Anti-Money Laundering (AML) Policy

Company Overview

Medium Rare N.V. operates the online platform Stake and was established in 2017 under the laws of Curaçao. The company is licensed by the Curaçao Gaming Authority under license number OGL/2024/1451/0918 and provides services to users in multiple countries worldwide.

The platform maintains compliance procedures designed to prevent illegal activities, including money laundering, terrorist financing, fraud, and sanctions violations. These measures include customer verification, transaction monitoring, and risk-based controls.

AML Compliance Commitment

Stake follows applicable anti-money laundering and counter-terrorism financing requirements established by Curaçao regulations and international compliance standards.

The platform prohibits the use of its services for:

  • Money laundering;
  • Terrorist financing;
  • Fraudulent activities;
  • Sanctions violations;
  • Other forms of illegal financial activity.

The compliance framework includes:

  • Internal AML policies and procedures;
  • Risk assessment and monitoring systems;
  • Employee compliance training;
  • Regular reviews of AML controls.

Key AML Definitions

Money Laundering – the process of disguising illegally obtained funds as legitimate money.

It typically includes three stages:

  • Placement – introducing illegal funds into financial systems;
  • Layering – using complex transactions to hide the origin of funds;
  • Integration – returning processed funds into circulation as apparently legitimate assets.

Suspicious Activity – transactions or account behaviour that may indicate fraud, illegal activity, or attempts to bypass compliance requirements.

Sanctions – restrictions imposed by governments or international organisations to prevent specific individuals, entities, or jurisdictions from accessing financial services.

Compliance Management

The platform has a dedicated compliance function responsible for implementing AML procedures, reviewing regulatory requirements, investigating suspicious activity, and maintaining internal controls.

Employees receive regular training related to AML, fraud prevention, and financial crime risks.

Know Your Customer (KYC)

The platform applies risk-based customer verification procedures to confirm user identity and assess potential risks.

KYC procedures may include:

  • Collection of account information, including email, wallet address, name, country, and date of birth;
  • Identity and age verification through third-party providers;
  • Screening against sanctions and prohibited jurisdiction lists;
  • Verification of payment methods and funding sources.

Users may be required to provide:

  • Government-issued identification;
  • Proof of address;
  • Payment ownership documents;
  • Source of funds or wealth information.

Failure to complete verification or providing inaccurate information may result in account restrictions or closure.

Restricted Jurisdictions and Sanctions Screening

The platform uses geo-blocking and compliance checks to prevent access from restricted jurisdictions.

User information and wallet addresses may be screened against global sanctions databases. Accounts connected to prohibited regions, sanctioned individuals, or high-risk activity may be restricted.

Transaction Monitoring

All deposits and withdrawals are monitored using automated systems and compliance reviews.

Monitoring focuses on:

  • Unusual transaction volumes;
  • Rapid deposits and withdrawals;
  • Suspicious wallet activity;
  • Transactions linked to high-risk sources;
  • Attempts to bypass platform restrictions.

Crypto transactions may be reviewed using blockchain analysis tools to detect suspicious activity.

Suspicious Activity Reviews

When potential risks are identified, the platform may:

  • Request additional verification documents;
  • Restrict deposits or withdrawals;
  • Suspend an account during investigation;
  • Review transaction history and account activity.

Suspicious cases may be reported to relevant regulatory authorities where required by law.

Account Restrictions

Accounts may be suspended or blocked if users:

  • Provide false identification information;
  • Use prohibited payment methods;
  • Access the platform from restricted jurisdictions;
  • Attempt to bypass security controls;
  • Use multiple accounts to avoid restrictions;
  • Engage in suspicious financial activity.

Additional Monitoring Measures

The compliance system includes:

  • Detection of duplicate accounts and account sharing;
  • Device and location monitoring;
  • Prevention of prohibited payment methods;
  • Restrictions on anonymous transaction tools;
  • Regular reviews of third-party compliance providers.

Employee Training and Compliance Updates

Employees receive AML and financial crime prevention training to ensure compliance procedures are applied effectively.

The AML framework is regularly reviewed and updated according to regulatory requirements and industry standards.

Reporting Suspicious Transactions

Transactions linked to sanctions violations, money laundering, terrorist financing, or other criminal activity may be reported to the relevant authorities in accordance with applicable regulations.

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