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Home › AML / KYC Policy

This Anti-Money Laundering and Know Your Customer Policy ("Policy") applies to all persons who register and use the services available at shakebetsonline.com ("the Site"), operated by May Sun Services S.A. ("Shakebet", "we", "us", "our") under Anjouan licence number ALSI-202411025-FI1. Shakebet is committed to maintaining the highest practicable standards of financial integrity, preventing the use of its platform for money laundering, terrorist financing, or any other form of financial crime, and fulfilling all obligations imposed by applicable legislation and its licensing conditions.

1. Purpose and Scope

The purpose of this Policy is to set out the principles, procedures, and controls that Shakebet applies to detect, prevent, and report activities that may constitute money laundering, terrorist financing, or related predicate offences. This Policy applies to:

  • All registered customers of shakebetsonline.com;
  • All employees, contractors, and agents acting on behalf of May Sun Services S.A.;
  • All deposits, withdrawals, and gaming transactions processed through the Site, whether in fiat currency or any of the eight supported cryptocurrencies (Bitcoin, Ethereum, BNB, USDC, Dogecoin, TRON, Bitcoin Cash, and Litecoin, including USDT across BEP20, ERC20, and TRC20 networks).

Shakebet reserves the right to amend this Policy at any time in order to reflect changes in applicable law, licensing requirements, or internal risk assessments. Continued use of the Site following the publication of any amendment constitutes acceptance of the revised Policy.

2. Legal and Regulatory Framework

Shakebet operates under the regulatory authority of the Anjouan Offshore Finance Authority and holds licence number ALSI-202411025-FI1. In discharging its obligations under that licence, Shakebet applies AML and KYC controls consistent with internationally recognised standards, including the recommendations of the Financial Action Task Force (FATF) and relevant European Union directives, to the extent that they inform best practice within the iGaming sector.

May Sun Services S.A. has appointed a designated Money Laundering Reporting Officer (MLRO) who holds primary responsibility for implementing this Policy, monitoring compliance, receiving internal suspicious activity reports, and making disclosures to the relevant authorities where required.

3. Risk-Based Approach

Shakebet adopts a risk-based approach to AML and KYC, meaning that the intensity of due diligence applied to any customer or transaction is proportionate to the assessed risk of money laundering or terrorist financing associated with that customer or transaction. Risk is assessed by reference to, among other factors:

  • The customer's country or territory of residence and the associated jurisdiction risk;
  • The payment methods used, including the distinction between fiat instruments (such as Visa, Mastercard, Trustly, Klarna, Boku, Wise, Revolut, Zimpler, and Payoneer) and cryptocurrency transactions;
  • The volume, frequency, and value of deposits and withdrawals relative to the customer's stated profile;
  • The customer's position within the Shakebet loyalty programme (Bronze through to Mega tier), particularly where high cashback limits or the elevated daily withdrawal limit of €100,000 available to Mega tier players are engaged;
  • Unusual patterns of bonus usage, multi-account indicators, or structuring behaviour;
  • Any information received from third-party screening databases, sanctions lists, or law enforcement sources.

Customers assessed as presenting a higher risk will be subject to Enhanced Due Diligence (EDD) as described in Section 6 below.

4. Customer Due Diligence — Standard Verification (KYC)

4.1 When KYC Is Required

Shakebet will request identity verification documentation from a customer at any of the following trigger points, whichever occurs earliest:

  • Prior to processing the customer's first withdrawal request;
  • When cumulative deposits reach or exceed the applicable internal threshold;
  • When cumulative withdrawals reach or exceed the applicable internal threshold;
  • When transaction patterns, account behaviour, or third-party screening results generate a risk alert;
  • At any time that the MLRO or compliance team considers it necessary to verify or update the customer's identity.

Regardless of the above triggers, Shakebet may request documentation at account registration if the customer's risk profile so warrants. No withdrawal — whether by fiat or cryptocurrency — will be released until all outstanding KYC requirements have been satisfied to Shakebet's reasonable satisfaction.

4.2 Identity Documents Required

To satisfy standard Customer Due Diligence (CDD), a customer will typically be required to provide:

  • Proof of Identity (POI): A valid, unexpired government-issued document bearing the customer's full name, date of birth, and photograph — such as a passport, national identity card, or driving licence;
  • Proof of Address (POA): A document issued within the preceding three months confirming the customer's residential address — such as a utility bill, bank statement, or official government correspondence;
  • Payment method verification: Where required, confirmation that the deposit payment method is registered in the customer's name (for example, a partial card image, screenshot of an e-wallet account, or cryptocurrency wallet ownership confirmation).

