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This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Zephyr Holding Sociedad de Responsabilidad Limitada ("we", "us", "our"), operator of inky at casino-inky.com, in relation to the prevention of money laundering, terrorist financing, and other financial crime. inky is licensed by the Anjouan Offshore Financial Authority. All persons who register or transact on casino-inky.com ("you", "the Player") are bound by this Policy, which forms part of our Terms and Conditions.

1. Introduction and Purpose

Money laundering is the process by which criminally obtained funds are introduced into the legitimate financial system and made to appear lawful. Terrorist financing involves the provision or collection of funds intended for use in acts of terrorism. Both activities cause serious harm to individuals, businesses, and society at large.

inky is committed to ensuring that casino-inky.com is not used, directly or indirectly, as a vehicle for money laundering, terrorist financing, fraud, or any other financial crime. This Policy establishes the framework of controls, procedures, and responsibilities through which we fulfil that commitment, in accordance with the standards required by our licence under the Anjouan Offshore Financial Authority and applicable international best practice.

The objectives of this Policy are to:

2. Scope

This Policy applies to:

This Policy should be read alongside our Privacy Policy, Terms and Conditions, Responsible Gambling Policy, and Bonus Terms, all of which are published on casino-inky.com.

3. Regulatory and Legal Framework

inky operates under a licence granted by the Anjouan Offshore Financial Authority. Our AML and KYC controls are designed and maintained in accordance with the requirements of that licence and with reference to internationally recognised standards, including the recommendations of the Financial Action Task Force (FATF). We do not hold a licence issued by the Dutch Kansspelautoriteit (KSA). Players resident in the Netherlands access casino-inky.com as an offshore platform and are solely responsible for verifying that their use of the site is lawful in their jurisdiction.

4. Know Your Customer (KYC) — Overview

KYC is the process by which inky verifies the identity of its players, confirms the legitimacy of their source of funds, and assesses the risk profile of the relationship. KYC is an ongoing obligation, not a one-time check. Our procedures are designed to be proportionate to risk while ensuring no withdrawal is processed before the identity of the player has been fully verified.

4.1 When KYC Is Triggered

At inky, account registration requires only a name, email address, date of birth, and currency selection. However, KYC verification is mandatory and must be completed before we will process any withdrawal. In addition, we reserve the right to request KYC documentation at any point during a player's lifecycle on the platform, including but not limited to:

Players should be aware that submitting a withdrawal request before completing KYC will not result in funds being released. The withdrawal queue will remain on hold until all requested documentation has been reviewed and approved.

4.2 Standard KYC Documentation

To satisfy our standard KYC requirements, you must provide all of the following:

The details on all documents submitted must be consistent with one another and with the information held in your inky account. Documents where names, addresses, or dates of birth do not match across all sources will not be accepted, and additional documentation may be requested to resolve discrepancies.

4.3 Enhanced Due Diligence (EDD)

In certain circumstances, standard KYC documentation is insufficient and we will apply Enhanced Due Diligence (EDD). EDD may be triggered by, but is not limited to, the following:

Where EDD applies, we may request one or more of the following in addition to standard KYC documents:

Failure to provide EDD documentation within the timeframe stipulated by our compliance team may result in suspension of your account and/or withholding of funds pending investigation.

4.4 Ongoing Monitoring

KYC is not a one-off event. We continuously monitor player accounts and transactional behaviour throughout the lifetime of the relationship. Ongoing monitoring includes:

5. Customer Identification — Registration and Account Controls

5.1 Registration Requirements

To create an account on casino-inky.com, you must provide your full name, email address, and date of birth, and confirm that you are 18 years of age or older. You must also select your account currency at the point of registration. Euro (EUR) is the default currency; cryptocurrency accounts are maintained separately. You may not hold more than one account on casino-inky.com. The creation of duplicate accounts is prohibited and constitutes grounds for account closure and forfeiture of funds.

