1. Business Model
- Stadiobet was established in 2017 and currently supports users in over 169 countries worldwide.
- As part of its global operations, Stadiobet has implemented compliance measures aligned with its services and products, designed to reasonably prevent and detect illegal activities on its platform.
- These measures include customer onboarding and compliance screening, as well as transaction-based controls.
2. Company Policy Statement
- Stadiobet is not a financial institution under Curaçao law and is therefore not directly subject to regulations applicable to certain financial institutions, remittance providers, or virtual asset service providers.
- However, under the 2016 Anti-Money Laundering and Counter-Terrorism Financing ("AML / CFT") rules provided by the Curaçao Gaming Control Board for the Curaçao jurisdiction, Stadiobet strictly prohibits and refuses the use of its products for any illegal activity, including money laundering, terrorism financing, or violations of trade sanctions, in line with AML laws, regulations, and standards of various countries.
- Stadiobet continuously monitors the standards set by the Financial Action Task Force ("FATF"), relevant gaming industry bodies, and the Curaçao Gaming Control Board, and will take necessary actions in response to legal changes.
- Stadiobet aims to follow global best practices to prevent its products from being used to facilitate such activities. These best practices include:
- • Implementing written policies, procedures, and controls reasonably designed to prevent money laundering, terrorism financing, and trade sanctions violations;
- • Appointing a Compliance Officer, where appropriate, to oversee the implementation of policies, procedures, and controls;
- • Providing relevant education and training to personnel; and
- • Conducting independent review, monitoring, and maintenance of policies, procedures, and controls.
3. Definitions
- Money Laundering: The process of making illegally obtained funds appear legitimate, typically in three steps: placement, layering, and integration.
- Placement: Depositing illegally obtained funds into traditional financial institutions via deposits or other means.
- Layering: Separating criminal proceeds from their source through complex financial transactions, such as converting cash into traveler's checks, money orders, wire transfers, letters of credit, stocks, bonds, or purchasing assets.
- Integration: Using seemingly legitimate transactions to obscure illegally obtained funds, allowing laundered funds to be reintroduced into normal use by criminals.
- Suspicious Activity: Transactions by users or non-users that indicate the transaction may be conducted for fraudulent or illegal purposes.
- Sanctions: Measures imposed by the international community to prohibit or restrict sanctioned activities. For example, they may be used to:
- • Encourage a target country or regime to change behavior;
- • Apply pressure on a target country to comply with set objectives;
- • Serve as an enforcement tool when international peace and security are threatened and diplomatic efforts fail;
- • Prevent and suppress financing of terrorists or terrorist acts.
4. Governance & Oversight
- Stadiobet has appointed a Chief Compliance Officer ("CCO") responsible for coordinating AML policies and program implementation.
- The CCO’s duties include developing the AML program, updating AML policies with other Stadiobet stakeholders, evaluating new regulatory requirements, and investigating potentially suspicious or unusual activity.
- Stadiobet also provides regular AML training to all employees.
5. Know Your Customer (KYC) & Transaction Monitoring
- Stadiobet applies legally required user due diligence and ongoing monitoring measures. Stadiobet strives to prevent users from engaging in illegal or unauthorized activities.
- Compliance is enforced through a combination of Stadiobet’s software features and service agreements to ensure adherence to applicable laws.
5.A Customer Due Diligence (CDD)
- Stadiobet uses a risk-based CDD approach to understand the nature and purpose of the relationship between users and the Stadiobet platform, creating a risk profile for each customer.
- During account registration, Stadiobet collects certain written and non-written information relevant to the account type and services provided. Different CDD measures are maintained for different accounts and services.
- Example CDD procedures require users to complete Stadiobet’s Customer Identification Program (CIP), which includes:
- • Collecting baseline information (e.g., wallet address, email) via Stadiobet’s onboarding portal at account creation;
- • Monitoring risk profiles associated with the cryptocurrency wallets funding user accounts;
- • Recording information used to identify the user; and
- • Checking whether the user appears on known or suspected terrorist lists provided by financial institutions.
- These steps are implemented through:
- • Identity & Age Verification: Third-party providers help verify the validity of identity information and other KYC materials, confirm the user is legally allowed, and ensure the user is not located in fully sanctioned or prohibited jurisdictions. Global sanctions lists are checked using onboarding information such as wallet addresses.
- • Customer Information: Stadiobet collects detailed information to form a reasonable belief about the user’s identity, aligned with the user’s risk profile. This may include wallet address, name, address, country, date of birth, or postal code (collectively "KYC Information"). Stadiobet collects this information before issuing funding addresses (e.g., QR codes). Currently, non-natural person users are not allowed. Stadiobet may rely on another entity to perform some or all elements of CIP.
- • Geoblocking for Prohibited Jurisdictions: Contracted users must confirm they are not in countries where services are prohibited, verified through IP-based geoblocking. Users must not be subject to U.S., EU, or other global sanctions or watchlists, including individuals or entities in fully sanctioned U.S. jurisdictions (Iran, Cuba, North Korea, Syria, and Crimea). Risk-based measures, including KYC and IP geoblocking, are used to verify these statements.
- Contracts prohibit onboarding users from restricted jurisdictions. Users are informed that Stadiobet does not provide services in restricted jurisdictions. These policies stem from Stadiobet’s risk, fraud prevention, and AML standards, as well as assessments of service permissibility in specific jurisdictions.
