the three document categories described in Section 4.2, plus ongoing monitoring of transactional behaviour against the player's stated profile.

5.2 Enhanced Due Diligence

EDD is applied where a player's risk profile is elevated. This may require:

Proof of source of funds — for example, recent payslips, bank statements, tax returns, proof of business ownership, or evidence of investment proceeds
Proof of source of wealth — a broader account of how the player's overall net worth was accumulated
A declaration of PEP or sanctions status
Additional identification documents or certified copies thereof
A personal interview conducted by a compliance officer via email or live chat

betoranje reserves the right to place a temporary hold on withdrawals and to restrict gameplay while EDD is ongoing. Failure to provide requested documentation within a reasonable period — ordinarily 30 days from the date of request — may result in account suspension.

5.3 Politically Exposed Persons and Sanctions Screening

All players are screened against international PEP lists and sanctions databases (including, without limitation, lists maintained by the United Nations, the European Union, and the Office of Foreign Assets Control). This screening is conducted at the point of registration and repeated on an ongoing basis. A player identified as a PEP is not automatically refused service; however, senior management approval is required before their account may be activated or continued, and EDD measures will apply throughout the relationship.

betoranje will not knowingly accept funds from, or pay funds to, any individual or entity appearing on a relevant sanctions list. Where a match is confirmed, the account will be frozen and the matter referred to the MLRO for escalation to the appropriate authorities.

6. Transaction Monitoring

betoranje maintains automated and manual systems to monitor transactional activity across all accounts on a continuous basis. Our payment infrastructure — referred to on the platform as Lightspeed Payments — processes deposits and withdrawals across fiat and cryptocurrency channels, and all transaction data is retained and analysed for compliance purposes.

Behaviours and patterns that may trigger a review include:

Deposits that are immediately withdrawn with little or no gameplay
Multiple rapid deposits close to or at the per-transaction limit (e.g., Visa/Mastercard deposits approaching the €1,000 single-transaction cap)
Cryptocurrency transactions of significant value — noting that crypto withdrawals at betoranje may reach up to €75,000 per day, and such activity will be subject to proportionate scrutiny
Unusual or sudden changes in deposit volumes relative to a player's historical pattern
Attempts to circumvent verification by splitting transactions across accounts or payment methods
Requests to change withdrawal methods to a different account or wallet than the one used for deposit — noting betoranje's standard policy that withdrawals are returned to the same method used for deposit
Activity inconsistent with responsible gambling norms that may suggest a player is acting on behalf of a third party

Where a transaction or pattern of activity raises concern, the account may be temporarily restricted pending review. The player will be notified unless doing so would constitute "tipping off" — that is, alerting a subject of an investigation in a manner that could compromise it.

7. Suspicious Activity Reporting

All betoranje staff who interact with player accounts — including customer support agents available 24/7 via live chat — are trained to recognise indicators of money laundering and are required to report any concerns internally to the MLRO. The MLRO reviews all internal reports and determines whether an external report to the appropriate financial intelligence authority is warranted. betoranje maintains a zero-tolerance policy towards tipping off, and no member of staff will inform a player that their account is under investigation or that a SAR has been filed.

8. Record Keeping

betoranje retains all KYC documents, transactional records, account activity logs, and compliance correspondence for a minimum of five years from the date of the relevant transaction or the closure of the account, whichever is the later. This retention period is consistent with international best-practice guidelines and allows us to assist any competent authority that may request access to historical data.

Records are stored securely in accordance with our Privacy Policy, which governs how personal data collected during the KYC process is processed, stored, and protected.

9. Withdrawal Holds and Account Restrictions

betoranje reserves the right to delay, suspend, or refuse a withdrawal where:

KYC documentation has not been provided or has not been accepted
A transaction monitoring alert is under active review
EDD procedures have been initiated and are not yet complete
There is a reasonable suspicion of fraud, money laundering, or violation of our Terms and Conditions
A request has been received from a relevant law enforcement or regulatory authority

The standard withdrawal timeline at betoranje — up to 96 hours, with faster processing available from Silver VIP level — applies only to accounts that have passed all applicable verification requirements and have no active compliance holds. betoranje will communicate the reason for any hold to the extent permitted by law, but is not obliged to disclose information that could prejudice an ongoing investigation.

