AML policy

Last updated: 1 September 2026 · Version 2.0

1. Introduction and Purpose

1.1 About This Policy

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy ("Policy") describes the procedures Parea Gaming, Inc. ("Company", "we", "us", or "our") uses to verify the identity of users, prevent fraud, and comply with applicable laws and regulations related to financial crimes.

1.2 Our Commitment

We are committed to:

(a) Preventing money laundering and terrorist financing

(b) Verifying the identity and age of all users

(d) Complying with all applicable federal and state laws

(e) Protecting the integrity of our Platform and Sweepstakes

(f) Maintaining the trust and safety of our community

1.3 Scope and Application

This Policy applies to all users of the Casinio.com platform ("Platform"), including anyone who:

(a) Registers an account

(b) Purchases Gold Coins

(d) Plays games on the Platform

(e) Requests redemption of prizes

By creating an account or using our Platform, you agree to comply with this Policy and cooperate with our verification procedures.

1.4 Integration with Other Policies

This Policy should be read in conjunction with our:

Terms & Conditions
Privacy Policy
Official Sweepstakes Rules

2. Legal and Regulatory Framework

2.1 Applicable Laws and Regulations

While we operate a promotional sweepstakes and not a traditional gambling operation, we implement AML/KYC procedures consistent with best practices and applicable legal requirements, including:

(a) Bank Secrecy Act (BSA)

(b) USA PATRIOT Act

(d) State consumer protection laws

(e) Federal and state anti-fraud statutes

(f) Internal Revenue Service (IRS) reporting requirements

2.2 Risk-Based Approach

We apply a risk-based approach to AML/KYC compliance, meaning we:

(a) Assess the risk level of each user based on various factors

(b) Apply enhanced verification measures for higher-risk situations

(d) Adjust our procedures as risks evolve

2.3 Continuous Compliance

AML/KYC compliance is an ongoing process. We may request additional information or verification from you at any time, even after your account has been verified.

3. When Verification Is Required

3.1 Mandatory Verification Triggers

You must complete identity verification in the following circumstances:

3.1.1 Account Registration

Basic information is collected when you create an account:

Full legal name
Email address
Date of birth
Residential address
Phone number (optional but recommended)

3.1.2 First Redemption Request

Before we process your first prize redemption, you must complete full KYC verification. This verification is processed through our trusted third-party identity verification provider and includes:

Government-issued photo identification verification
Facial recognition matching (selfie verification)
Address verification
Age verification (21+)
Tax information (Social Security Number or Individual Taxpayer Identification Number)

3.1.3 Redemptions Exceeding Thresholds

Additional verification or enhanced due diligence may be required when:

Total redemptions exceed $10,000 in a calendar year
A redemption request reaches a daily, weekly or monthly redemption limit set out in the Official Sweepstakes Rules
Activity patterns suggest enhanced due diligence is warranted

3.1.4 Purchases Exceeding Thresholds

We may request verification when Gold Coin purchases exceed:

$2,500 in a single transaction
$5,000 in a 24-hour period
$10,000 in a calendar month

3.1.5 Suspicious Activity

Verification may be required at any time if we detect:

Unusual transaction patterns
Inconsistent account information
Potential fraud indicators
Behavior consistent with money laundering
Multiple accounts or collusion
Use of stolen payment methods
Chargebacks or payment disputes

3.2 Ongoing Verification

We may request updated verification:

Periodically (typically annually for high-activity accounts)
When your account information changes
When your documents expire
To comply with regulatory requirements
At our discretion for risk management purposes

3.3 Voluntary Verification

You may voluntarily complete verification at any time to:

Establish trust and credibility
Enable faster redemption processing
Access higher transaction limits
Avoid delays when you're ready to redeem prizes

4. Verification Process and Technology

4.1 Third-Party Identity Verification

We use a leading third-party identity verification service provider to process all KYC verifications. This service uses advanced technology including:

(a) Document Authentication

Optical character recognition (OCR) to extract data from IDs
Security feature detection (holograms, microprinting, UV elements)
Template matching against known genuine documents
Detection of tampered, forged, or altered documents

(b) Facial Recognition

Biometric facial analysis and matching
Liveness detection to prevent spoofing (photos of photos, videos, masks)
Comparison between ID photo and live selfie
AI-powered fraud detection

Cross-reference against government databases
Identity fraud detection
Sanctions and watchlist screening
PEP (Politically Exposed Persons) screening

(d) Address Verification

Validation against postal and address databases
Risk assessment of provided address

4.2 Accepted Identity Documents

The verification system accepts the following government-issued photo identification documents:

(a) U.S. State Driver's License

(b) U.S. State Identification Card

(d) U.S. Military ID

(e) Permanent Resident Card (Green Card)

(f) Other government-issued photo ID (subject to system compatibility)

REQUIREMENTS:

