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Home › AML / KYC Policy

This Anti-Money Laundering and Know Your Customer Policy ("Policy") applies to all players who register and transact on vavve.nl, operated by TechOptions Group B.V. under a licence issued by the Curacao Gaming Authority. It sets out the obligations Vave assumes under applicable legislation, and the obligations players accept when using the platform.

1. Introduction and Purpose

TechOptions Group B.V. ("Vave", "we", "us", "our") is committed to preventing the use of vavve.nl for money laundering, terrorist financing, or any other financial crime. As a licensed operator under the Curacao Gaming Authority, we are required to implement and maintain robust AML and KYC controls proportionate to the risks inherent in online gambling. This Policy describes how we identify players, monitor transactions, detect suspicious activity, and fulfil our reporting duties. All staff, contractors, and third-party service providers engaged in the operation of vavve.nl are required to comply with this Policy.

2. Legal and Regulatory Framework

Vave operates in accordance with:

  • The requirements and conditions of our Curacao Gaming Authority licence;
  • Applicable international AML and counter-terrorist financing (CTF) standards, including the recommendations of the Financial Action Task Force (FATF);
  • The laws and regulations of the jurisdictions in which we are permitted to offer services;
  • Internal compliance procedures reviewed and updated on a regular basis by our designated AML Compliance Officer.

Where national law in a player's jurisdiction imposes additional obligations, those obligations apply concurrently with this Policy.

3. Risk-Based Approach

Vave adopts a risk-based approach to AML and KYC. This means the level of due diligence applied to any given player or transaction is proportionate to the assessed risk of money laundering or terrorist financing. Risk factors we consider include, but are not limited to:

  • Player geographic location and country of residence;
  • Volume, frequency, and pattern of deposits and withdrawals;
  • Cryptocurrencies and wallet addresses used;
  • Whether a player is a Politically Exposed Person (PEP) or appears on any sanctions list;
  • Inconsistencies between stated source of funds and observed transaction behaviour;
  • Unusual bonus or promotional exploitation patterns.

Players assessed as lower risk may be subject to standard due diligence. Players assessed as higher risk will be subject to Enhanced Due Diligence (EDD) before we process further transactions or release winnings.

4. Know Your Customer (KYC) Procedures

4.1 When KYC Applies

As stated on vavve.nl, KYC verification is not required at the point of registration. However, verification must be completed before withdrawing larger amounts, and Vave reserves the right to request documentation at any time during a player's account lifecycle — including at the point of deposit, prior to any payout, or whenever our internal monitoring flags a concern. Players are strongly encouraged to submit documents early so that verification does not delay a withdrawal request.

4.2 Standard KYC — Required Documents

To verify identity, Vave may request one or more of the following:

  • Proof of Identity (POI): A valid government-issued photo ID clearly showing the player's full name, date of birth, nationality or citizenship, and photograph. Acceptable documents include a passport, national identity card, or driving licence.
  • Proof of Address (POA): A recent document (issued within the last three months) confirming the player's residential address. Acceptable documents include a utility bill, bank statement, or official government correspondence.
  • Selfie Verification: In some cases, we will ask for a selfie of the player holding their photo ID, or a live facial comparison check, to confirm that the account holder and the document owner are the same individual.
  • Proof of Payment Method: Because all deposits and withdrawals at Vave are processed via cryptocurrency, we may request confirmation that the sending wallet is registered in the player's own name. Withdrawals are returned to crypto wallets only, and that wallet must belong to the account holder.

4.3 Source of Funds (SOF) and Source of Wealth (SOW)

For players whose transaction volumes, withdrawal requests, or risk profile meet our internal escalation thresholds, Vave may request Source of Funds or Source of Wealth documentation. This is not a punitive measure — it is a legal obligation. Acceptable evidence may include:

  • Recent payslips, employment contracts, or employer letters;
  • Tax returns or official income assessments;
  • Business accounts or company financial statements;
  • Evidence of investment returns, dividends, or property sale proceeds;
  • Inheritance or gift documentation where applicable.

We will specify what documentation is required and provide a reasonable timeframe for submission. Failure to provide satisfactory documentation may result in funds being held pending review, or the account being restricted.

