Carat Casino Starts Source-of-Wealth Checks When Deposits Pass 45% of a Player's Gross Income

The Carat Casino KYC policy captured on 29 August 2026 is headed "Know Your Customer Policy" and "LEOPARD B.V", and does not mention Carat Casino by name. It reads as the operator's internal compliance manual: it refers to "the Risk Assessment excel file" and keeps a drafting note beside one declaration ("we draft it, and customer accepts it"). Suspicious activity is reported to the Curaçao FIU, and screening runs through a provider called iDenfy.

• Three levels, and a threshold in XCG. Level 1 at sign-up asks for name, date of birth, address, email, an identity document and a selfie or 3D liveness check. Level 2 becomes mandatory when deposits reach XCG 4,000, counted over a 365-day period from the first deposit, and adds employment status, proof of income, gross annual income and proof of address. The figure appears only as XCG, a currency code the document never names or converts.
• The policy contradicts itself on XCG 4,000. The level table sends a player who reaches XCG 4,000 to Level 2. Section 15.5 says: "The threshold has been devised so no customer will exceed XCG 4000 or equivalent without prompting Level 3 due diligence." A player cannot tell from the document which level XCG 4,000 triggers.
• 45% of gross income. Enhanced due diligence is mandatory when "The Client attempts to deposit more than the allowed 45% threshold based on the users Gross Income". The level table also lists 15,000 euro of deposits in one year as a Level 3 trigger. Once the source of wealth is verified, the 45% is recalculated on the verified amount. How much a player can deposit before the documents are due depends on an income the casino has to see first.
• What counts as proof. A salary needs three months of bank statements showing it paid in. An inheritance needs a copy of the deceased's will, a gift needs a letter and certified identity documents from the donor, crypto mining needs a ledger and the wallet address and transaction hash, and gambling winnings need a receipt of winnings plus proof of where the original deposit came from. Corporate crypto wallets are not accepted as a source of funding. A gift brings a second person's identity documents into the player's file.
• 30 days, then a hard block. When an automatic request goes unanswered, the account is blocked for withdrawals within those 30 days and hard-blocked after, and the funds are to be sent back. A manually prompted request left unanswered for 30 days is escalated and may lead to a suspicious transaction report. Elsewhere the policy says an account may be restricted while due diligence is pending. The money stays in the account while the clock runs, and the withdrawal is what stops first.
• What comes back on a closed account. "Unless a STR has been raised and an appropriate period has passed in which the customer has still not completed CDD, the account may be closed, and deposited funds still present on the customer’s account will be returned to the deposit method, where possible, less any charges incurred by the business for transmission to this destination." The sentence names deposited funds and transmission charges, and says nothing about winnings.
• Screening goes past convictions. Every player is screened by iDenfy at the first deposit and the client list is rescanned weekly, with sanctions lists checked daily. Negative media screening covers people under investigation and allegations as well as convictions, and verification may draw on social media. An allegation in the press is enough to open an evaluation.
• Proof does not last. Accounts are reviewed every 12 months at high risk, 24 months at medium risk and 30 months at low risk, and source of wealth is re-verified every 12 months for high-risk players and every 24 months for medium-risk ones. Documents accepted once can be asked for again.

Most of the document is anti-money-laundering procedure written out at length. What reaches the player is two thresholds and a clock: XCG 4,000, 45% of gross income, and 30 days before a withdrawal block becomes a hard block.