Document must be current and not expired
Must be an original physical document (not a photocopy)
All information must be clearly visible
Document must show full legal name, date of birth, photo, and expiration date
Name on ID must match name on account

4.3 How the Verification Process Works

When you are prompted to verify your identity:

STEP 1: Initiate Verification

Log into your account
Navigate to Account Settings or respond to verification prompt
Click "Verify Identity" to begin
You will be redirected to our secure third-party verification provider

STEP 2: Select Document Type

Choose your document type (driver's license, passport, etc.)
Select your issuing country/state

STEP 3: Capture Document

Using your mobile device or webcam, you will be guided to capture:

• Front of your ID document

• Back of your ID document (if applicable)

The system will provide real-time feedback to ensure image quality
Auto-capture technology will take the photo when properly positioned

STEP 4: Capture Selfie (Facial Recognition)

Take a live selfie using your device camera
The system will verify you are a real person (liveness detection)
Your selfie will be compared to the photo on your ID

STEP 5: Automated Processing

The verification system processes your submission in real-time
Advanced AI analyzes document authenticity
Facial recognition matches your selfie to your ID photo
Your information is verified against databases

STEP 6: Result

Most verifications are completed instantly (within seconds to minutes)
You will receive immediate notification of the outcome
If approved, your account is marked as verified
If additional review is needed, our compliance team will be notified

4.4 Manual Review

In some cases, submissions require manual review by our compliance team when:

The automated system cannot make a confident determination
Document quality is borderline
Enhanced due diligence is required
You are flagged for additional verification

Manual reviews typically take 24-72 hours.

4.5 Verification Outcome

After processing, you will receive one of the following outcomes:

(a) APPROVED: Your identity is verified. Your account is marked as verified and you can proceed with redemptions.

(b) DECLINED: The verification could not be completed due to:

Document not readable or poor quality
Document expired or invalid
Facial recognition mismatch
Suspected fraudulent document
Information mismatch with account
Underage user detected
Other verification failure

If declined, you will receive specific instructions on how to resubmit or what information is needed.

(c) MANUAL REVIEW REQUIRED: Your submission requires human review by our compliance team. You will be notified of the estimated review timeframe.

4.6 Resubmission

If your verification is declined, you may resubmit by:

Ensuring your document is not expired
Using better lighting and camera quality
Removing any glare or obstructions
Ensuring your face is clearly visible for selfie
Using a different document type if available
Contacting support at [email protected] for guidance

Most common reasons for declined verifications:

Poor image quality (blurry, dark, glare)
Document partially cut off
Expired document
Document held at an angle
Poor lighting during selfie capture
Face partially covered or obscured

5. Required Information

5.1 Personal Information

You must provide accurate and complete information including:

(a) Full legal name (as appears on government-issued ID)

(b) Date of birth

(d) Email address

(e) Phone number

(f) Social Security Number or ITIN (where redeemed prizes reach $2,000 in a calendar year)

5.2 Document Requirements

Your identity verification will require:

Government-issued photo ID (see Section 4.2 for accepted documents)
Live selfie for facial recognition matching
Tax information (SSN/ITIN) before first redemption

No additional documents are needed for standard verification. The third-party verification system handles document authentication and facial recognition automatically.

5.3 Enhanced Due Diligence Documents

In higher-risk situations requiring enhanced due diligence, we may request additional documentation such as:

(a) Proof of Address

Utility bill (electric, gas, water, internet) dated within 90 days
Bank statement or credit card statement dated within 90 days
Lease agreement or mortgage statement
Official government correspondence

(b) Source of Funds Documentation

Bank statements showing deposit sources
Employment verification letter
Business ownership documentation
Explanation of source of funds letter

Additional photo ID
Birth certificate
Social Security card

(d) Payment Method Verification

Bank statement showing account ownership
Photo of credit/debit card (covering middle 8 digits)
Proof of bank account ownership

(e) Video Verification

Live video call with compliance team
Real-time identity verification and interview

Enhanced due diligence documents should be submitted via email to [email protected] or through our secure document upload portal.

5.4 Data Accuracy

You are responsible for ensuring all information provided is:

Accurate and truthful
Current and up-to-date
Matches your government-issued identification
Complete (no missing required fields)

Providing false, inaccurate, or fraudulent information is grounds for immediate account termination and forfeiture of all balances.