All documents must be submitted in a clear, legible format. Shakebet reserves the right to request certified copies or additional documents where the quality or authenticity of a submission is in doubt.

4.3 Verification of Cryptocurrency Accounts

Because Shakebet processes deposits and withdrawals in eight cryptocurrencies — including Bitcoin, Ethereum, USDT (BEP20, ERC20, TRC20), and others — the compliance team applies additional scrutiny to cryptocurrency transactions. Customers using cryptocurrency may be asked to:

  • Confirm ownership of the sending wallet address;
  • Provide blockchain transaction references for review;
  • Demonstrate that the wallet is not associated with high-risk or blacklisted addresses, as determined by Shakebet's transaction-monitoring tools.

Withdrawals to cryptocurrency wallets will only be processed to the same wallet address used for the corresponding deposit, unless the customer has passed enhanced verification confirming ownership of the alternative address.

5. Source of Funds and Source of Wealth

In addition to identity verification, Shakebet may require customers to demonstrate the legitimate origin of funds deposited or wagered on the Site. A Source of Funds (SOF) or Source of Wealth (SOW) request may be triggered by:

  • High-value deposits or withdrawals, including those approaching or exceeding the bank transfer maximum of €10,000 per transaction;
  • Cumulative activity that is disproportionate to the customer's stated occupation or known financial profile;
  • Customers who have progressed to higher loyalty tiers (particularly Diamond, Ruby, Emerald, Sapphire, Obsidian, or Mega) where weekly cashback maxima and withdrawal limits are materially elevated;
  • Any transaction pattern that the MLRO considers inconsistent with normal recreational gaming behaviour.

Acceptable SOF/SOW evidence may include, but is not limited to, recent payslips, tax returns, business accounts, investment statements, inheritance documentation, or a signed and dated written explanation accompanied by supporting evidence. Shakebet will treat all information provided in response to an SOF/SOW request with strict confidentiality.

6. Enhanced Due Diligence

Enhanced Due Diligence (EDD) is applied to customers who are identified as presenting a higher risk of money laundering or terrorist financing. EDD triggers include, without limitation:

  • Residency in, or transactions originating from, a jurisdiction identified by the FATF as high-risk or subject to a call for action;
  • Identification of the customer as a Politically Exposed Person (PEP) or a close associate or family member of a PEP;
  • Adverse media findings, sanctions list matches, or law enforcement alerts;
  • Transactions structured in a manner that suggests an attempt to avoid reporting thresholds;
  • Unusual cryptocurrency activity, including deposits from mixer services, high-risk exchanges, or flagged wallet addresses;
  • Any other factor that the MLRO or compliance team considers to elevate the risk profile above standard levels.

Where EDD is applied, the compliance team will conduct a more detailed review of the customer's identity, activity, and funding sources. The MLRO will determine whether the customer relationship may continue, be restricted, or must be terminated, and whether a suspicious activity report must be filed.

7. Politically Exposed Persons

Shakebet screens all customers against recognised PEP databases at the point of registration and on an ongoing basis. A PEP is an individual who holds, or has held within the preceding twelve months, a prominent public function, including but not limited to heads of state, senior government officials, senior judiciary members, senior military officials, senior executives of state-owned enterprises, and senior officials of international organisations. Immediate family members and known close associates of PEPs are treated equivalently.

Where a customer is identified as a PEP, Shakebet will:

  • Obtain senior management approval before establishing or continuing the business relationship;
  • Apply full EDD, including SOF/SOW documentation;
  • Conduct enhanced and more frequent ongoing monitoring of the customer's transactions.

8. Sanctions Screening

Shakebet screens all customers and associated parties against applicable international sanctions lists, including those maintained by the United Nations, European Union, UK Office of Financial Sanctions Implementation (OFSI), and the United States Office of Foreign Assets Control (OFAC), as well as any lists specified under Shakebet's Anjouan licence conditions. Screening is conducted at account registration and on an ongoing basis whenever sanctions lists are updated or a material change to the customer's profile occurs.