10. Cryptocurrency and Digital Asset Transactions

betoranje accepts deposits and processes withdrawals in Bitcoin (BTC), Tether (USDT), and other supported cryptocurrencies. Cryptocurrency transactions are subject to the same KYC and AML requirements as fiat transactions. In addition, betoranje applies the following specific measures to crypto activity:

Blockchain analytics tools are used to assess the risk profile of incoming cryptocurrency deposits, including screening for wallet addresses associated with known illicit activity.
Players depositing in cryptocurrency are required to confirm that they are the sole beneficial owner of the wallet from which funds are sent.
Withdrawals in cryptocurrency — which may reach up to €75,000 per day — will be subject to enhanced scrutiny at higher value thresholds.
Crypto balances and fiat balances are maintained separately at betoranje, and players may not convert between them on the platform. Attempts to use crypto channels to circumvent controls applicable to fiat transactions will be treated as a compliance red flag.
The crypto welcome bonus (200% up to 3,000 USDT on first deposit) is subject to the same wagering and verification conditions as all other bonuses, and no withdrawal of bonus-related winnings will be processed until KYC is complete.

11. Bonus Integrity and AML Interaction

betoranje's promotional structure — including the five-deposit welcome package worth up to €11,500 plus 400 free spins, the Sports Welcome Pack worth up to €25,900, daily cashback of up to 45%, instant rakeback of up to 25%, and the full ongoing promotion calendar — is designed for recreational players engaging in genuine gameplay. Bonus mechanisms may not be used as a vehicle for laundering funds.

Patterns that suggest bonus abuse in conjunction with potential financial crime — for example, meeting wagering requirements through systematically low-risk bets in order to extract clean funds — will be treated as a compliance concern. betoranje reserves the right to void bonuses, withhold associated winnings, and report the activity concerned where there are reasonable grounds to suspect that the bonus framework is being exploited for illicit purposes.

The maximum bet of €5 applicable during an active bonus, the 5x cashout ceiling on bonus amounts, and the 30-day activation and 3-day wagering-clearance windows all serve both player-protection and AML functions: they limit the speed and volume of funds that can be cycled through a bonus account in any short period.

12. Staff Training

All betoranje personnel with access to player account data or financial systems receive AML and KYC training at induction and on a regular basis thereafter. Training covers the identification of suspicious behaviour, the internal reporting process, tipping-off prohibitions, record-keeping obligations, and the specific risks associated with online gaming and cryptocurrency transactions. The MLRO is responsible for maintaining and updating the training programme in line with evolving regulatory standards and emerging typologies.

13. Player Responsibilities

Players have a responsibility to cooperate with betoranje's compliance procedures. Specifically, every player at bets-oranje.com agrees to:

Provide accurate, complete, and up-to-date registration information at all times
Submit requested KYC documentation promptly and in the format specified
Play only with funds that belong to them and have been obtained through lawful means
Not allow any third party to use their account or to deposit or withdraw funds on their behalf
Not attempt to exploit the platform's payment infrastructure or bonus system for the purpose of laundering funds
Notify betoranje of any material change in their personal circumstances that may be relevant to their risk profile (e.g., a change in PEP status)

Breach of any of the above obligations constitutes a violation of betoranje's Terms and Conditions and may result in account suspension, permanent closure, forfeiture of balances, and referral of the matter to relevant authorities.

14. Responsible Gambling and AML Interaction

betoranje's responsible gambling framework and its AML programme are complementary. A player who is gambling beyond their apparent means, making erratic deposits, or showing signs of problem gambling may also present an elevated AML risk — for example, where funds cannot be attributed to a plausible source of income. betoranje's compliance and player-protection teams work in coordination to ensure that accounts flagged by either system receive appropriate attention.

Players who wish to set deposit limits, take a cooling-off period, or self-exclude are encouraged to contact betoranje's 24/7 support team via live chat or email. Such tools are available in English and Dutch to serve the player communities betoranje operates within.

15. Policy Updates

This Policy is reviewed and updated on a regular basis to reflect changes in international AML standards, emerging financial crime typologies, and developments in the payment and gaming environment — including the continued evolution of cryptocurrency markets. The most current version of this Policy is always available at bets-oranje.com. By continuing to use the platform after an updated Policy has been published, players confirm their acceptance of the revised terms.

16. Contact and Compliance Enquiries

Players with questions about this Policy, the status of their verification, or any compliance matter may contact betoranje's support team at any time:

Live chat: Available 24/7 via bets-oranje.com, in English and Dutch
Email: Available through the contact details published in the Help section of bets-oranje.com

Compliance correspondence will be handled with appropriate confidentiality. betoranje does not disclose the existence or content of any SAR or related investigation to the subject of that report.