AML Policy Shuffle: Rules for Preventing Money Laundering and Terrorist Financing

Purpose of the Policy and Curaçao Compliance Framework

Shuffle‘s AML Policy is built on AML and CFT obligations under Curaçao law, best practice guidance for the gaming sector, and requirements issued by the Curaçao Gaming Control Board. The policy was developed to address real risks that online gaming platforms face from individuals or groups seeking to move criminal proceeds or channel funds toward terrorist activity. The platform is operated by Natural Nine B.V. under gaming licence OGL/2024/1337/0628, and all compliance measures are structured around the regulatory expectations attached to that licence.

Shuffle Controls Against Illicit Activity and Sanctions Violations

Shuffle prohibits the use of its products and services for any illicit activity, including ML, TF and sanctions violations, and treats this prohibition as a core operational principle rather than a background obligation. The compliance system that supports this position covers a written policy, documented procedures and controls, a designated compliance officer, structured staff training, and independent reviews. Together, these elements form a layered approach to identifying and addressing risk before it affects the platform or its users.

Chief Compliance Officer and Suspicious Transaction Reporting

Shuffle’s Chief Compliance Officer coordinates AML Policy implementation, develops AML initiatives, revises procedures as regulations evolve, assesses new regulatory requirements, and investigates suspicious or unusual activity identified across the platform. The CCO has a direct and independent reporting line to the Board and acts on their own authority without requiring sign-off from other departments. The CCO may file suspicious transaction reports with the Financial Intelligence Unit of Curaçao at their own discretion and without prior approval.

Duties of Employees, Directors and Officers in Compliance Work

Employees, directors and officers at all levels must follow this policy and report any transaction or potential transaction suspected of involving criminal proceeds to the CCO without delay. This duty applies regardless of seniority or department, and it covers both completed transactions and activity that has not yet been processed. Failure to report in a timely manner may result in disciplinary action under internal company procedures.

Monitoring, Reviews and Maintenance of AML Procedures

Shuffle runs ongoing monitoring, independent reviews, staff education and regular procedural updates as a continuous compliance effort that covers all platform activity. Transaction behaviour is assessed against risk profiles, and patterns that fall outside expected parameters are flagged for further examination. The framework is reviewed and updated regularly to reflect changes in regulatory guidance, emerging typologies, and the results of independent audits.

Player Side of AML Rules During Payments and Account Activity

Players must use legitimate funds and maintain accurate account data consistent with platform terms at all times. Providing incorrect information or using payment methods that do not match account details creates inconsistencies that the compliance team is required to investigate. Unusual transaction patterns, atypical volumes, or activity that does not align with a player’s established profile may prompt an additional compliance review, which could include a request for supporting documentation.