4.4 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied automatically in the following circumstances, and may be applied at our discretion in any other case that warrants it:

  • The player is identified as, or connected to, a Politically Exposed Person (PEP);
  • The player is a national of, or the transaction originates from, a jurisdiction identified by FATF as high-risk or under increased monitoring;
  • Transaction patterns are inconsistent with the player's stated profile;
  • A withdrawal of 50,000 USDT or above is requested — as noted on vavve.nl, such payouts may be split into instalments paid over up to 30 days, during which period our compliance team may complete additional checks;
  • Our automated monitoring systems generate a risk alert on the account.

EDD may include any combination of the above documentation requests, direct interview or written questionnaire, blockchain analytics review of wallet addresses used, and senior compliance officer sign-off before funds are released.

4.5 Politically Exposed Persons (PEPs) and Sanctions Screening

Vave screens all players at registration and on an ongoing basis against recognised PEP databases and international sanctions lists, including those maintained by the UN, EU, OFAC, and HM Treasury. If a player is identified as a PEP, a family member of a PEP, or a close associate of a PEP, a senior compliance officer must approve the business relationship before or immediately after onboarding. A PEP status does not automatically result in refusal; it does result in EDD and ongoing enhanced monitoring.

If a player matches or appears on a sanctions list, Vave is required to freeze funds and report to the relevant authority immediately. No funds will be released pending the outcome of that process.

5. Transaction Monitoring

Vave employs automated transaction monitoring systems that operate continuously across all player accounts. These systems are configured to flag activity that deviates from expected patterns, including but not limited to:

  • Rapid cycling of deposited funds without meaningful gameplay;
  • A pattern of depositing and withdrawing amounts that sit consistently just below documentation thresholds;
  • Multiple accounts receiving or sending funds to the same wallet address;
  • Use of multiple cryptocurrency addresses across a short time window;
  • Requests to withdraw to a wallet address different from the one used for deposits;
  • Unusual accumulation of winnings relative to deposited amounts and wagering activity;
  • Bonus abuse patterns that may indicate coordinated activity across accounts.

Alerts generated by the monitoring system are reviewed by our compliance team. Depending on the outcome of that review, the account may be cleared, flagged for further investigation, subjected to EDD, suspended, or reported to the appropriate authority.

6. Cryptocurrency-Specific Controls

Vave accepts nine cryptocurrencies — BTC, ETH, USDT (TRC20, ERC20, and Solana networks), LTC, DOGE, XRP, and TRX — for both deposits and withdrawals. Because all financial flows on vavve.nl are crypto-denominated, we apply blockchain analytics as a core component of our AML programme. This includes:

  • Screening of incoming wallet addresses against known high-risk, darknet, or mixer-associated addresses;
  • Review of transaction history and on-chain risk scores for wallets used by players;
  • Monitoring for fund flows that pass through tumbling, mixing, or chain-hopping services.

Players are required to use wallets registered in their own name. Third-party wallet payments are not accepted. If our blockchain analytics identify that funds have passed through a high-risk service or address prior to reaching Vave, we reserve the right to request additional documentation, hold the funds, or file a Suspicious Activity Report (SAR).

Cryptocurrency Minimum Deposit Network Confirmations Required
BTC 0.0014965 BTC 1
ETH 0.0109934 ETH 2
USDT (TRC20) 5 USDT 2
USDT (ERC20) 19.99 USDT 2
USDT (Solana) 3 USDT —
LTC 0.03471733 LTC 1
DOGE 42.18 DOGE 1
XRP 7.8 XRP 1
TRX 38.82 TRX 1

7. Deposit and Withdrawal Limits

The following limits apply across all accounts on vavve.nl and form part of our AML controls:

Parameter Detail
Minimum Deposit 20 USDT (or crypto equivalent)
Maximum Deposit No stated maximum; large deposits subject to enhanced monitoring
Minimum Withdrawal 20 USDT (method-dependent)
Large Withdrawal Threshold 50,000 USDT or above — may be paid in instalments over up to 30 days
Withdrawal Destination Player's own cryptocurrency wallet only; third-party wallets not permitted

Where a withdrawal of 50,000 USDT or above is requested, our compliance team conducts a full review of the account prior to, or during, the instalment payment period. This is not optional and cannot be waived by the player.

