Spacehills Casino – Anti-Money Laundering (AML) Policy

Spacehills is committed to maintaining the highest standards of integrity, transparency, and legal compliance. This Anti-Money Laundering (AML) Policy explains the measures we have implemented to prevent, detect, and report money laundering and terrorist financing in accordance with United Kingdom law.

Use of the Spacehills platform constitutes acceptance of the practices outlined in this policy.

Objectives of the AML Policy

The objectives of this AML Policy are to:

• Prevent the use of Spacehills for money laundering or terrorist financing
  • Comply fully with AML legislation and regulatory guidance
  • Protect the integrity, reputation, and operational security of Spacehills

AML Compliance Framework

Spacehills operates a robust, risk-based AML compliance programme in line with Gambling Commission expectations.

Customer Due Diligence (CDD)

We apply customer due diligence procedures to verify the identity and legitimacy of all users.

Identity Verification

• Collection and verification of personal information using reliable and independent sources
  • Age verification in line with gambling legislation

Ongoing Monitoring

• Continuous monitoring of customer activity and transactions
  • Identification and investigation of unusual or suspicious behaviour

Enhanced Due Diligence (EDD)

Additional checks are applied where higher risk is identified, including but not limited to:

• High-value transactions
  • Higher-risk jurisdictions
  • Unusual or complex transaction patterns

Record Keeping

Spacehills maintains accurate and secure records as required by law, including:

• Verified customer identification and due diligence records
  • Complete transaction histories
  • Internal reports relating to suspicious activity

Records are retained for the legally required period and are made available to competent authorities upon lawful request.

Reporting of Suspicious Activity

Spacehills has established clear reporting procedures to ensure timely escalation and disclosure of suspicious activity.

Internal Reporting

Employees are trained to identify red flags and must promptly report concerns to the AML Compliance Officer.

External Reporting

Where required, Suspicious Activity Reports (SARs) are submitted to the Financial Intelligence Unit (UKFIU) via the National Crime Agency, in accordance with legal obligations.

Employee Training

All Spacehills employees receive ongoing AML training appropriate to their role. Training includes:

• Understanding money laundering and terrorist financing risks
  • Identifying suspicious patterns and red flags
  • Correct reporting and escalation procedures

Training is reviewed regularly to ensure continued effectiveness and regulatory alignment.

Risk Assessment and Risk Management

Spacehills conducts regular AML risk assessments to identify and mitigate potential vulnerabilities.

Risk assessments consider:

• Customer behaviour and transaction activity
  • Geographic risk factors
  • Payment methods and product types

Controls are applied proportionately based on the level of risk identified and are updated as threats and regulations evolve.

Roles and Responsibilities

AML Compliance Officer

The appointed AML Compliance Officer is responsible for:

• Implementing and maintaining the AML framework
  • Conducting periodic audits and policy reviews
  • Submitting SARs to the relevant authorities
  • Ensuring staff awareness and regulatory compliance

Management and Employees

All staff and management are required to:

• Adhere strictly to AML policies and procedures
  • Complete mandatory AML training
  • Report suspicious activity or policy breaches without delay

Policy Review

This AML Policy is reviewed regularly to reflect changes in legislation, Gambling Commission guidance, and emerging financial crime risks. Updates are communicated internally and, where appropriate, to users to ensure continued transparency and compliance.