5.B Enhanced Due Diligence (EDD) & Ongoing Monitoring
- Stadiobet continuously monitors users to detect behavior or indicators potentially linked to money laundering or terrorism financing. A set of red-flag indicators helps identify such behavior and triggers further action during customer assessments.
- If a red flag is triggered, the user account may be suspended and subject to enhanced due diligence (EDD).
- EDD may include, but is not limited to, collecting and verifying: full name; nationality; permanent address; identification numbers (tax ID, passport, foreigner ID, or other government-issued ID); identity documents; source of funds and wealth.
- Stadiobet may use third-party service providers to verify any of the above information to establish a reasonable basis for understanding the true identity of the user if required by their activities.
5.C Acceptance Policy
- Stadiobet will not accept and will block users who:
- • Fail to provide requested identity information;
- • Submit false identity documents;
- • Attempt to misrepresent their location;
- • Are from restricted or prohibited jurisdictions;
- • Are subject to U.S., EU, or other global sanctions or watchlists;
- • Have long-term gambling addiction or mental health issues;
- • Conduct transactions from restricted jurisdictions or with prohibited funding sources.
- Stadiobet reserves the right to block or suspend players for any other reason.
5.D Transaction Monitoring
- Stadiobet strictly complies with economic and trade sanctions applicable in its operating jurisdictions.
- To enforce this, Stadiobet has established a transaction monitoring program using a combination of internally developed rule-based systems and third-party systems to identify and detect anomalies in real-time and through ongoing monitoring.
- This program outlines how Stadiobet identifies unusual activity through employee and customer identity verification, law enforcement queries, other referrals, transaction and monitoring system reports, and focuses on investigating, assessing, and recording alerts for identified or potentially suspicious activities.
- Stadiobet follows these processes to achieve these goals:
- • Sanctions & Restricted Jurisdiction Monitoring: Stadiobet monitors transactions from sanctioned or prohibited jurisdictions. Additional due diligence may be applied when users withdraw balances. A mix of manual and automated monitoring identifies red-flag behavior. Suspicious withdrawals may be rejected or additional information may be requested. Users attempting to fund accounts from prohibited jurisdictions (disclosed in the Stadiobet UI and updated internally) may be restricted. For example, funding from wallets associated with U.S. exchanges may be blocked.
- • Sanctions Screening: Before issuing Stadiobet funding addresses, wallet addresses are screened against applicable sanctions databases using third-party blockchain forensics providers, such as Chainalysis. Wallets are regularly re-screened.
- • Suspicious Activity Detection: Account activity is monitored for unusual transaction size, frequency, patterns, or types, considering risk factors and red flags. Reports of unusual, high-risk, or suspicious activity are generated regularly.
- • Anti-Mixing Measures: Software is used to detect suspicious deposit or withdrawal patterns. Cases are reviewed individually based on risk, and users may be asked to explain their platform usage.
- • Chainalysis Review: All crypto deposits and withdrawals, direct or indirect, are reviewed for signs of fraud or suspicious activity. Accounts flagged for potential illegal activity are suspended and reviewed. High-risk accounts may be required to provide proof of funds. Withdrawals to high-risk addresses, as determined by Chainalysis risk scores, may be denied.
- • Withdrawal Threshold KYC: Any account reaching a withdrawal threshold based on its risk profile will be suspended until sufficient KYC due diligence is completed.
Additional Ongoing Monitoring Controls
- Stadiobet has implemented the following procedures to complement its KYC and ongoing monitoring programs:
- • Multiple Account Detection: Third-party software detects users operating multiple accounts by linking accounts accessed from the same device. Cases are reviewed individually based on risk, and users may be asked to explain their platform usage. Stadiobet accounts are funded via local (non-custodial) or custodial wallets. Beyond Chainalysis screening, user activity on the Stadiobet platform is monitored, and all withdrawals must comply with Stadiobet and third-party verification processes. Peer-to-peer account transfers within the Stadiobet platform are prohibited. Attempts to bypass these restrictions are treated as red flags.
- • Timezone Monitoring: Device timezone information is monitored and cross-checked with restricted jurisdictions to detect attempts to hide connection sources using geolocation tools.
- • Product & Service Review: Additional procedures are in place to prevent users from abusing the platform. Users must comply with Stadiobet’s robust user terms. Safeguards mitigate abuse risks, including policies restricting which assets may be uploaded to the platform. Stadiobet maintains a list of allowable assets and prohibits anonymity-enhanced technologies (mixers, tumblers, certain coins/tokens). Any detected use of these technologies is banned.
- • Vendor Management: Stadiobet partners with reputable third-party service providers as part of its compliance infrastructure. Key vendors are regularly evaluated to ensure services meet contractual obligations, and corrective measures are taken if needed. Vendors may be required to provide information as part of the vendor review process.
- • Compliance Innovation: Emerging compliance solutions are monitored to assess applicability. Pilot programs may be conducted to evaluate effectiveness. Blockchain-native tools include anti-fraud services, on-chain KYC providers, and other tools reflecting technical characteristics of blockchain platforms.
- • Education & Training: Under legal counsel and CCO oversight, Stadiobet provides regular AML, CFT, and sanctions compliance training to employees as needed.
- • Reporting: Stadiobet is required by law to report any unusual or suspicious transactions. Customers confirmed on sanctions lists or involved in money laundering, terrorism financing, or other criminal activities are reported to regulatory authorities as suspicious activity.