8. Suspicious Activity Reporting

Where our compliance team identifies activity that gives reasonable grounds to suspect money laundering or terrorist financing, we are required to file a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU) or competent authority. This obligation applies regardless of the amount involved and regardless of whether the player has completed KYC verification.

In accordance with legal requirements, Vave staff are strictly prohibited from tipping off a player — or any associated party — that a SAR has been, or may be, filed. Any communication that might prejudice an investigation is itself a criminal offence. Players should be aware that account access may be restricted and funds held during an investigation without explanation being given.

9. Record Keeping

Vave retains the following records for a minimum of five years from the date of the relevant transaction or the termination of the business relationship, whichever is later:

  • All KYC and identity verification documents submitted by players;
  • Transaction records, including deposit and withdrawal histories with timestamps, amounts, and wallet addresses;
  • Records of internal investigations, risk assessments, and escalation decisions;
  • SARs and any related correspondence with competent authorities;
  • Training records for staff with AML responsibilities.

Records are stored securely in a manner that allows them to be retrieved promptly in response to a lawful request from a regulatory or law enforcement authority.

10. Staff Training

All staff at TechOptions Group B.V. who handle player accounts, process transactions, or provide customer support are required to complete AML and KYC training at induction and on a regular refresher basis thereafter. Training covers recognition of suspicious activity indicators, escalation procedures, tipping-off restrictions, and the specific risks associated with cryptocurrency-denominated gambling. Records of training completion are maintained by the Compliance Officer.

11. AML Compliance Officer

TechOptions Group B.V. has appointed a designated AML Compliance Officer ("AMLCO") responsible for:

  • Oversight and day-to-day implementation of this Policy;
  • Receiving internal suspicious activity disclosures from staff;
  • Making decisions on whether to file SARs with the relevant authority;
  • Liaising with regulators, law enforcement, and FIUs as required;
  • Reviewing and updating this Policy at least annually, or following any material change in law or business operations.

Players with compliance-related queries may contact our support team via 24/7 Live Chat or email through vavve.nl. Queries will be escalated to the AMLCO where appropriate.

12. Player Responsibilities

By registering on vavve.nl, players confirm and agree that:

  • They are at least 18 years of age;
  • All funds used for deposits are from a legitimate, lawful source and belong to them personally;
  • They are not using vavve.nl to launder money, facilitate terrorist financing, or engage in any other financial crime;
  • All information provided to Vave during registration and KYC is accurate, complete, and up to date;
  • They will notify Vave promptly if any of their personal details change;
  • They will cooperate fully with any KYC, SOF, or SOW request made by Vave and understand that failure to do so may result in funds being withheld or the account being closed;
  • They will only withdraw to wallets registered in their own name.

13. Consequences of Non-Compliance

Vave reserves the right to take any of the following actions where a player fails to comply with this Policy, provides false information, or where we identify suspicious activity:

  • Suspend or restrict access to the account pending investigation;
  • Withhold or freeze funds pending completion of KYC, EDD, or SOF review;
  • Void bonuses or winnings obtained through activity that triggers AML concern;
  • Permanently close the account;
  • Report the matter and any associated funds to the relevant regulatory authority, FIU, or law enforcement agency.

Where funds are held pending investigation, Vave will comply with any order or instruction from a competent authority regarding those funds, which may prevent their release to the player indefinitely.

14. Responsible Gambling and AML Interaction

Vave recognises that problem gambling and financial crime can intersect. Our player monitoring systems consider responsible gambling indicators alongside AML indicators. Players who appear to be depositing beyond their apparent means, or whose behaviour suggests financial harm, may be contacted by our player protection team independently of any AML review. Players who wish to set deposit limits, take a cooling-off period, or self-exclude may do so at any time through their account settings or by contacting our 24/7 support team.

15. Policy Review

This Policy is reviewed at least once per calendar year by the AML Compliance Officer and updated as necessary to reflect changes in applicable law, regulatory guidance, FATF recommendations, or our business operations. The version published on vavve.nl at any given time is the current version. Continued use of the platform constitutes acceptance of the Policy as updated.

16. Contact

If you have questions about this AML/KYC Policy or need to submit verification documents, please contact us through the 24/7 Live Chat function on vavve.nl or via our support email address available in the Help section of the site. All compliance-related correspondence is handled by trained staff and escalated to the AMLCO where required.

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