This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of HNA Gaming B.V. ("the Operator"), which operates HugoBet at hugobetwin.com ("the Platform"), with respect to preventing financial crime, verifying customer identity, and ensuring full compliance with applicable regulations. HugoBet holds a Curaçao gaming licence (OGL/2024/1191/0663) and is committed to maintaining the highest standards of integrity across all player accounts, payment transactions, and gaming activity conducted on the Platform.
Money laundering is the process by which individuals attempt to conceal the origins of criminally obtained funds by passing them through legitimate financial or commercial channels. Terrorist financing refers to the provision or collection of funds with the intention that they be used to carry out terrorist acts. Both represent serious criminal offences under international law and are wholly incompatible with the values and operating standards of HugoBet.
The purpose of this Policy is to:
This Policy applies to every individual who registers an account, deposits funds, places wagers, or withdraws winnings on hugobetwin.com, regardless of their jurisdiction of residence or the payment method used.
HugoBet operates under the authority of its Curaçao gaming licence, reference OGL/2024/1191/0663, granted to the Operator HNA Gaming B.V. The Operator acknowledges and adheres to internationally recognised AML/CFT (Counter-Financing of Terrorism) standards, including the recommendations of the Financial Action Task Force (FATF), and applies corresponding internal controls proportionate to the risks inherent in operating an online gambling platform.
The Operator maintains a designated Money Laundering Reporting Officer (MLRO) who is responsible for overseeing the day-to-day implementation of this Policy, receiving and evaluating internal suspicious activity reports, filing disclosures with the relevant authorities where required, and ensuring that AML/KYC procedures remain current and effective.
HugoBet applies a risk-based approach (RBA) to its AML and KYC obligations. This means that the level of due diligence applied to any given customer or transaction is proportionate to the assessed risk that the customer or transaction presents. Factors considered when determining risk level include, but are not limited to:
Based on this assessment, customers are categorised as presenting a standard, medium, or high risk profile. The level of Customer Due Diligence (CDD) applied is calibrated accordingly, ranging from standard checks through to Enhanced Due Diligence (EDD) for higher-risk individuals.
HugoBet will conduct Customer Due Diligence at the following points:
To satisfy standard CDD requirements, customers will be required to provide the following documentation. All documents must be valid (not expired), clearly legible, and submitted in an acceptable digital format (JPEG, PNG, or PDF).
One of the following government-issued documents:
The document must clearly display the customer's full legal name, date of birth, photograph, document number, and expiry date.
One of the following, dated within the last three months:
The document must clearly display the customer's full name and residential address as registered on the Platform.
Depending on the deposit method used, the Operator may request additional verification to confirm ownership of the payment instrument, including:
Enhanced Due Diligence will be applied in circumstances where the standard risk assessment indicates a higher level of risk, or where specific triggers arise during the customer relationship. Circumstances that may give rise to EDD include:
Where EDD is triggered, the Operator may request one or more of the following in addition to the standard documentation:
Failure to provide requested EDD documentation within the timeframe stipulated by the Operator will result in the restriction or suspension of the customer's account, including the blocking of any pending withdrawals, until satisfactory documentation is received and reviewed.
When a customer registers an account on hugobetwin.com, they are required to provide accurate personal information including their full legal name, date of birth, residential address, email address, and contact details. By submitting this information, the customer confirms that it is true, complete, and current. Providing false or misleading information constitutes a breach of the Platform's Terms and Conditions and may result in immediate account closure and the forfeiture of any funds held on the account.
As stated on the Platform, KYC verification is mandatory before any withdrawal is processed. This requirement applies to all customers, regardless of the withdrawal amount or the payment method selected. Customers are encouraged to complete verification proactively after registration, rather than waiting until they wish to withdraw, in order to avoid delays. The minimum withdrawal amount is €20; the maximum is €50,000 per month under standard terms.
In addition to identity verification, players are required to wager 100% of any deposit amount before a withdrawal request will be processed. For example, a customer who deposits €100 must wager at least €100 across eligible games before their withdrawal request can be approved. This requirement exists to ensure that deposit and withdrawal activity reflects genuine gaming behaviour rather than the use of the Platform as a pass-through mechanism for funds.
Customers may submit KYC documents via the secure upload portal within their account area or by sending them directly to the Operator's support team via the designated verification email address. Documents will be reviewed by the Operator's compliance team within a reasonable timeframe. The Operator reserves the right to request clarification, additional documents, or certified copies where the initial submission is unclear or insufficient. Customers will be notified of the outcome of their verification by email or through the Platform's live chat function, which is available 24 hours a day, seven days a week, in English, German, Spanish, French, and Portuguese.