5.2 Age Verification

inky accepts players aged 18 and over only. You are required to confirm your age at registration by ticking the relevant declaration. Age verification is conducted as part of the KYC process, and no withdrawal will be processed until your date of birth has been confirmed against an acceptable identity document. Where we have reason to suspect that a player may be underage, the account will be suspended immediately pending verification. In the event that age verification reveals a player to be under 18, the account will be closed, all funds will be withheld, and the matter may be reported to the relevant authority.

5.3 Accurate Account Information

You are responsible for ensuring that all information provided to inky at registration and at any subsequent point is accurate, complete, and up to date. If any of your personal details change — including your name following a legal change, your residential address, or your contact information — you must notify our support team promptly at [email protected] or via 24/7 live chat. Providing false or misleading information is grounds for immediate account closure and may constitute a criminal offence.

6. Payment Methods, Deposits, and Withdrawals

6.1 Accepted Methods and Transaction Limits

inky accepts a range of fiat and cryptocurrency payment methods. The minimum deposit on casino-inky.com is €20. The minimum withdrawal for fiat payment methods is €40. The standard monthly withdrawal cap for non-jackpot winnings is €15,000, though this limit is adjustable upwards for players at higher VIP levels, subject to satisfactory completion of any additional due diligence that such limits may trigger.

Cryptocurrency withdrawals are processed with an average completion time of 9 minutes and 35 seconds, as displayed on the casino-inky.com homepage. The speed of crypto payouts does not reduce or waive KYC obligations; all withdrawals, regardless of method, require a verified account.

6.2 Payment Method Consistency

As a core principle of our AML controls, inky requires that:

6.3 Cryptocurrency Transactions

Cryptocurrency accounts on casino-inky.com are maintained separately from fiat accounts. Players using cryptocurrency payment methods remain subject to the same KYC and AML obligations as fiat players. We reserve the right to request evidence of the origin of any cryptocurrency funds, including blockchain transaction records and wallet ownership confirmation, where this is considered necessary for AML purposes.

We do not accept deposits from anonymous or privacy-enhanced cryptocurrencies, mixers, tumblers, or any source that prevents us from conducting appropriate due diligence on the origin of funds.

6.4 Suspicious Transaction Monitoring

Our systems monitor all deposits, withdrawals, and in-play transactions for indicators of suspicious activity. Patterns that may give rise to concern include, but are not limited to:

7. Politically Exposed Persons (PEPs) and Sanctions Screening

7.1 Politically Exposed Persons

A Politically Exposed Person is an individual who holds, or has held within the last 12 months, a prominent public position, or who is a close family member or known associate of such a person. PEPs are considered to present a higher risk of involvement in bribery and corruption.

All players are screened against PEP databases at registration and on an ongoing basis. Where a player is identified as a PEP, their account will be subject to Enhanced Due Diligence as described in section 4.3 of this Policy. Senior management approval is required before a business relationship with a PEP is established or continued.

7.2 Sanctions Screening

inky screens all players and transactions against applicable international sanctions lists, including those published by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and His Majesty's Treasury. Players who appear on any applicable sanctions list, or who are resident in a sanctioned jurisdiction, will have their accounts immediately suspended and relevant funds frozen pending further action. We will report any matches to the appropriate authority as required.

8. Suspicious Activity and Reporting

8.1 Internal Reporting

All employees and contractors of Zephyr Holding Sociedad de Responsabilidad Limitada who identify or suspect money laundering, terrorist financing, or other financial crime must report their concerns to the designated Money Laundering Reporting Officer (MLRO) without delay. Internal reports must not be communicated to the player in question, as doing so could constitute the criminal offence of "tipping off".

8.2 External Reporting

Where the MLRO determines that a Suspicious Activity Report (SAR) is warranted, the report will be submitted to the relevant financial intelligence unit or competent authority in accordance with applicable legal obligations. Where a SAR has been filed, inky may be required by law to freeze the relevant account and withhold associated funds pending guidance from the authority. We are not obliged to inform the player that a SAR has been made, and doing so is expressly prohibited.

8.3 No Tipping Off

Neither inky staff nor any player who becomes aware of a suspicious activity investigation may communicate that fact to the subject of the investigation. Any breach of this requirement may constitute a criminal offence and will result in immediate termination of employment or account closure, as applicable.

