This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Winner Island, operator of winnerislandbet.nl, and the requirements placed on every player who opens an account or transacts on the platform. Winner Island is licensed under the Union of the Comoros and is committed to upholding robust financial-crime prevention standards in full compliance with applicable anti-money laundering legislation and international best practice. All staff, agents, and players interacting with winnerislandbet.nl are bound by the terms of this Policy.
The primary purpose of this Policy is to prevent winnerislandbet.nl from being used, intentionally or otherwise, as a vehicle for money laundering, terrorist financing, fraud, or any other financial crime. This Policy applies to:
Money laundering is the process by which criminally obtained funds are given the appearance of legitimate origin. It typically involves three stages: placement (introducing illicit funds into the financial system), layering (obscuring the trail through a series of transactions), and integration (reintroducing the funds into the legitimate economy). Winner Island maintains controls at every stage to detect and interrupt this process.
Winner Island operates under a licence granted by the Union of the Comoros. In addition to the obligations imposed by that licence, Winner Island aligns its AML and KYC procedures with internationally recognised standards, including the recommendations of the Financial Action Task Force (FATF) and the principles underpinning the European Union's Anti-Money Laundering Directives, where applicable. This Policy is reviewed and updated on a regular basis to reflect changes in legislation, regulatory guidance, and evolving typologies of financial crime.
Winner Island has designated a Money Laundering Reporting Officer (MLRO) responsible for overseeing day-to-day compliance with this Policy. The MLRO is the first point of escalation for any suspicious activity identified by operational staff. The MLRO holds the authority to suspend accounts, delay or block transactions, and make Suspicious Activity Reports (SARs) to the relevant authorities where the circumstances warrant it. The identity and contact details of the MLRO are held internally and available to the licensing authority upon request.
Winner Island operates a risk-based KYC programme. Every player must pass identity verification before any withdrawal is processed from their account. Winner Island reserves the right to request verification documents at any point — including at registration, before a bonus is activated, or when account activity triggers a compliance review. Failure to provide satisfactory documentation within a reasonable timeframe will result in the suspension of withdrawal rights and, where necessary, account closure.
KYC is not a one-time event. Ongoing due diligence is applied throughout the customer lifecycle. If a player's circumstances change — or if their transaction patterns become inconsistent with their verified profile — Winner Island may request updated or additional documentation at any stage.
To complete standard KYC verification, players must supply documents across the following categories:
One of the following government-issued documents, valid and unexpired:
The document must clearly show the player's full legal name, date of birth, photograph, document number, and expiry date. Images or scans must be in colour, fully legible, and unobstructed by reflections or cropping.
One of the following, dated within the last three months:
The document must show the player's full name and residential address matching the details held on their winnerislandbet.nl account. PO Box addresses are not accepted as proof of residence.
All deposits at Winner Island must originate from a payment method registered in the player's own name — no third-party transfers are accepted under any circumstances. To verify ownership of the payment method used, Winner Island may request:
Withdrawals at winnerislandbet.nl are returned to the same payment method used for the qualifying deposit. This principle supports the traceability of funds and reduces the risk of layering.
Certain customers or circumstances require a higher standard of scrutiny beyond standard KYC checks. Winner Island will apply Enhanced Due Diligence in, but not limited to, the following situations:
Where EDD is applied, Winner Island may request one or more of the following in addition to standard KYC documentation:
During any EDD review, Winner Island reserves the right to restrict deposits, suspend bonus eligibility, and place a temporary hold on pending withdrawals. These measures are precautionary and do not constitute an accusation of wrongdoing.
A Politically Exposed Person is an individual who holds, or has held within the past twelve months, a prominent public function — including but not limited to heads of state or government, senior politicians, senior government officials, judicial or military officers, senior executives of state-owned enterprises, and senior officials of international organisations. Immediate family members and known close associates of PEPs are treated with equivalent caution.
Winner Island screens all players against recognised PEP databases as part of the verification process. Where a player is identified as a PEP, their account will not be activated or their withdrawal will not be processed until EDD has been completed to the satisfaction of the MLRO. Ongoing monitoring is applied to PEP accounts for the duration of the customer relationship.
Winner Island screens all players and transactions against applicable international sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and other relevant authorities. Where a match — or a potential match — is identified, the player's account will be suspended immediately and the matter escalated to the MLRO for investigation. Any confirmed match will result in permanent account closure and reporting to the appropriate authorities. Winner Island accepts no liability for funds held in accounts subject to a sanctions freeze.
