Anti Money Laundering


Under the license conditions (“Instaspin” or “the Company”) is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.


Instaspin is fully committed to remaining vigilant in preventing money laundering and combatting terrorist financing (“TF”) in order to minimise and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

Instaspin will endeavour to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organization and its operations and safeguards, its reputation, and all from the threat of money laundering, the funding of terrorist and other criminal activities.


The objective of the internal manual is to provide a high-level assessment of the operations and services provided by Instaspin, and the risks Companies have in relation to that they may facilitate money laundering (“ML”) or terrorist financing (“TF”). Instaspin sets out the policies, procedures, systems and controls necessary to meet its obligations as defined in its licence conditions and relevant legislation, being:

  • EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
  • EU : “Regulation 2015/847 on information accompanying transfers of funds”
  • EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
  • BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash"

The above list is not exhaustive and as a case of best practice, Instaspin complies with international standards where no Curacao regulation or legislation is in force.

The procedures that are appropriate for the purpose of forestalling and preventing ML and countering TF include:

  • Player Identification
  • Record keeping
  • Internal procedures including the reporting of suspicious transactions, both internal and external
  • Staff education, training and development

Instaspin will assess the ML and TF risks it faces, and implement appropriate measures in respect of the above based on its assessment.