AML Policy
1Win N.V. (company no. 147039, registered in Curaçao) operates under Curaçao eGaming License 8048/JAZ2018-040. This Anti-Money Laundering (AML) Policy sets out the operator's commitment to preventing money laundering, terrorist financing, and other financial crimes. The policy applies to all players, transactions, and business relationships conducted through the domain slideapp.pk and associated platforms. Compliance with this policy is mandatory for all players and staff.
Legal Framework and Regulatory Scope
1Win operates under the Curaçao eGaming regulatory framework, which incorporates standards aligned with the Financial Action Task Force (FATF) Recommendations on combating money laundering and terrorist financing. The operator maintains compliance with international best practices, including principles derived from the Fifth and Sixth Anti-Money Laundering Directives (5AMLD/6AMLD) of the European Union, to the extent applicable to offshore gaming operations. All AML procedures are designed to detect and prevent the use of the platform for money laundering, terrorist financing, sanctions evasion, and other financial crimes.
Customer Due Diligence (CDD)
Before you open an account or place your first deposit, you must complete Customer Due Diligence verification. This process is mandatory and is designed to establish your identity and assess the risk profile of your account.
- You must provide your full legal name, date of birth, and residential address.
- You must submit a valid government-issued photo identification document (passport, national ID card, or driving licence).
- You must provide proof of address dated within the last three months (utility bill, bank statement, or official correspondence).
- You must declare the source of funds used for deposits.
- You must confirm that you are not a Politically Exposed Person (PEP) or a relative of a PEP.
- All documents must be clear, legible, and in English or accompanied by a certified translation.
Enhanced Due Diligence (EDD)
Certain players are subject to Enhanced Due Diligence procedures due to elevated risk factors. If you fall into any of the following categories, you may be required to provide additional information and documentation:
- Politically Exposed Persons (PEPs) — individuals holding or having held prominent public positions, or their close family members.
- High-value players — accounts with cumulative deposits exceeding ~PKR 500,000 or equivalent in a rolling 12-month period.
- High-transaction-frequency players — accounts with more than 100 transactions per month.
- Players from high-risk jurisdictions as identified by the FATF or international sanctions lists.
- Players with unclear or inconsistent source of funds declarations.
- Players engaging in structuring or other patterns indicative of money laundering.
Enhanced Due Diligence may include requests for additional documentation, source of wealth verification, beneficial ownership information, and ongoing transaction monitoring at an elevated threshold.
Transaction Monitoring and Suspicious Activity Detection
1Win employs automated transaction monitoring systems to detect patterns and activities that may indicate money laundering, terrorist financing, or other financial crimes. Monitoring is conducted on an ongoing basis and covers all deposits, withdrawals, and in-game transfers.
- Structuring — multiple deposits below reporting thresholds designed to avoid detection.
- Rapid deposit-and-withdrawal cycles without meaningful gameplay.
- Unusually large transactions inconsistent with the player's profile or declared source of funds.
- Transactions involving high-risk jurisdictions or sanctioned entities.
- Round-tripping — deposits immediately withdrawn without gaming activity.
- Use of multiple accounts or payment methods to obscure transaction patterns.
- Transactions inconsistent with the player's stated occupation or income level.
If suspicious activity is detected, your account may be frozen pending investigation. You will be notified of any account restrictions in accordance with applicable law.
Reporting Obligations
1Win is obligated to report suspicious transactions and activities to the relevant Financial Intelligence Unit (FIU) in accordance with Curaçao eGaming regulations and international AML standards. Suspicious Activity Reports (SARs) are filed without prior notification to the player, as required by law. The operator may also be required to file Currency Transaction Reports (CTRs) or other regulatory filings as mandated by the licensing jurisdiction.
Record Keeping and Data Retention
1Win maintains comprehensive records of all customer identification documents, transaction histories, and AML-related communications. Records are retained for a minimum of five years following the closure or termination of your account, or longer if required by law or ongoing investigations.
- Customer identification and verification documents.
- Account opening documentation and CDD/EDD records.
- All deposits, withdrawals, and in-game transactions.
- Correspondence relating to source of funds or beneficial ownership.
- Suspicious activity reports and investigation outcomes.
- Sanctions and PEP screening results.
Money Laundering Reporting Officer (MLRO)
1Win has appointed a Money Laundering Reporting Officer (MLRO) responsible for overseeing AML compliance, investigating suspicious activities, and filing reports with the relevant FIU. The MLRO reports directly to senior management and the board of directors. Staff members may report suspected money laundering or financial crimes to the MLRO through secure, confidential channels. The operator maintains a whistleblower policy to protect staff who report suspected violations in good faith.
Sanctions and PEP Screening
All players are screened against international sanctions lists, including those maintained by the United Nations, the European Union, the United States Office of Foreign Assets Control (OFAC), and other relevant authorities. Players are also screened to identify Politically Exposed Persons and their close associates. Screening is conducted at account opening and on an ongoing basis. If you are identified as a sanctioned individual or entity, your account will be immediately frozen and appropriate authorities will be notified.
Staff Training and Awareness
All 1Win employees involved in customer-facing operations, account management, payments processing, and compliance receive mandatory AML training on an annual basis. Training covers the identification of suspicious activities, customer due diligence procedures, reporting obligations, and sanctions compliance. Staff are required to maintain confidentiality regarding AML investigations and suspicious activity reports.
Your Responsibilities as a Player
You are responsible for providing accurate, complete, and truthful information during account registration and verification. You must:
- Provide your true legal name, date of birth, and residential address.
- Submit genuine, unaltered identification and proof-of-address documents.
- Declare the true source of all funds deposited into your account.
- Notify 1Win immediately if any of your personal information changes.
- Comply with all requests for additional documentation or clarification.
- Not attempt to circumvent or interfere with AML screening or transaction monitoring systems.
- Not use your account for the benefit of third parties or to facilitate money laundering.
Providing false information, submitting forged documents, or engaging in structuring or other evasion tactics constitutes a breach of this policy and may result in account closure, forfeiture of funds, and referral to law enforcement authorities.
Account Closure and Fund Forfeiture
1Win reserves the right to close your account and forfeit any remaining balance if you are found to have violated this AML Policy, provided false information, engaged in suspicious activity, or been identified as a sanctioned individual. Account closure may occur without prior notice if required by law or to prevent financial crime. You will be notified of the closure and the reasons for it in accordance with applicable regulations.
Contact and Queries
If you have questions regarding this AML Policy or your verification status, you may contact 1Win support at any time. Support is available 24/7 in English and Urdu. Payment processing is handled by MFI Investments Limited (Cyprus, HE386738), which maintains its own AML compliance framework in accordance with Cypriot and international regulations.