9. Record Keeping

inky maintains comprehensive records in connection with its AML and KYC obligations. Records retained include:

All records are retained for a minimum of five years from the date of the relevant transaction or the end of the customer relationship, whichever is the later, or for such longer period as may be required by our licensing authority or applicable law. Records are stored securely and in accordance with our Privacy Policy.

10. Bonus and Promotional Activity — AML Considerations

The bonus and promotional structure at inky — including the casino welcome track (325% up to €3,000 + 150 Free Spins), the live casino welcome track (up to €3,750 across three deposits), and the sports welcome track (200% up to €1,250 across two deposits), as well as ongoing reload bonuses, daily cashback, and rakeback — is designed for genuine recreational players. These promotions are subject to wagering requirements and other conditions that are incompatible with the use of bonus funds for money-laundering purposes.

Nonetheless, we monitor bonus and promotional activity for signs of abuse or misuse that may indicate financial crime, including:

Where such activity is identified, the account will be reviewed, bonuses may be voided, and the matter may be escalated for AML investigation. The standard bonus rule that a withdrawal request voids any active bonus balance is not affected by any AML hold placed on the account; funds subject to an AML investigation may be withheld regardless of bonus status.

11. VIP Programme and High-Value Players

The inky VIP programme offers enhanced benefits at each tier, including increased monthly withdrawal caps beyond the standard €15,000 non-jackpot limit and higher cashback rates (rising from 3% at entry level to 20% at the top tier). Players at the upper tiers of the VIP programme, including those working towards the top-tier prize of a Porsche Cayenne, are subject to proportionately enhanced due diligence.

Any adjustment to a player's monthly withdrawal cap will trigger a review of that player's source of funds and source of wealth. Approval of an enhanced withdrawal limit is conditional on satisfactory completion of EDD and, where applicable, senior management sign-off. Players who are unwilling or unable to provide the documentation required to support enhanced limits will not have their caps increased.

12. Responsible Gambling and AML Interaction

Our AML monitoring and our responsible gambling controls operate in parallel and are mutually reinforcing. Patterns of play that indicate problem gambling — such as rapidly escalating stakes, chasing losses, or extreme session lengths — may also be relevant from an AML perspective and will be reviewed accordingly. Where responsible gambling measures are applied to an account, including self-exclusion or deposit limits, those measures will remain in place irrespective of any AML investigation and vice versa. Players must be 18 or older to hold an account on casino-inky.com.

13. Staff Training

All employees and contractors of Zephyr Holding Sociedad de Responsabilidad Limitada who are involved in player-facing activity, payment processing, or compliance functions receive AML and KYC training appropriate to their role. Training covers the recognition of suspicious activity indicators, the correct process for internal reporting, record-keeping obligations, the prohibition on tipping off, and the specific risks associated with the online gambling sector. Training records are maintained and refreshed regularly.

14. Player Obligations

By registering on casino-inky.com, you agree to:

Failure to comply with any of the above obligations may result in account suspension, forfeiture of funds, and/or reporting to the relevant authority.

15. Consequences of Non-Compliance

Where a player fails to complete KYC, provides false or misleading documentation, or is found to have used casino-inky.com in connection with financial crime, inky reserves the right to take one or more of the following actions:

16. Policy Review and Updates

This Policy is reviewed periodically by the compliance function of Zephyr Holding Sociedad de Responsabilidad Limitada and updated as necessary to reflect changes in applicable law, regulatory guidance, or our internal risk assessment. The current version of this Policy is published on casino-inky.com and supersedes all previous versions. Continued use of casino-inky.com following the publication of an updated Policy constitutes acceptance of its terms.

17. Contact

If you have any questions about this Policy, or if you wish to submit KYC documentation or raise a compliance concern, please contact us using the following channels:

This Policy was last reviewed in August 2026. Zephyr Holding Sociedad de Responsabilidad Limitada reserves the right to amend this Policy at any time. Any material changes will be communicated to registered players via the contact details held on their account.