Brutal Casino

This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Brutal Casino, operated by Santeda International B.V. under Curaçao Gaming Authority licence OGL/2024/1798/1048, with respect to the detection, prevention and reporting of money laundering, terrorist financing and related financial crime. All players registering at brutal-casino.co are bound by this Policy as a condition of account use and access to casino, sportsbook and eSports services.

1. Introduction and Legal Basis

Santeda International B.V. ("the Operator", "we", "us") is committed to conducting its business in full compliance with applicable anti-money laundering ("AML") and counter-terrorist financing ("CTF") legislation, the requirements of the Curaçao Gaming Authority, and internationally recognised standards including those published by the Financial Action Task Force (FATF). This Policy is reviewed and updated on a regular basis to reflect changes in applicable law, regulatory guidance and operational practice.

Money laundering is broadly defined as the process by which the proceeds of criminal activity are disguised to appear as legitimately obtained funds. Terrorist financing involves the provision or collection of funds intended to be used to carry out terrorist acts. Brutal Casino maintains a zero-tolerance position towards both and will take all reasonable steps to ensure that the platform at brutal-casino.co is not used to facilitate either.

2. Scope

This Policy applies to:

3. Appointed Compliance Function

The Operator has designated a Money Laundering Reporting Officer ("MLRO") responsible for overseeing compliance with this Policy, receiving and evaluating internal suspicion reports, filing external reports with the appropriate authorities where required, and maintaining AML/CTF training records. The MLRO has unrestricted access to all relevant transaction and account data held by Brutal Casino and reports directly to senior management of Santeda International B.V.

4. Know Your Customer (KYC) — Overview

Brutal Casino applies a risk-based KYC framework to verify the identity of players, assess the source of their funds where necessary, and monitor ongoing account activity for unusual or suspicious patterns. KYC checks are a legal requirement and also serve to protect players from identity fraud and financial crime. Completion of required KYC verification is a prerequisite for the processing of any withdrawal from brutal-casino.co, including crypto withdrawals, and affects access to certain promotional features such as the daily login bonus which is tied to KYC status.

5. Customer Due Diligence (CDD)

5.1 Standard CDD

Standard Customer Due Diligence is applied to all players at the point of registration and, at the latest, before any withdrawal is processed. The minimum withdrawal amount at brutal-casino.co is €20 and payouts are processed within up to three banking days following successful verification. Standard CDD requires the player to provide:

5.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied in circumstances where the standard risk assessment identifies an elevated risk of money laundering or terrorist financing, or where the volume or pattern of transactions warrants further scrutiny. EDD may be triggered by, but is not limited to, the following circumstances:

Under EDD, the Operator may request one or more of the following:

The Operator reserves the right to restrict access to withdrawals, bonuses (including the welcome package of up to €5,500 across three deposits, the crypto welcome offer, the sports welcome offer and the eSports welcome offer) and gameplay pending satisfactory completion of EDD. Failure to provide requested documentation within a reasonable timeframe will result in account suspension and may result in permanent closure.

6. Politically Exposed Persons (PEPs), Sanctions and Adverse Media

Brutal Casino screens all players against recognised PEP lists, international sanctions lists (including those maintained by the UN, EU, OFAC and HM Treasury), and adverse media databases at the point of registration and on an ongoing basis. A Politically Exposed Person is an individual who holds or has held a prominent public function, or is a close associate or family member of such a person.

Players identified as PEPs are automatically subject to Enhanced Due Diligence, require senior management approval for the establishment or continuation of a business relationship, and are subject to ongoing monitoring at a heightened frequency. Players who are the subject of active sanctions will be refused registration or have their accounts suspended and funds frozen pending legal advice and, where required, reporting to the relevant authority. Adverse media results are assessed on a case-by-case basis by the compliance function.

7. Ongoing Transaction Monitoring

All accounts at brutal-casino.co are subject to continuous automated and manual transaction monitoring. The purpose of this monitoring is to identify patterns of activity that are inconsistent with a player's stated profile or that exhibit characteristics commonly associated with money laundering or fraud. Monitored indicators include but are not limited to:

Where a monitoring alert is generated, the account is referred to the compliance function for manual review. The Operator may request further documentation, temporarily restrict account functionality or escalate the matter to the MLRO for assessment.

