This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Stellar Ltd ("the Operator"), which operates Spinbara Casino at spinbarra.fr, to prevent money laundering, terrorist financing, and other financial crime. Spinbara is dual-licensed under the Anjouan ALSI (licence no. 202412012, FI1) and Curaçao eGaming authority. Compliance with this Policy is mandatory for all players, and the Operator reserves the right to suspend or close any account and to withhold funds where a breach is identified or suspected.
Stellar Ltd operates Spinbara in accordance with the anti-money laundering and counter-terrorist financing ("AML/CTF") requirements imposed by its licensing authorities: the Anjouan Licensing Services International (ALSI) and the Curaçao eGaming Regulatory Board. The Operator maintains written AML/CTF procedures, appoints a designated compliance officer, and conducts periodic internal reviews to ensure that controls remain effective and up to date.
This Policy applies to all financial activity conducted through spinbarra.fr, including deposits made via Visa, Mastercard, Skrill, Neteller, PayPal, MiFinity, Trustly, Paysafecard, Neosurf, bank transfer, and all accepted cryptocurrencies (Bitcoin, Ethereum, Litecoin, USDT, USDC, XRP, BNB, and TRX), as well as all withdrawals processed through those same channels.
This Policy applies to:
For the purposes of this Policy, money laundering is defined as the process by which the proceeds of criminal activity are disguised to appear as legitimate funds. This includes placement (introducing illicit funds into the financial system), layering (concealing the origin of those funds through multiple transactions or transfers), and integration (reintroducing laundered funds into the legitimate economy).
Terrorist financing refers to the provision or collection of funds, by any means, with the intention that they be used, or in the knowledge that they are to be used, in full or in part, to carry out terrorist acts or to benefit terrorist organisations, regardless of whether the funds themselves are of legitimate or criminal origin.
Using a gambling account to facilitate either process is strictly prohibited and will result in immediate account suspension, reporting to relevant authorities, and forfeiture of any funds held.
KYC procedures enable the Operator to verify that each player is who they claim to be, that they are of legal gambling age, that their source of funds is legitimate, and that they do not appear on any sanctions, politically exposed persons (PEP), or adverse-media lists. KYC is not optional — it is a regulatory obligation and a condition of maintaining an active account at spinbarra.fr.
The Operator may request KYC documentation at any of the following points:
In practice, players should expect to complete full verification before their first withdrawal is released. Delays in submitting valid documentation will result in delays to withdrawal processing. The Operator will not be liable for any such delays where they arise from a player's failure to provide documentation promptly.
Players are required to provide clear, legible copies of the following documents. All documents must be in date, unaltered, and show the player's details clearly. The Operator reserves the right to request certified copies where the quality of submitted documents is insufficient.
Where standard KYC is insufficient, or where risk factors indicate a heightened level of scrutiny is appropriate, the Operator will apply Enhanced Due Diligence. EDD may be triggered by any of the following circumstances:
Under EDD, the Operator may require one or more of the following in addition to standard documents:
The Operator will not process withdrawals and may restrict gameplay on an account while EDD is outstanding.
Stellar Ltd applies a risk-based approach to customer due diligence, meaning that the level of scrutiny applied to any individual account is proportionate to the assessed risk that account poses for money laundering, terrorist financing, or related financial crime. All accounts are assigned a risk rating — low, medium, or high — at onboarding and reassessed continuously throughout the customer lifecycle.
Factors considered in determining risk rating include, but are not limited to:
Low-risk accounts will receive simplified due diligence. Medium- and high-risk accounts will receive standard or enhanced due diligence as appropriate. Risk classifications are reviewed at regular intervals and may be upgraded at any time in response to new information or changes in behaviour.
KYC is not a one-time event. The Operator conducts continuous monitoring of all active accounts to detect changes in player behaviour that may indicate money laundering, fraud, or account misuse. Monitoring systems flag, for manual review, any transactions or patterns that meet internal alert criteria.
Activities that are likely to trigger enhanced monitoring include:
Where ongoing monitoring produces a concern, the Operator may pause withdrawals, request updated documentation, or escalate the matter to its compliance officer for assessment and potential reporting.
Spinbara operates a strict same-name policy. This means that all funds deposited into a player account must originate from a payment method registered in that player's own name. Equally, all withdrawals will be returned exclusively to the payment method from which the deposit was made, or to a verified method held in the player's own name.
The following are strictly prohibited:
In respect of cryptocurrency specifically — Bitcoin, Ethereum, Litecoin, USDT, USDC, XRP, BNB, and TRX are all accepted at spinbarra.fr — the Operator reserves the right to conduct blockchain analysis on incoming and outgoing transactions. Where funds are identified as having originated from, or being destined for, a sanctioned address, darknet marketplace, or other high-risk source, the Operator will suspend the relevant transaction, freeze the account, and report the matter to the applicable authority. Crypto-to-fiat or fiat-to-crypto conversion solely for the purpose of circumventing standard AML checks is also prohibited.