6. Transaction Monitoring

6.1 Automated Monitoring Systems

We use sophisticated automated systems to monitor all account and transaction activity for suspicious patterns, including:

(a) Unusual transaction amounts or frequency

(b) Rapid redemption of newly acquired Sweeps Coins

(d) Multiple accounts with similar information or behavior

(e) Use of multiple payment methods in short timeframes

(f) Activity from high-risk IP addresses or locations

(g) Geographic inconsistencies (location not matching stated address)

(h) Unusual gameplay patterns

(i) Accounts accessing from prohibited jurisdictions

6.2 Manual Review

In addition to automated monitoring, our compliance team conducts periodic manual reviews of:

High-value transactions
Flagged accounts
Redemption requests over $5,000
User-reported suspicious activity
Accounts with unusual activity patterns

6.3 Red Flags

We investigate accounts exhibiting "red flags" such as:

(a) Providing false or inconsistent information

(b) Refusing to provide verification documents

(d) Creating multiple accounts

(e) Colluding with other users

(f) Exploiting system errors or vulnerabilities

(g) Engaging in bonus abuse schemes

(h) Unusual win/loss ratios inconsistent with game RTP

(i) Rapid movement of funds in and out of account

(j) Failed verification attempts followed by new accounts

6.4 Consequences of Suspicious Activity

If we detect suspicious activity, we may:

(a) Request immediate verification or enhanced due diligence

(b) Temporarily suspend your account pending investigation

(d) Close your account and forfeit balances

(e) Report to law enforcement or regulatory authorities

(f) Take legal action to recover damages

7. Suspicious Activity Reporting

7.1 Internal Reporting

Any employee, contractor, or agent of the Company who becomes aware of suspicious activity must immediately report it to our AML Compliance Officer.

7.2 Reporting to Authorities

While we are not currently a regulated financial institution subject to mandatory Suspicious Activity Report (SAR) filing requirements, we reserve the right to report suspected money laundering, fraud, or other financial crimes to:

(a) Financial Crimes Enforcement Network (FinCEN)

(b) Federal Bureau of Investigation (FBI)

(d) State gaming or consumer protection regulators

(e) Internal Revenue Service (IRS)

7.3 User Reporting

If you become aware of suspicious activity by another user, report it immediately to [email protected] or [email protected]

Examples of reportable activity:

Another user asking you to accept payments on their behalf
Offers to buy or sell Sweeps Coins or accounts
Users admitting to using stolen payment methods
Collusion or coordinated fraud schemes

7.4 Non-Disclosure

We do not disclose to the user that their activity has been reported to authorities. This is a legal requirement under anti-money laundering laws and is necessary to protect investigations.

8. Data Security and Privacy

8.1 How We Protect Your Information

All verification data and personal information are:

(a) Transmitted via secure, encrypted connections (SSL/TLS)

(b) Processed by our third-party verification provider using industry-leading security standards

(d) Encrypted at rest using industry-standard encryption

(e) Accessible only to authorized compliance personnel

(f) Protected by multi-factor authentication and access controls

(g) Subject to regular security audits

8.2 Third-Party Verification Provider

Our third-party identity verification provider:

(a) Operates under strict data protection and privacy standards

(b) Is compliant with GDPR, CCPA, SOC 2 Type II, and ISO 27001

(d) Deletes facial recognition data after verification is complete

(e) Maintains the highest security standards in the industry

(f) Is contractually bound to protect your information

When you complete verification, you are interacting directly with this secure third-party system. Your biometric data (facial recognition) is processed in real-time and is not permanently stored by either the verification provider or by us.

8.3 Data Shared with Verification Provider

The following information is shared with our third-party verification provider:

Your name and date of birth (from account registration)
Government-issued ID images (captured during verification)
Selfie photo (captured during verification)
Device and IP information (for fraud detection)

8.4 Data Retention

We retain verification records and related information for:

Minimum of five (5) years from account closure or last transaction
Longer if required by law or ongoing legal/regulatory matters
In accordance with our record retention schedule

Biometric facial data is deleted after verification is complete and is not permanently stored.

8.5 Your Privacy Rights

Your personal information is collected, used, and shared in accordance with our Privacy Policy. You have certain rights regarding your data, including:

Right to access your information
Right to correct inaccurate information
Right to request deletion (subject to legal retention requirements)
Right to opt out of certain uses

See our Privacy Policy for complete information.

8.6 Confidentiality

We treat your verification information as confidential and will not share it except:

With authorized third-party service providers (including our verification provider)
As required by law or legal process
To law enforcement or regulatory authorities
To prevent fraud or protect our rights
With your explicit consent

9. Consequences of Non-Compliance

9.1 Failure to Verify

If you fail to complete verification when requested:

(a) Your redemption request will be denied

(b) Future redemption requests will be blocked until verification is complete

(d) Your account may be restricted or closed after 30 days

9.2 Providing False Information

If you provide false, altered, or fraudulent documents or information:

(a) Your account will be immediately terminated

(b) All balances will be forfeited

(d) We may report you to law enforcement

(e) We may pursue legal action against you

9.3 Refusal to Cooperate

If you refuse to cooperate with our verification procedures:

(a) We cannot process your redemptions

(b) Your account may be closed

9.4 Multiple or Duplicate Accounts

If we discover you have created multiple accounts:

(a) All accounts will be closed except one (at our discretion)

(b) Balances in duplicate accounts will be forfeited

(d) You may be permanently banned

Our verification system can detect duplicate identities through facial recognition and document matching.