8. Suspicious Activity Reporting

Where the MLRO concludes, following review, that there are reasonable grounds to know or suspect that a transaction or pattern of activity is related to money laundering or terrorist financing, a Suspicious Activity Report ("SAR") will be filed with the relevant Financial Intelligence Unit ("FIU") or competent authority as required by applicable law. The existence of a SAR, or any investigation associated with it, will not be disclosed to the player concerned. Tipping off a player that a SAR has been filed, or that they are under investigation, is a criminal offence and Brutal Casino strictly prohibits it.

Players and staff who make a good-faith report of suspected money laundering or terrorist financing are protected from retaliation. Internal reports by staff should be directed to the MLRO via the designated internal reporting channel.

9. Record Keeping

Brutal Casino retains all KYC documentation, transaction records, account history, monitoring alerts and SAR-related materials for a minimum period of five (5) years from the date of the most recent transaction or the closure of the account, whichever is later. Records are stored securely in accordance with applicable data protection legislation. Where a longer retention period is required by law or regulatory instruction, that longer period shall apply.

Retained records include:

10. Risk-Based Approach

The Operator applies a risk-based approach to AML/CTF compliance. This means that the level of scrutiny applied to any given player or transaction is proportionate to the assessed risk. Risk factors considered include the player's country of residence, the payment methods used, the currencies involved (including the specific cryptocurrencies available at brutal-casino.co), the nature and volume of gameplay across slots, crash titles, live casino, sportsbook, eSports and virtual sports, and any information provided during registration or KYC review.

The Operator maintains a risk assessment framework that is reviewed at least annually and updated in response to regulatory guidance, emerging typologies and changes to the platform's product or payment offering.

11. Prohibited Activities

The following activities are strictly prohibited at brutal-casino.co and will result in immediate account suspension, forfeiture of any bonus funds (including all tiers of the welcome package), withholding of pending withdrawals pending investigation, and referral to the relevant authorities:

12. Responsible Gambling and AML Interaction

Brutal Casino's responsible gambling framework and its AML/KYC programme operate in parallel. Indicators of problem gambling — such as sudden large deposits inconsistent with prior account behaviour — may also constitute AML risk indicators and will be reviewed under both frameworks simultaneously. Players who set deposit limits, loss limits or self-exclusions via the responsible gambling tools available at brutal-casino.co will have those restrictions enforced regardless of any open KYC or AML review.

Responsible gambling support is available at any time via the 24/7 live chat service and email support. Players requiring assistance can also contact independent organisations such as GamCare, Gamblers Anonymous and BeGambleAware.

13. Staff Training

All relevant personnel employed by or acting on behalf of Santeda International B.V. in connection with the operation of brutal-casino.co receive AML/CTF training appropriate to their role. Training covers recognition of suspicious activity, KYC and CDD obligations, the internal reporting procedure, tipping-off restrictions and record-keeping requirements. Training is conducted at induction and refreshed on a regular basis, or sooner where significant regulatory developments make earlier updating necessary. Training records are maintained by the MLRO.

14. Third-Party Relationships

Where the Operator relies on third-party service providers for identity verification, payment processing (including the processing of card transactions via Visa and Mastercard, e-wallet services, bank transfers, and cryptocurrency transactions), or game provision, those third parties are subject to due diligence prior to engagement and ongoing monitoring. Reliance on a third party for any element of the KYC process does not diminish the Operator's own AML/CTF obligations. Ultimate responsibility for compliance with this Policy rests with Santeda International B.V.

15. Player Cooperation and Consequences of Non-Compliance

Players are required to cooperate fully and promptly with all KYC and AML requests made by the Operator. This includes providing accurate and complete information at registration, supplying requested documentation within the timeframe specified, and notifying brutal-casino.co promptly of any material change in circumstances such as a change of address, payment method or source of funds.

Where a player fails to provide requested documentation, provides documentation the Operator reasonably believes to be false or fraudulent, or otherwise obstructs the KYC or AML process, Brutal Casino reserves the right to:

16. Changes to This Policy

Santeda International B.V. reserves the right to amend this Policy at any time in response to changes in applicable law, regulatory guidance, or operational requirements. The current version of this Policy is always available at brutal-casino.co. Continued use of the site following the publication of any amendment constitutes acceptance of the updated Policy. Where a change is material, we will take reasonable steps to notify registered players.

17. Contact

If you have questions about this Policy, require clarification on the KYC process, or wish to submit documentation, please contact the Brutal Casino compliance team via:

Correspondence relating to AML or KYC matters will be handled in confidence by the compliance function and, where appropriate, escalated to the MLRO.