Where a potential match is identified, the customer's account will be suspended pending MLRO review. Confirmed matches will result in immediate account closure, freezing of any associated funds, and a report to the relevant authorities.

9. Ongoing Monitoring

KYC is not a one-time event. Shakebet's compliance systems conduct continuous monitoring of customer accounts and transactions. Ongoing monitoring activities include:

  • Automated transaction monitoring to detect unusual patterns, including rapid cycling of funds, large round-sum transactions, or significant deviations from established account behaviour;
  • Periodic review and refresh of KYC documentation, particularly for higher-risk customers or those with elevated activity levels;
  • Monitoring of withdrawal requests relative to deposit history, wagering activity, and game-type usage to identify structuring or fund-cycling without genuine gameplay intent;
  • Review of bonus and cashback utilisation, particularly where cashback — which is paid as fully withdrawable real cash with no wagering requirement — is the primary withdrawal source relative to gameplay losses;
  • Monitoring of loyalty programme progression where rapid tier advancement is inconsistent with the customer's declared profile.

10. Suspicious Activity Reporting

All employees and contractors of May Sun Services S.A. are required to report any suspicion of money laundering, terrorist financing, or related activity to the MLRO without delay using the internal reporting procedure. The MLRO will review each report and determine whether it is necessary to make an external disclosure to the relevant competent authority.

It is a serious offence under applicable law to "tip off" a customer who is the subject of a suspicion report or an investigation. Accordingly, where a customer account is under review for AML purposes, no information that could prejudice that investigation will be disclosed to the customer or to any third party not authorised to receive it.

11. Record Keeping

Shakebet retains all KYC documentation, transaction records, and AML-related correspondence for a minimum of five years from the date of the relevant transaction or the termination of the customer relationship, whichever is later. Records are held securely and in a format that permits their timely retrieval in response to a lawful request from a competent authority.

Records retained include, without limitation:

  • Copies of all identity and address verification documents submitted;
  • SOF/SOW documentation and correspondence;
  • Full transaction histories, including deposit and withdrawal records across all payment methods and currencies;
  • Internal suspicious activity reports and MLRO decisions;
  • Results of PEP and sanctions screening;
  • Account communication logs.

12. Refusal of Transactions and Account Closure

Shakebet reserves the right, at its sole discretion and without prior notice, to:

  • Decline to process any deposit or withdrawal where the customer has not completed KYC to Shakebet's satisfaction;
  • Place a temporary hold on funds pending the outcome of a compliance review;
  • Refuse to process a withdrawal to a payment method or cryptocurrency wallet that differs from the method used to deposit, where this would present a money-laundering risk;
  • Close a customer account and retain funds where required by law, a court order, or a direction from a competent authority;
  • Report the matter to the relevant law enforcement or regulatory authority.

Where an account is closed for AML-related reasons, Shakebet will not be obliged to disclose the reason for closure to the customer, and will act in accordance with any applicable tipping-off restrictions.

13. Player Protection and Responsible Gaming Interaction

Shakebet recognises that problem gambling behaviour can, in certain circumstances, intersect with financial crime indicators. Customers who exhibit signs of disordered gambling — such as escalating deposit volumes, repeated attempts to reverse withdrawals, or erratic account activity — will be referred simultaneously to Shakebet's responsible gaming team and, where appropriate, to the MLRO for AML assessment. Shakebet operates responsible gaming tools including deposit limits, session controls, and self-exclusion facilities, which form part of the overall framework for identifying and protecting vulnerable customers.

14. Staff Training

All personnel at May Sun Services S.A. who are involved in customer-facing activity, payment processing, compliance, or management receive mandatory AML and KYC training at induction and on a regular ongoing basis. Training covers the recognition of suspicious activity, the correct internal reporting procedure, the prohibition on tipping off, record-keeping obligations, and the legal consequences of non-compliance. Training records are maintained by the MLRO and are available for inspection by the relevant licensing authority upon request.

15. Contact and Reporting

Customers who have questions regarding this Policy or their KYC obligations may contact Shakebet's compliance team via the contact details available on shakebetsonline.com. All queries will be handled in strict confidence. Please note that the compliance team is unable to confirm or deny whether a specific account is under AML review.

This Policy was last reviewed and updated in 2025. May Sun Services S.A. reviews this Policy at least annually, and whenever there is a material change in applicable law, licensing requirements, or the risk environment in which Shakebet operates.

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