9.5 Using Another Person's Identity

Using someone else's identity, documents, or payment methods is:

Identity theft (a federal crime)
Fraud (a federal and state crime)
A violation of our Terms & Conditions

This will result in immediate account termination, balance forfeiture, and referral to law enforcement.

10. Age Verification

10.1 Minimum Age Requirement

You must be at least 21 years of age to use our Platform and participate in the Sweepstakes. This is verified through:

(a) Date of birth provided during registration

(b) Government-issued photo ID showing date of birth (verified by third-party system)

(d) Third-party age verification databases

10.2 Zero Tolerance for Underage Users

If we discover you are under 21 years of age:

(a) Your account will be immediately terminated

(b) All balances will be forfeited

(d) We will not refund any Gold Coin purchases

(e) We may report to authorities if required by law

Our verification system automatically detects document forgery and age falsification.

10.3 Parental Responsibility

Parents and guardians are responsible for preventing minors from accessing our Platform. If you believe a minor has created an account, report it immediately to [email protected].

11. Restricted Jurisdictions

11.1 Geographic Restrictions

The Platform and the Sweepstakes are not available to residents of, or persons located in, the following Restricted Jurisdictions: California, Connecticut, Idaho, Indiana, Iowa, Louisiana, Maine, Michigan, Montana, Nevada, New Jersey, New York, Oklahoma, Tennessee, Washington. See Terms & Conditions Section 12.1 and Official Sweepstakes Rules Section 2.3 for the full provisions, and Official Sweepstakes Rules Section 2.4 for state-specific limitations that apply in certain permitted states.

11.2 Geo-Location Verification

We use various technologies to verify your location, including:

IP address detection
GPS data (if you permit location services)
WiFi triangulation
Mobile network data
Address verification during KYC process

11.3 VPN and Proxy Detection

Use of VPNs, proxy servers, or other location-masking technologies to access our Platform from Restricted Jurisdictions is:

(a) A violation of our Terms & Conditions

(b) Grounds for immediate account termination

(d) Potential fraud

11.4 Travel and Temporary Location

If you are temporarily located in a Restricted Jurisdiction (due to travel, military deployment, etc.):

You cannot access the Platform while in that location
Your account remains active
You may resume access when you return to an eligible jurisdiction

12. Payment Method Verification

12.1 Authorized Payment Methods Only

You may only use payment methods (credit cards, debit cards, bank accounts) that:

Are registered in your legal name
You are authorized to use
Are valid and not stolen, fraudulent, or compromised

12.2 Payment Verification Requirements

We may verify your payment methods by requesting:

Bank statement showing the card or account
Photo of the credit/debit card (covering middle 8 digits for security)
Verification from the payment provider
Video call verification

The name on your payment method must match your verified identity.

12.3 Third-Party Payment Methods

You may NOT use:

Someone else's credit card, debit card, or bank account
Gift cards or prepaid cards issued to someone else
Business or corporate cards (unless verified business account)
Payment methods registered under a different name

12.4 Chargeback Prevention

If you initiate a chargeback, dispute, or reversal of a Gold Coin purchase:

(a) Your account will be immediately suspended

(b) We may request full verification before reactivation

(d) Future purchases and redemptions may be restricted

(e) Repeated chargebacks result in permanent ban

13. Compliance Officer and Contact

13.1 AML Compliance Officer

Our designated AML Compliance Officer oversees this Policy and all AML/KYC procedures. The Compliance Officer is responsible for:

(a) Implementing and maintaining AML/KYC procedures

(b) Training staff on AML/KYC requirements

(d) Reporting to authorities as required

(e) Updating this Policy as laws and risks evolve

13.2 Contact Information

AML/KYC Compliance Officer:

Email: [email protected]

Mail: 1007 N Orange St. 4th Floor, Suite #5450, Wilmington, Delaware 19801, United States

Attention: AML Compliance Officer

For verification questions:

Email: [email protected]

Phone: +1 484 457 8433

For suspicious activity reports:

Email: [email protected]

For general customer support:

Email: [email protected]

Phone: +1 484 457 8433

14. Policy Updates

14.1 Right to Modify

We reserve the right to modify this Policy at any time to:

Comply with new laws or regulations
Respond to emerging fraud or money laundering risks
Improve our verification procedures
Clarify existing provisions

14.2 Notice of Changes

Material changes to this Policy will be communicated by:

Updating the "Last Updated" date at the top of this Policy
Posting notice on the Platform
Email notification to registered users (when feasible)

14.3 Continued Use

Your continued use of the Platform after Policy changes constitutes acceptance of the updated Policy. If you do not agree with the changes, you must discontinue use of the Platform.