Last updated: 15 August 2026
Highrollz • highrollz.com
Highrollz is operated by HR-CASINOS (the “Company”), a Curaçao company licensed and supervised by the Curaçao Gaming Authority (“CGA”) under licence number 399412.
The Company applies a risk-based AML/CFT/CPF programme designed to comply with applicable Curaçao legislation, CGA requirements, sanctions obligations and other laws applicable to the markets in which it operates. This includes customer identification and verification, sanctions screening, transaction monitoring, enhanced due diligence, record keeping, internal escalation and regulatory reporting.
The Company appoints appropriately qualified compliance personnel with responsibility for implementing and maintaining the AML/CFT/CPF framework. The responsible compliance function has authority to investigate unusual or suspicious activity, require additional information, restrict transactions, escalate concerns to senior management and make reports to competent authorities where required.
Relevant employees, contractors and officers must comply with the Company’s AML procedures and receive training appropriate to their role. Employees must promptly escalate unusual or suspicious activity and must not disclose the existence of a suspicious-activity report or investigation where such disclosure is prohibited by law.
We assess ML/TF/PF and sanctions risk using factors that may include the Player’s jurisdiction, nationality, occupation or business, PEP status, payment method, source and destination of funds, blockchain exposure, transaction size and velocity, product usage, account behaviour, device and location data, linked accounts and other relevant risk indicators.
The level and frequency of due diligence and monitoring may vary according to the assessed risk. Higher-risk relationships and transactions may be subject to enhanced review, additional documentation, management approval and more intensive ongoing monitoring.
We collect and verify information sufficient to establish a reasonable belief that we know the identity, age and location of each Player. Information may be requested at onboarding, before a first withdrawal, when risk or transaction thresholds are reached, when information changes, when a red flag is identified, or at any other time required by law or our risk-based procedures.
Information and evidence may include:
Highrollz may use reliable third-party identity-verification providers and databases to verify submitted information. We do not permit registration by non-natural persons unless expressly supported by the product and approved under our compliance programme.
Players must be at least 18 and meet any higher legal gambling age applicable to them. We may use documentary and electronic checks to verify age and identity. Government-issued identification may be required at any time and, where required by CGA rules, no later than the applicable verification point before withdrawal.
We screen Players and transactions against applicable sanctions lists, watchlists and high-risk-jurisdiction controls. We may block or reject a Player who is sanctioned, resident or located in a prohibited jurisdiction, who cannot be satisfactorily verified, or who seeks to conceal their location or identity.
Because Highrollz accepts digital assets, we may conduct blockchain analytics on deposits, withdrawals and wallet addresses. Such analysis may evaluate direct and indirect exposure to illicit or high-risk activity, including sanctions, stolen funds, fraud, ransomware, darknet markets, scams, terrorist financing, mixers, tumblers, unauthorised gambling, high-risk exchanges or other risk categories.
We may use third-party blockchain analytics and fraud-prevention providers. A deposit or withdrawal may be delayed, rejected, returned where lawful, or subjected to enhanced due diligence if its blockchain risk profile is inconsistent with our risk appetite or legal obligations.
Highrollz does not permit use of the Services to obscure the origin, ownership or destination of funds. Use of mixers, tumblers, privacy-enhancing routing or other anonymity techniques may be prohibited or treated as a red flag where they prevent us from satisfying legal or regulatory requirements.
We conduct ongoing monitoring of account and transaction activity. Monitoring may be manual, automated or a combination of both and may include:
EDD may be applied when a Player or transaction presents elevated risk, including in relation to politically exposed persons (“PEPs”), high-risk jurisdictions, high-value or complex transactions, sanctions exposure, unusual behaviour, adverse information, source-of-funds concerns or other red flags. We do not publish all internal monetary or behavioural thresholds because doing so could undermine monitoring controls.
EDD may include obtaining and verifying additional identification, proof of address, occupation or business information, bank or exchange statements, wallet-ownership evidence, source-of-funds documentation, source-of-wealth evidence, tax or corporate records, transaction explanations and other information reasonably required to understand the relationship or transaction.
A PEP is a person who is or has been entrusted with a prominent public function and may also include specified family members and close associates. PEP status does not automatically imply wrongdoing, but it may require enhanced review, approval and monitoring in accordance with applicable law and our risk procedures.
We may refuse registration, restrict an account, suspend deposits or withdrawals, request further information, reject a transaction, terminate a relationship or retain funds where legally required if we cannot complete satisfactory due diligence, identify material sanctions or financial-crime risk, detect prohibited conduct, receive a lawful request from an authority or otherwise determine that continuing the relationship would breach applicable law or our compliance obligations.
Where a transaction is suspicious, Highrollz may be legally prohibited from explaining the reason for a delay, restriction, refusal or report. Payment of any commercial processing fee does not remove or reduce AML verification requirements.
Where required, unusual or suspicious transactions and sanctions-related matters will be reported to the competent Curaçao authorities, including the Financial Intelligence Unit of Curaçao, without prior notice to the Player where disclosure is prohibited. We may cooperate with the CGA, law-enforcement agencies, courts, payment providers and other competent authorities in accordance with applicable law.
We retain KYC, account, transaction, risk-assessment, investigation and communication records for the period required by applicable law and regulatory requirements. Personal data is handled in accordance with our Privacy Policy and applicable data-protection law. Information may be shared with verification, analytics, sanctions, fraud-prevention and payment providers where necessary and lawful.
We may update this policy to reflect changes in law, CGA requirements, risk assessment, technology or business operations. The current version will be published on highrollz.com. Questions regarding this policy may be directed to Customer Support through the contact methods displayed on the Website.
