HugoBet, operated by HNA Gaming B.V. at hugo-bets.co under Curaçao licence OGL/2024/1191/0663, is committed to preventing money laundering, terrorist financing, and financial crime on its platform. This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations HugoBet places on itself and on its customers to ensure that hugo-bets.co remains a safe, compliant, and transparent environment for all players.
Money laundering is the process by which proceeds of criminal activity are disguised to appear as legitimately obtained funds. Terrorist financing involves the provision of funds, however obtained, to support terrorist activity. Both offences carry serious criminal penalties and cause significant harm to society.
HNA Gaming B.V., as the operator of HugoBet, is required to maintain robust AML and KYC controls as a condition of its Curaçao gaming licence (OGL/2024/1191/0663). This Policy is designed to comply with applicable anti-money laundering legislation, the requirements of our licensing authority, and internationally recognised standards including those set by the Financial Action Task Force (FATF).
All employees, contractors, and third-party service providers who interact with customer accounts, payment flows, or compliance functions at hugo-bets.co are bound by the principles set out in this Policy. Customers who register and play at HugoBet are required to cooperate fully with our verification and monitoring procedures.
This Policy applies to:
HugoBet operates a risk-based approach to AML and KYC compliance. This means we allocate our verification and monitoring resources in proportion to the level of risk presented by individual customers, transactions, and patterns of play. Our core commitments are:
KYC verification must be completed before HugoBet will process any withdrawal from a customer's account. This applies regardless of the withdrawal method — whether Visa, Mastercard, bank transfer, or cryptocurrency — and regardless of the amount. The minimum withdrawal at HugoBet is €20 and the monthly withdrawal ceiling is €50,000; no withdrawal within this range will be released without a completed and approved verification.
In addition, HugoBet reserves the right to request KYC documentation at any time during a customer's account lifecycle, including at the point of registration, after a significant deposit, or where our transaction monitoring systems flag unusual activity. Customers may also be asked to verify their account before a bonus is credited or their loyalty cashback is paid, where our risk assessment deems this appropriate.
As a minimum, every customer will be required to provide documents that satisfy the following three verification requirements:
| Verification Requirement | Acceptable Documents |
|---|---|
| Proof of Identity (POI) | Valid government-issued passport, national identity card, or driving licence — must show full name, date of birth, and a clear photograph |
| Proof of Address (POA) | Utility bill, bank statement, or official government correspondence — issued within the past three months and showing the customer's full name and residential address |
| Proof of Payment Method (POP) | Copy or screenshot of the payment method used to deposit — for cards, the front of the card (with middle eight digits obscured) and cardholder name; for bank transfer, a bank statement showing the account number; for crypto, confirmation of the wallet address used |
Documents must be legible, unexpired, and in a format that allows HugoBet's compliance team to assess them clearly. We may request that documents be submitted in colour. Where documents are not in English, HugoBet may require a certified translation at the customer's expense.
In certain circumstances, standard verification is not sufficient and HugoBet will apply enhanced due diligence (EDD). EDD may be triggered by, but is not limited to, the following:
Where EDD is required, HugoBet may request one or more of the following in addition to the standard documents:
Until EDD is satisfactorily completed, HugoBet may restrict the customer's ability to deposit, withdraw, or access bonuses, including loyalty cashback through the 50-level programme.
HugoBet strictly prohibits gambling by persons under the age of 18. Age verification is a mandatory component of our KYC process. If we are unable to confirm that a customer is 18 or over from the documents submitted, the account will be suspended pending further verification. Any deposits made by a player who is found to be under 18 will be returned, and all winnings will be voided.
HugoBet aims to review submitted KYC documents promptly. Our compliance team processes verification requests during operational hours, and we will inform customers by email of the outcome or of any further documents required. Withdrawal processing times shown on hugo-bets.co are contingent on KYC verification being complete; delays caused by incomplete or unsatisfactory documentation are the customer's responsibility.
KYC is not a one-time event. HugoBet conducts ongoing customer due diligence (CDD) throughout the lifecycle of each account. This includes:
Where ongoing monitoring identifies a concern, HugoBet reserves the right to place a hold on the customer's account, suspend withdrawal processing, and escalate the matter to our compliance officers or to the relevant authorities.
All deposits at hugo-bets.co are processed through approved payment methods, which currently include Visa, Mastercard, Apple Pay (via Gumball Pay), Google Pay (via Gumball Pay), bank transfer, and cryptocurrency. The minimum deposit is €10 for most methods (€20 for bonus-qualifying purposes on the welcome package). HugoBet does not accept cash deposits or deposits from unidentified third parties.
Customers are required to deposit only from payment accounts or wallets that are registered in their own name. Deposits from third-party sources are not permitted and, if identified, will result in the deposit being returned and the relevant bonus or winnings being voided. We may request proof of payment method ownership at any time.