KYC verification is not a one-time event. The Operator continuously monitors customer accounts and transaction histories throughout the duration of the customer relationship. This monitoring includes automated transaction screening, pattern analysis, and periodic manual review. Where a change in a customer's circumstances, behaviour, or risk profile is detected, the Operator may request updated documentation or initiate a fresh round of due diligence at any time.
HugoBet fully supports cryptocurrency deposits and withdrawals. Crypto is treated with the same rigour as any other payment method under this Policy. Customers who deposit via cryptocurrency must be able to demonstrate ownership of the originating wallet and, where required under EDD procedures, may be asked to provide documentation evidencing the source of the cryptocurrency funds. Blockchain analytics tools may be used by the Operator to assess the provenance of incoming cryptocurrency transactions and to identify any association with flagged or high-risk wallet addresses. Transactions found to originate from mixing services, darknet markets, or other high-risk sources may be rejected and reported to the relevant authorities. The minimum crypto deposit is €10–€20, and the minimum crypto withdrawal is €20.
HugoBet screens all customers against relevant PEP lists and international sanctions databases, including those maintained by the United Nations, the European Union, and other recognised bodies. This screening is conducted at the point of registration and on an ongoing basis throughout the customer relationship.
A Politically Exposed Person is an individual who holds or has held a prominent public function, including heads of state or government, senior politicians, senior government officials, senior judicial or military officials, senior executives of state-owned enterprises, and senior officials of political parties, as well as their immediate family members and known close associates.
Where a customer is identified as a PEP or is subject to an applicable sanctions designation:
All members of staff with access to customer account information, transaction data, or compliance systems are required to report any knowledge or reasonable suspicion of money laundering or terrorist financing to the MLRO without delay using the Operator's internal reporting procedures. Reports must be made promptly and must not be disclosed to the customer in question, as tipping off a subject of suspicion is itself a criminal offence in many jurisdictions.
Upon receipt of an internal report, the MLRO will assess whether there are reasonable grounds to suspect money laundering or terrorist financing and, where appropriate, will file a Suspicious Activity Report (SAR) or equivalent disclosure with the relevant financial intelligence unit or competent authority in accordance with applicable law. The filing of such a report does not constitute an accusation of wrongdoing; it is a legally mandated precaution.
The following patterns and behaviours, amongst others, may constitute red flags that prompt an internal suspicious activity report:
The Operator retains all KYC documentation, transaction records, account histories, and AML-related correspondence for a minimum period of five (5) years from the date of the last transaction or the closure of the account, whichever is later. Records are stored securely in accordance with applicable data protection legislation and are made available to competent authorities upon lawful request. Customers may refer to HugoBet's Privacy Policy, available on hugobetwin.com, for further information on how their personal data is collected, stored, and processed.
The Operator reserves the right to restrict, suspend, or permanently close a customer account, and to withhold or freeze funds held on that account, in any of the following circumstances:
Where an account is closed on AML/KYC grounds, the Operator will handle any funds held on the account in accordance with its legal obligations, which may include reporting the matter to the relevant authorities and withholding funds pending the outcome of any investigation.
HugoBet ensures that all employees who interact with customers, handle transactions, or have access to compliance-sensitive information receive appropriate AML/KYC training upon joining the Operator and on a regular, ongoing basis thereafter. Training covers the legislative framework governing AML and KYC obligations, the Operator's internal policies and procedures, how to identify and escalate red flags and suspicious activity, the prohibition on tipping off, and the correct use of internal reporting channels. Training records are maintained and made available to the relevant authorities upon request.
HugoBet recognises that problem gambling and financial crime can intersect in complex ways. Individuals experiencing gambling-related harm may, in some cases, be more vulnerable to exploitation by those seeking to use online gambling platforms as a vehicle for financial crime, and may also be more likely to engage in financial deception to fund their play. HugoBet's responsible gaming controls — including deposit limits, self-exclusion options, and account monitoring — operate alongside and complement the AML/KYC framework described in this Policy. Players who have concerns about their gambling behaviour are encouraged to contact the support team via 24/7 live chat or email, and to make use of the responsible gaming tools available on hugobetwin.com.
This Policy is reviewed by the Operator's compliance function on a regular basis and updated as necessary to reflect changes in applicable law, regulatory guidance, industry standards, and the Operator's own risk assessment. The current version of this Policy is published on hugobetwin.com and supersedes all previous versions. Customers are advised to review this Policy periodically. Continued use of the Platform following the publication of an updated Policy constitutes acceptance of the revised terms.
Any questions or concerns relating to this Policy, or to a customer's individual KYC verification status, should be directed to HugoBet's support team:
The Operator, HNA Gaming B.V., is responsible for the operation of hugobetwin.com and for the implementation of this Anti-Money Laundering and Know Your Customer Policy in accordance with the terms of Curaçao gaming licence OGL/2024/1191/0663.
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