Winner Island operates a continuous transaction monitoring programme designed to detect unusual or suspicious activity. The following patterns, amongst others, may trigger a review:
Where a transaction monitoring alert is generated, the MLRO will review the flagged activity and determine whether the account should be placed under enhanced monitoring, documentation requested, transactions suspended, or a SAR filed with the relevant authority.
Where Winner Island has knowledge, suspicion, or reasonable grounds to suspect that a player is engaged in money laundering or terrorist financing, the MLRO is obligated to file a Suspicious Activity Report with the appropriate financial intelligence unit or regulatory body. This obligation arises regardless of the transaction value and regardless of whether the player has completed a withdrawal. Tipping off — alerting a player to the fact that a SAR has been filed or is being considered — is strictly prohibited under applicable law and constitutes a serious criminal offence. Winner Island staff are trained accordingly, and this prohibition extends to all communications, including responses to player enquiries.
Winnerislandbet.nl is strictly prohibited from accepting registrations from individuals under the age of 18 (or the legal gambling age in the player's jurisdiction, if higher). Age verification is conducted as part of the KYC process. Where a player's age cannot be confirmed through the standard documentary checks, their account will be suspended pending satisfactory verification. Any funds deposited by a player subsequently found to be underage will be returned — minus any winnings, which are void — and the account will be closed. Winner Island maintains records of all age-verification checks in accordance with its data retention obligations.
Winner Island operates a strict no-third-party-payments policy. All deposits must originate from a payment account — whether a bank card, e-wallet, or Bitcoin wallet — held in the name of the registered player. Deposits identified as originating from a third party will be reversed, the account placed under review, and the matter escalated to the MLRO. This policy applies equally across all three accepted currencies (EUR, USD, and Bitcoin). Players are reminded that all withdrawals are processed back to the method of the original deposit, which further reinforces the traceability and ownership requirements underpinning this Policy.
Winner Island retains all KYC documentation, transaction records, correspondence, and compliance decisions for a minimum of five years from the date of the relevant transaction or the closure of the customer relationship, whichever is the later. Records are held securely and are accessible to the MLRO, senior management, and the licensing authority upon lawful request. Player data is processed in accordance with Winner Island's Privacy Policy, which governs how personal information is stored, used, and protected.
All Winner Island staff with customer-facing or compliance responsibilities receive AML and KYC training at induction and on a regular ongoing basis. Training covers the identification of suspicious activity, the correct escalation procedures, the prohibition on tipping off, and the legal consequences of non-compliance. Records of training completion are maintained by the compliance function and are available for inspection by the licensing authority.
Winner Island recognises that problem gambling and financial crime can, in certain circumstances, intersect. A player who is gambling with borrowed funds, funds obtained through fraud, or funds that are disproportionate to their known income may simultaneously be a vulnerable player and a compliance risk. Where the responsible gambling monitoring tools deployed by winnerislandbet.nl generate alerts — including patterns of high-frequency deposits, erratic session behaviour, or requests to remove self-imposed limits — the compliance team will be notified in addition to the responsible gambling function, so that both dimensions of the risk can be assessed concurrently.
Players experiencing difficulties with their gambling are encouraged to make use of the responsible gambling tools available on winnerislandbet.nl, including deposit limits, session limits, and self-exclusion. Further support is available through recognised independent organisations. Winner Island's responsible gambling framework operates alongside, and does not replace, the obligations set out in this AML/KYC Policy.
By registering an account on winnerislandbet.nl, each player agrees to:
Breach of any of the above obligations may result in suspension or permanent closure of the account, forfeiture of any bonus funds or bonus-derived winnings, withholding of withdrawals pending investigation, and reporting to the relevant law enforcement or regulatory authorities.
Where a player fails to satisfy Winner Island's KYC requirements, or where a review concludes that funds held in an account are the proceeds of criminal activity, Winner Island reserves the right to:
Winner Island will not be liable for any loss suffered by a player as a result of account suspension, transaction delays, or fund withholding carried out in good faith in accordance with this Policy and applicable law.
This Policy is reviewed at least annually by the MLRO and senior management, or sooner where significant changes occur in the applicable regulatory environment, the licensing conditions of the Union of the Comoros, or the risk profile of winnerislandbet.nl's operations. The current version of this Policy is published on winnerislandbet.nl and supersedes all previous versions.
Players with questions about this Policy, or who wish to understand how their personal data is used in the context of AML and KYC checks, may contact the Winner Island compliance team through the following channels:
| Channel | Details |
|---|---|
| [email protected] | |
| Live Chat | Available directly on winnerislandbet.nl |
Please note that, owing to legal constraints around tipping off and SAR confidentiality, Winner Island is not able to confirm or deny to any player whether their account is the subject of a compliance review or whether a report has been made to a competent authority.
