This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Zephyr Holding Sociedad de Responsabilidad Limitada ("we", "us", "our"), operator of inky.casino and inky.bet (together, "inky"), with respect to the prevention of money laundering, terrorist financing, and related financial crime. inky is licensed by the Anjouan Offshore Financial Authority. All players, regardless of payment method or currency, are subject to this Policy as a condition of using the platform.
Money laundering is the process by which the proceeds of criminal activity are disguised so as to appear legitimate. Terrorist financing involves the provision or collection of funds intended to be used to carry out terrorist acts. Both represent serious threats to the integrity of the financial system and to inky's customers.
This Policy applies to:
The objectives of this Policy are to:
inky.casino is operated by Zephyr Holding Sociedad de Responsabilidad Limitada, incorporated in Costa Rica, and holds a licence issued by the Anjouan Offshore Financial Authority. Players should be aware that inky does not hold a licence from the Dutch Kansspelautoriteit (KSA) or equivalent regulatory bodies in other jurisdictions. Players are solely responsible for verifying that their use of inky.casino is lawful in their own jurisdiction.
Although inky operates under an offshore licence, we voluntarily adopt AML and KYC standards consistent with the Financial Action Task Force ("FATF") recommendations and internationally recognised best practice for online gaming operators. This commitment reflects our determination to maintain the highest standards of player protection and financial integrity.
inky appoints a designated AML Compliance Officer ("AMLCO") who is responsible for:
Staff who have concerns about a transaction, a customer's behaviour, or compliance matters should escalate these to the AMLCO promptly via the internal reporting procedures. Players who wish to contact inky on compliance matters may do so via [email protected].
inky adopts a risk-based approach to AML and KYC. This means that the level of due diligence applied to any given customer or transaction is proportionate to the money-laundering or terrorist-financing risk that customer or transaction presents. Factors considered in our risk assessment include, but are not limited to:
Customers identified as higher risk will be subject to enhanced due diligence. Where a customer presents an unacceptably high risk that cannot be mitigated through enhanced measures, inky reserves the right to refuse or terminate the business relationship.
Customer due diligence is conducted at the following points:
To verify identity, inky may request one or more of the following documents. All documents must be valid, undamaged, and clearly legible. Copies submitted must show all four corners of the document.
| Document Type | Acceptable Examples | Purpose |
|---|---|---|
| Government-issued photo ID | Passport, national identity card, driving licence | Confirm full legal name, date of birth, nationality |
| Proof of address | Utility bill, bank statement, official government letter (dated within 90 days) | Confirm residential address |
| Proof of payment method | Bank statement, screenshot of e-wallet account, photograph of payment card (showing name and last four digits only) | Confirm ownership of the payment instrument used |
| Source of funds | Recent payslips, bank statements, tax returns, business accounts, proof of investment proceeds | Confirm the legitimate origin of funds deposited |
| Source of wealth | Employment contracts, inheritance documentation, property sale evidence | Required under enhanced due diligence |
inky verifies that the name, date of birth, and address provided at registration match the documents submitted. We also verify that the customer is aged 18 or over, in line with our minimum age requirement.
Whilst inky may request KYC documentation at any stage of the customer relationship, the following thresholds trigger a mandatory verification review as a minimum:
| Event | Threshold / Trigger |
|---|---|
| Withdrawal request | Any withdrawal — minimum withdrawal is €40 (fiat); KYC must be cleared before funds are released |
| Cumulative deposits | Triggered at internal risk thresholds set by the AMLCO; customers will be notified when verification is required |
| Monthly withdrawal cap | Non-jackpot withdrawals are capped at €15,000 per month; activity approaching or at this level triggers enhanced review |
| High-value single transaction | Any single deposit or withdrawal of significant value as defined in our internal risk matrix |
| Suspicion of money laundering | Irrespective of amount — CDD and internal reporting are initiated immediately |
inky will not process a withdrawal until the customer's identity has been verified to our satisfaction. We aim to review submitted KYC documents promptly; however, processing times may vary depending on the volume of requests and the complexity of documentation provided.
Customer due diligence is not a one-time event. inky continuously monitors active accounts for:
Where monitoring triggers a concern, the relevant account may be temporarily restricted pending further investigation. inky is not obliged to inform a customer that their account is under review if doing so could constitute "tipping off" in respect of a suspicious activity report.
Enhanced due diligence applies to customers who present a higher degree of AML or terrorist-financing risk. EDD requires more detailed documentation and closer ongoing scrutiny. inky applies EDD in the following circumstances as a minimum:
A politically exposed person is an individual who holds or has held a prominent public function, including but not limited to heads of state, senior politicians, senior government officials, 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 as connected to one, inky will:
inky screens all customers against applicable international sanctions lists, including those published by the United Nations Security Council, the European Union, the Office of Foreign Assets Control (OFAC), and the UK HM Treasury. Any match or potential match results in the immediate suspension of the account and a report to the AMLCO. inky will not provide services to any individual or entity subject to applicable sanctions.
Customers who are resident in, or whose funds originate from, jurisdictions identified as high risk by the FATF or other relevant bodies are subject to enhanced due diligence. inky reserves the right to restrict or decline service to customers in certain jurisdictions entirely.
Customers whose deposit or withdrawal activity approaches or exceeds the monthly non-jackpot withdrawal cap of €15,000 will be required to provide enhanced documentation, including source of funds and, where appropriate, source of wealth evidence. This applies regardless of the payment method used.
inky accepts cryptocurrency deposits and withdrawals. The average payout speed for crypto transactions is approximately 9 minutes 35 seconds. Given the pseudonymous nature of blockchain transactions, all cryptocurrency deposits are subject to blockchain analytics screening. Where the origin of cryptocurrency funds is flagged as high risk, tainted, or associated with illicit activity, inky will apply EDD and may freeze or return the relevant funds pending investigation. Customers may be asked to provide additional information about the source of their cryptocurrency holdings.
