Proven Expertise in Combating Financial Crime in Gaming

Xtraspin has extensive experience in safeguarding gaming businesses from criminal misuse. The leadership team is deeply familiar with the Proceeds of Crime Act and recognizes key AML indicators common in both remote and non-remote gaming environments, especially in Card Not Present (CNP) transactions. The company’s director, well-versed in AML legislation and responsibilities, plays a crucial role in shaping and overseeing these measures. This expertise forms the foundation for continuous staff training and the development of effective operational controls to proactively prevent financial crime.

Robust Anti-Money Laundering and Fraud Detection Measures

Due to the rapid pace of transactions and the diversity of payment methods, gaming platforms are particularly vulnerable to money laundering and fraud. To address these risks effectively, Xtraspin implements a comprehensive approach focused on risk identification, management, and regulatory compliance:

Identifying and Managing Risks

Xtraspin implements multiple controls to detect and mitigate money laundering threats, including:

• Detection of Irregular Betting and Wagering Patterns. The system continuously monitors betting behaviours to identify anomalies such as sudden large bets or unusual winning streaks that deviate from normal customer activity. These patterns signal attempts to launder illicit funds through the gaming platform. Early detection allows for timely investigation and intervention.
• Monitoring Suspicious Deposit and Withdrawal Behaviors. Transactions are scrutinized for unusual size, frequency, or timing, which may indicate layering or structuring attempts to avoid detection. For example, frequent small deposits followed by large withdrawals can be a red flag. This ongoing surveillance helps identify and prevent fraudulent financial flows.
• Verification of Customer Data Accuracy and Authenticity. Customer information is rigorously checked against reliable sources and databases to confirm identity and prevent the use of false or stolen data. This verification reduces the risk of identity theft and ensures compliance with UK AML regulations.
• Prevention of Identity Theft and Account Duplication. Measures are in place to detect and block attempts to open multiple accounts using the same or related personal details. This prevents criminals from circumventing limits and controls by spreading activity across several accounts.
• Identification of Linked or Multiple Accounts. Cross-referencing data helps uncover accounts connected through shared IP addresses, payment methods, or behavioural patterns. Identifying these links is crucial to stopping coordinated fraudulent activities and money laundering schemes.

Reporting Protocols and Regulatory Compliance

Xtraspin maintains a strict reporting framework to ensure full compliance with AML regulations:

• Confidential Reporting to the MLRO. All suspicions of money laundering are reported confidentially to the Money Laundering Reporting Officer, who evaluates the information and decides on further actions. This protects the integrity of investigations and prevents tipping off customers.
• Submission of Suspicious Activity Reports (SARs). The MLRO files SARs with the appropriate authorities, such as the UK’s National Crime Agency, international bodies like Costa Rica’s Financial Intelligence Unit via the goAML system. These reports include detailed information about the suspicious transactions and involved parties.
• Comprehensive Record-Keeping. Xtraspin keeps thorough records of all reports, investigations, and communications to demonstrate compliance during audits and regulatory reviews. Maintaining these records supports transparency and accountability in the company’s AML efforts.

Know Your Customer (KYC) Procedures

Xtraspin applies a rigorous Know Your Customer (KYC) policy to ensure the authenticity of customer identities and minimise the risk of fraud. During registration, customers are clearly informed, both on the website and within the onboarding process, about the use of advanced online verification tools designed to confirm their identity and address. If these automated checks do not provide sufficient assurance, Xtraspin promptly requests additional documentation, such as government-issued identification and proof of address, to fully satisfy regulatory compliance standards and maintain the integrity of its platform.

Transaction Controls and Withdrawal Limits

Xtraspin enforces strict transaction controls and withdrawal limits to protect against financial crime, ensure regulatory compliance, and promote responsible gaming:

• Director Approval for Large Withdrawals. Any card withdrawal or bank transfer above £2,500 per transaction requires explicit director approval. This extra layer of oversight helps prevent unauthorised or suspicious high-value transactions.
• Daily and Weekly Withdrawal Limits. Players are limited to a maximum withdrawal of £800 per day, £2,500 per week, and £8,300 per month, as outlined in Xtraspin’s terms and conditions. These limits help manage risk and comply with anti-money laundering (AML) regulations.
• Withdrawal Frequency Restrictions. Customers may request up to three withdrawals per day, supporting both operational efficiency and enhanced monitoring of withdrawal activity.
• Enhanced Due Diligence (EDD). Any withdrawal request exceeding set thresholds triggers Enhanced Due Diligence. This process requires additional identity and address verification beyond standard online checks, ensuring that only legitimate players can access large sums.
• Cashless Operations. Xtraspin operates exclusively without cash transactions, eliminating risks associated with counterfeit currency and supporting secure, traceable payment flows.
• Deposit Wagering Requirement. To further comply with AML policies, players must wager their deposited amount at least three times before being eligible to withdraw funds. This rule helps prevent rapid deposit-and-withdrawal cycles associated with money laundering attempts.
• Secure Payment Methods. The platform offers a range of trusted payment options, including bank transfers, credit and debit cards, e-wallets, and cryptocurrencies, all processed with advanced encryption for maximum security.

Continuous Monitoring and Security Enhancements

Xtraspin meticulously records all customer transactions, subjecting them to continuous reviews aimed at detecting fraud and ensuring social responsibility. Unusual betting or winning patterns are carefully analyzed and cross-referenced with call recordings to identify any potential collusion or misconduct involving staff or customers. The company maintains a dedicated register of high-risk customers and Politically Exposed Persons (PEPs), who receive intensified scrutiny and more frequent compliance checks to manage elevated risks effectively.

Employee conduct is closely monitored, and any signs of illegal or unethical behaviour prompt formal investigations and disciplinary actions, including suspension when necessary, in line with employment laws and contractual obligations. Protecting customer data is a top priority. Xtraspin enforces a strict “Encrypt Everything Possible” policy, limits and monitors access to shared drives, and employs secure data storage and backup procedures to prevent unauthorized access or data loss.

Call recording technology plays a vital role in supporting staff training, verifying transaction accuracy, and safeguarding the company’s reputation. Regular monitoring of calls helps deter and detect any collusion between staff and customers, reinforcing the overall security and integrity of the platform.

Relationships with Customers and Business Partners

Xtraspin maintains ethical relationships with customers and business partners by making its Terms and Conditions, along with KYC and AML policies, publicly available on its website. These documents clearly address issues such as fraud, insider knowledge, match-fixing, and suspicious activities, detailing the company’s response procedures upon detection. The company works transparently with regulators and sports authorities to uphold the highest standards of integrity.

Staff receive ongoing training to conduct investigations discreetly, ensuring that suspects are not prematurely informed of any suspicions or inquiries. Business partnerships are subject to standardized due diligence processes, including disclosure of ownership, management, incorporation details, and contact information. These checks are formalized through Non-Disclosure Agreements (NDAs), with all records maintained systematically to ensure accountability and compliance.

Conclusion

Xtraspin’s AML and Fraud Prevention Framework illustrates its unwavering commitment to establishing a secure, compliant, and trustworthy gaming environment for all users. By implementing comprehensive policies, maintaining vigilant monitoring practices, and providing continuous training for staff, the company diligently works to protect its customers from potential risks. This proactive approach not only safeguards the interests of players but also reinforces the integrity and reliability of the Xtraspin platform as a whole.