Withdrawals are processed post-KYC only. Additional controls include:
HugoBet accepts cryptocurrency deposits and withdrawals. Crypto transactions are subject to the same KYC, AML, and source-of-funds requirements as fiat transactions. In addition:
HugoBet's compliance team and automated monitoring systems are trained to identify indicators of suspicious activity. Red flags that may prompt further investigation or a suspicious activity report include, but are not limited to:
Any employee of HNA Gaming B.V. who identifies or suspects money laundering or terrorist financing in connection with HugoBet must report this to the designated Money Laundering Reporting Officer (MLRO) without delay using our internal reporting procedures. The MLRO is responsible for evaluating the report and determining whether a suspicious transaction report (STR) or suspicious activity report (SAR) should be submitted to the relevant authority.
It is a criminal offence in most jurisdictions to inform a customer — or any other person — that a suspicious activity report has been made, or that an investigation is under way. Accordingly, HugoBet staff are strictly prohibited from disclosing to any customer or third party that their account is under review, that a report has been or may be filed, or that a transaction has been held or declined for AML reasons. If your account is under review, you may be advised only that additional verification is required.
The following activities are strictly prohibited on hugo-bets.co and will result in account suspension, forfeiture of funds, and referral to relevant authorities where appropriate:
HugoBet maintains comprehensive records of all customer identification documents, transaction histories, correspondence, and compliance decisions. Records are retained for a minimum of five years from the date of the relevant transaction or the closure of the customer's account, whichever is later. Records are stored securely in accordance with applicable data protection law and are accessible to regulatory or law enforcement authorities upon lawful request.
The types of records we maintain include:
HNA Gaming B.V. ensures that all staff involved in the operation of hugo-bets.co who have responsibilities relevant to AML and KYC compliance receive adequate training. Training covers:
Training is provided to new staff prior to taking up their role and is refreshed periodically to reflect changes in regulatory requirements, typologies, or internal procedures. HugoBet also maintains an appointed MLRO with appropriate seniority and authority to implement and oversee this Policy.
HugoBet assesses AML and KYC risk at multiple levels:
| Risk Factor | Lower Risk Indicators | Higher Risk Indicators |
|---|---|---|
| Customer Profile | Consistent identity, stable address, verifiable income | PEP status, adverse media, inconsistent information |
| Geography | Low-risk jurisdiction, consistent IP/location | High-risk or sanctioned jurisdiction, VPN use, mismatched location |
| Payment Method | Card or bank transfer in customer's own name | Third-party payment, anonymous crypto, multiple methods |
| Transaction Pattern | Regular, modest deposits consistent with stated profile | Large rapid deposits, minimal play, immediate withdrawal requests |
| Transaction Volume | Activity well within typical player ranges | Activity approaching the €50,000 monthly withdrawal limit |
| Crypto Activity | Wallet in customer's name, clean blockchain history | Wallet linked to mixing services, darknet, or flagged addresses |
Customers assessed as higher risk will be subject to enhanced scrutiny, including additional documentation requests, increased monitoring frequency, and potentially restricted access to certain features until their status is satisfactorily resolved.
HugoBet screens all customers against applicable international sanctions lists, including those maintained by the United Nations, the European Union, and other relevant bodies. Customers who are found to be listed on a sanctions register will have their accounts immediately suspended and any funds held pending instruction from the relevant authority. HugoBet will not process any transaction where doing so would constitute a breach of applicable sanctions law.
HugoBet recognises that problem gambling and money laundering can sometimes share behavioural indicators — for example, erratic or escalating deposit behaviour. Our compliance and responsible gambling teams work in coordination to ensure that customers displaying concerning patterns are assessed from both a safeguarding and a financial crime perspective. Players who wish to set deposit limits, take a cooling-off period, or self-exclude may do so through the responsible gaming tools available on hugo-bets.co. These options remain available regardless of a customer's KYC status, and requesting them will not delay the processing of a verification review already under way.
HNA Gaming B.V. and HugoBet will cooperate fully with law enforcement agencies, regulatory bodies, and our licensing authority — the Curaçao Gaming Control Board — in any investigation related to money laundering, terrorist financing, or other financial crime connected to activity on hugo-bets.co. This includes providing transaction records, account information, and compliance documentation in response to lawful requests. We will not obstruct, delay, or seek to circumvent any such investigation.
This AML/KYC Policy is reviewed on a regular basis — and in any event whenever there is a material change to the regulatory environment, our payment infrastructure, or our product offering — to ensure it remains current, effective, and compliant with our obligations under Curaçao licence OGL/2024/1191/0663. The most up-to-date version of this Policy is always available at hugo-bets.co. Customers are encouraged to review it periodically. Continued use of HugoBet following any update to this Policy constitutes acceptance of its terms.
If you have questions about this Policy, or if you wish to submit documents for KYC verification, please contact the HugoBet compliance team via:
Please do not send original identity documents by post. All documentation should be submitted electronically through the secure upload facility provided within your account, or as directed by a member of our compliance team.
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