All players must register a single account at inky.casino. Duplicate accounts are prohibited. At registration, customers are required to provide:
By registering, the customer confirms that all information provided is accurate, complete, and up to date, and that they are legally permitted to use online gambling services in their jurisdiction.
When verification is requested, customers must submit documents via the secure upload facility within their account, or as directed by the inky support team at [email protected]. Documents should be:
inky reserves the right to request original documents or notarised copies in cases of doubt about the authenticity of submitted materials.
Following submission of documents, inky will review and reach one of the following outcomes:
Where a customer fails to provide requested KYC documentation within a reasonable timeframe:
inky is not liable for any losses, including losses of bonus value or time-sensitive promotions, arising from a customer's failure to complete verification within the requested timeframe.
inky accepts a range of fiat and cryptocurrency payment methods. The specific payment methods available to any given customer may vary depending on their country of residence. All payment methods are subject to the same AML controls as set out in this Policy.
| Parameter | Amount |
|---|---|
| Minimum deposit | €20 |
| Minimum withdrawal (fiat) | €40 |
| Monthly withdrawal cap (non-jackpot) | €15,000 |
| Average crypto payout speed | Approximately 9 minutes 35 seconds |
| Card / bank transfer payout time | Up to 48 hours |
inky applies a strict return-to-source policy. Withdrawals must, wherever technically feasible, be returned to the same payment method used to make the deposit. This prevents the laundering of funds through the platform by depositing via one method and withdrawing to another. Where a customer's original payment method is no longer available, additional verification will be required before an alternative withdrawal route is approved.
inky does not accept deposits from, or process withdrawals to, third-party payment methods, meaning payment accounts not registered in the customer's own name. Any deposit identified as originating from a third party will be returned and the account suspended pending investigation. Customers must not use shared or borrowed payment methods to fund their account.
Structuring — the deliberate breaking up of transactions into smaller amounts in order to avoid detection or scrutiny — is prohibited and constitutes a money-laundering red flag. inky's monitoring systems are designed to detect structuring patterns. Any suspected structuring will be reported internally and may result in an external suspicious activity report.
inky's compliance team and automated monitoring systems are alert to the following red flags, which may indicate money laundering or suspicious activity:
Any member of inky's staff who becomes aware of, or has reasonable grounds to suspect, that a customer is engaged in money laundering or terrorist financing must report this to the AMLCO immediately, using the internal suspicious activity reporting procedure. Staff must not discuss concerns with the customer concerned, as doing so may constitute tipping off.
The AMLCO will review all internal reports and, where there are reasonable grounds to suspect money laundering or terrorist financing, will file a report with the Anjouan Offshore Financial Authority and any other competent authority as required. inky cooperates fully with law enforcement agencies and competent authorities in connection with any investigation into suspected financial crime.
inky is legally and ethically prohibited from informing a customer that a suspicious activity report has been made in connection with their account, or that their account is under AML investigation. Customers whose accounts are under review may find that certain functions are temporarily unavailable without detailed explanation. This is a necessary and lawful consequence of our compliance obligations.
inky maintains comprehensive records in accordance with AML best practice. Records retained include:
Records are retained for a minimum of five (5) years from the date of the relevant transaction or the date on which the customer relationship ends, whichever is the later, or for such longer period as may be required by applicable law or regulation. Records are stored securely and accessed only by authorised personnel.
Problem gambling and financial crime are not entirely distinct issues. A customer who appears to be depositing funds well beyond their evident means may be doing so because those funds are of illegitimate origin, because they are in financial distress, or both. inky's AML monitoring and responsible gambling monitoring are therefore operated in close coordination.
All players must be at least 18 years of age. inky operates responsible gambling tools including deposit limits, wagering limits, cooling-off periods, and self-exclusion. Where our AML review raises concerns about a customer's financial circumstances — not just the origin of funds but the sustainability of their gambling expenditure — we will make responsible gambling interventions in parallel with any compliance action. Players experiencing difficulties may contact our 24/7 support team via live chat or at [email protected].
All inky employees and contractors who interact with customers, process transactions, or have any role in compliance are required to complete AML and KYC training. Training covers:
Training is provided at induction and refreshed at regular intervals, or immediately where there is a material change to this Policy or the regulatory landscape. Training records are maintained by the AMLCO.
Personal data collected by inky for AML and KYC purposes is processed solely for the purposes of fulfilling our legal and regulatory obligations, preventing financial crime, and verifying customer identity. Such data is held securely, is not sold to third parties, and is disclosed externally only where required by applicable law, regulation, or lawful authority. Customers have rights in respect of their personal data as set out in inky's Privacy Policy. However, those rights may be subject to limitations where their exercise would conflict with our AML obligations or impede a lawful investigation.
inky reserves the right to amend, update, or replace this Policy at any time in order to reflect changes in applicable law, regulatory guidance, business practice, or operational requirements. The current version of this Policy will always be available at inky.casino. Continued use of inky.casino following notification of any material change constitutes acceptance of the revised Policy. This Policy was last reviewed in August 2026.
Questions or concerns relating to this Policy, or requests for further information about inky's AML and KYC procedures, should be directed to:
inky is committed to maintaining a safe, fair, and compliant gaming environment. We take our obligations under this Policy seriously and expect all customers and staff to do the same.
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