- Introduction and Legal Basis
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy of D1 Club Casino as it applies to customers accessing services from Ireland. D1 Club Casino operates in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts, as amended, including the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018, which extended AML obligations to the betting and gambling sector. Procedures are also aligned with applicable EU Anti-Money Laundering Directives and the requirements introduced under the Gambling Regulation Act 2024.
As a gambling operator, D1 Club Casino is classified as a designated person under Irish AML legislation. This classification includes legal obligations to implement customer identification and verification procedures, conduct ongoing monitoring of transactions and account activity, and report suspicious activity to the relevant authorities. Compliance with these obligations is mandatory. No customer may bypass or opt out of these requirements.
- Purpose of This Policy
This policy is intended to prevent the use of D1 Club Casino for money laundering, terrorist financing, fraud, or any other form of financial crime. It also supports legal obligations in relation to age verification and the prevention of underage gambling. The procedures described in this document apply to all customers, regardless of the amount deposited or wagered, and are enforced consistently across all account types.
- Customer Due Diligence (CDD)
3.1 When CDD Is Required
D1 Club Casino initiates Customer Due Diligence at account registration and before permitting withdrawals. CDD is also required in the following circumstances:
- A single transaction or payout reaches or exceeds EUR 2,000.
- Linked or aggregated transactions within a defined monitoring window reach the EUR 2,000 threshold.
- A customer places a single bet of EUR 200 or more, at which point subsequent transactions of EUR 50 or more are monitored for a period of at least six months (online accounts) to determine whether the cumulative EUR 2,000 threshold is reached.
- A change in customer risk profile or account behaviour warrants review.
- There is any suspicion of money laundering, terrorist financing, or fraudulent activity.
No transaction that triggers the EUR 2,000 CDD threshold will be processed until the required documentation has been received and verified.
3.2 Identity Verification Documents
To complete standard CDD, customers must provide the following:
- Government-issued photo ID: for example, a valid passport, national identity card, or driving licence.
- Proof of address: for example, a utility bill, bank statement, or official government correspondence dated within the last three to six months.
Documents must be clear, legible, and unaltered. D1 Club Casino reserves the right to request additional documentation if the initial submission is insufficient or raises concerns.
3.3 Age Verification
Verification of a customer’s age is a mandatory component of the KYC process. Customers must confirm that they are of legal gambling age in Ireland before any account features, including deposits and wagering, become available. Age verification is conducted using the same government-issued photo ID required for identity verification.
- Enhanced Due Diligence (EDD)
Where a customer is identified as higher risk, or where account activity or transaction volumes exceed standard thresholds, D1 Club Casino applies Enhanced Due Diligence. EDD may include:
- Source of Funds (SOF) documentation confirming the origin of funds used for gambling activity.
- Source of Wealth (SOW) documentation confirming how the customer acquired their overall wealth.
- Additional identity checks, which may include biometric verification or liveness detection where applicable.
- More frequent or detailed review of account activity.
EDD is a legal requirement applied on a risk-based basis. Customers subject to EDD will be notified of the specific documents required. Account access may be restricted until EDD is completed to the satisfaction of the company.
- Ongoing Monitoring
D1 Club Casino conducts ongoing monitoring of customer accounts and transactions throughout the customer relationship. This includes reviewing transaction patterns, identifying unusual or inconsistent activity, and updating customer risk assessments when circumstances change. Monitoring is not limited to the point of account opening. Customers may be asked to provide updated documentation at any stage if their risk profile changes or if their account activity raises concerns.
- Prohibited Conduct
The following actions are prohibited and may result in account suspension, termination, reporting to the relevant authorities, and forfeiture of funds where required by law:
- Opening or operating more than one account.
- Submitting forged, altered, or stolen identity documents.
- Using payment instruments registered to another person.
- Misrepresenting identity, age, residency, or beneficial ownership.
- Structuring deposits or transactions to avoid CDD thresholds.
- Sharing or transferring account access to another individual.
- Attempting to launder funds or disguise the origin of funds through gambling activity.
- Any other conduct intended to circumvent AML or KYC controls.
- Suspicious Activity Reporting
D1 Club Casino maintains internal procedures for identifying and escalating suspicious activity. Where there are reasonable grounds to suspect money laundering or terrorist financing, the company is legally required to submit a Suspicious Transaction Report (STR) to the Financial Intelligence Unit (FIU) in Ireland via the goAML reporting system. The company is prohibited by law from disclosing to a customer that a report has been made or that an investigation is underway.
- Record Keeping
D1 Club Casino retains records of all customer identification documents, transaction data, and decisions or actions taken in connection with AML and KYC obligations. Records are maintained for the period required under applicable Irish law. These records may be made available to competent authorities upon lawful request.
- Internal Controls and Staff Training
D1 Club Casino has appointed a Money Laundering Reporting Officer (MLRO) responsible for overseeing AML and KYC compliance. Relevant staff receive regular training on AML and counter-terrorist financing obligations, including how to recognise suspicious behaviour and how to escalate concerns through internal reporting channels. Internal policies and procedures are reviewed and updated in line with changes to applicable legislation and regulatory guidance.
- Payment Method Restrictions
In accordance with Irish law, the use of credit cards for gambling deposits is prohibited. Customers must use permitted non-credit payment methods. This restriction applies to all accounts held with D1 Club Casino and is enforced at the point of deposit.
- Contact
Questions about this policy or about the status of account verification may be addressed to the compliance team through the support channels listed on the D1 Club Casino website. The company is unable to discuss the details of any STR or ongoing investigation.
This policy is subject to review and may be updated to reflect changes in applicable law or regulatory guidance. The version published on the website is the current operative version.