All new players are screened against applicable international sanctions lists at the point of registration, and all accounts are subject to ongoing rescreening as those lists are updated. Sanctions lists consulted include those maintained by the United Nations, the European Union, the Office of Financial Sanctions Implementation (OFSI), and the United States Office of Foreign Assets Control (OFAC), as well as any lists specified by the Operator's licensing authorities.
Politically exposed persons (PEPs) — defined as individuals who hold, or have held within the previous twelve months, prominent public office, together with their family members and known close associates — are subject to mandatory Enhanced Due Diligence before any account is approved or any significant transaction is processed. The Operator does not automatically refuse service to PEPs, but the level of scrutiny applied to such accounts will be considerably higher than that applied to standard accounts.
Where a sanctions match is identified, the Operator is legally required to freeze any associated funds and to report the matter to the relevant authority without notifying the customer ("tipping off" is prohibited under applicable legislation).
The Operator's compliance officer is responsible for receiving and evaluating internal suspicious activity reports generated by the monitoring systems or by members of the compliance team. Where there are reasonable grounds to suspect that funds held in, or transacted through, a Spinbara account are connected to money laundering or terrorist financing, the Operator is required by law to submit a Suspicious Activity Report (SAR) to the relevant financial intelligence unit.
The Operator, its directors, officers, employees, and contractors are prohibited from tipping off any player or third party that a SAR has been filed, or that a player is under investigation. Doing so constitutes a serious criminal offence.
Players whose accounts are subject to a SAR or related investigation should be aware that funds held in those accounts may be frozen for an indefinite period pending the outcome of any enquiry, without the Operator being in a position to provide reasons.
Players should submit KYC documents via the account verification section of spinbarra.fr, or by sending documents to the support team at [email protected]. The following timelines apply once documents are received:
| Verification Stage | Typical Processing Time |
|---|---|
| Initial identity and address check | 24–72 hours |
| Payment method verification | 24–48 hours |
| Enhanced due diligence review | Up to 14 business days |
| Document resubmission (if required) | Clock resets upon receipt of corrected documents |
Withdrawals will not be processed until all required verification is complete. The Operator will communicate with players via their registered email address if additional documents are needed. Players are strongly encouraged to complete verification proactively rather than waiting until a withdrawal is requested, in order to avoid delays.
The Operator reserves the right to refuse, reverse, or withhold any deposit or withdrawal where:
Where funds are returned, they will be sent to the original payment source where technically possible. The Operator will not be liable for any losses arising from a refusal to process a transaction where that refusal is made in good faith in accordance with this Policy.
Spinbara recognises that problem gambling and money laundering controls are closely interlinked: both require the Operator to monitor player behaviour for signs that something is wrong, and both may require the Operator to intervene. Players who display signs of gambling harm — including sudden large deposits, attempts to deposit beyond normal patterns, or requests to reverse pending withdrawals — may be referred to the responsible gambling team as well as reviewed from an AML perspective.
Players can access responsible gambling tools through their account, including deposit limits, loss limits, session limits, cooling-off periods, and self-exclusion. These tools are available to all registered players and do not affect a player's KYC status. If you wish to discuss your account or any responsible gambling concern, the support team is available 24 hours a day via live chat or by email at [email protected].
Any player found to have breached this Policy, or to have attempted to circumvent the Operator's AML/CTF controls, will be subject to one or more of the following actions:
The Operator will cooperate fully with any investigation conducted by a competent authority and will provide all documentation, transaction records, and account data as required by law.
Stellar Ltd retains all customer identification records, transaction data, and AML-related documentation for a minimum period of five years from the date the relevant account is closed or the relevant transaction is completed, whichever is later. Records are held securely and in accordance with applicable data protection law. Players who wish to understand how their personal data is used should refer to the Spinbara Privacy Policy, available at spinbarra.fr.
All employees and contractors of Stellar Ltd who are involved in the processing of player accounts, transactions, or compliance functions receive mandatory AML/CTF training at the point of induction and on an ongoing basis. Training covers the recognition of suspicious activity, the correct procedure for filing an internal suspicious activity report, tipping-off prohibitions, and the consequences of non-compliance. The Operator's compliance officer maintains records of all training completed.
Internal AML controls are reviewed at least annually, and following any material change to the Operator's business, the regulatory environment, or identified risk factors. The results of internal reviews are documented and acted upon by senior management.
This Policy is reviewed regularly and updated as required to reflect changes in applicable law, regulatory guidance, licensing conditions, or the Operator's internal risk assessment. The current version is always available at spinbarra.fr. Continued use of the Spinbara platform following any update to this Policy constitutes acceptance of the revised terms. Where a change materially affects players' rights or obligations, the Operator will notify registered players by email where reasonably practicable.
Queries relating to this Policy, KYC verification requirements, or AML compliance should be directed to the Spinbara compliance and support team:
This Policy was last reviewed in 2025. Spinbara is committed to maintaining the highest practicable standards of financial integrity and to ensuring that spinbarra.fr remains a safe, transparent, and compliant environment for all players.
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