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Player Complaints Policy

1. Policy Overview

This Complaints Policy sets out the structure for receiving and resolving player complaints and disputes. It aims to deliver a transparent, equitable, and efficient process in line with Article 5.3 of the National Ordinance on Games of Chance (Landsverordening op de kansspelen, LOK). Compliance with this Policy is a requirement under the LOK; non-compliance may be addressed by the Curaçao Gaming Authority (CGA) through its supervisory, monitoring, and enforcement powers.

The Policy ensures that players have access to a clear and effective complaints pathway, including free alternative dispute resolution (ADR) services that emphasize independence and quality.

Pursuant to Article 5.3 of the LOK, additional rules, policies, and guidelines concerning complaints and ADR may be introduced.

  • The operator’s complaints policy for players must be clearly included in, or referenced from, the operator’s Terms and Conditions and must describe all Stages of Complaint Resolution (Clause 3.2).
  • At the operator’s discretion, the policy may be published as a standalone document and linked from the website homepage and/or the registration page.
  • Subject to applicable private law, the operator may require players to explicitly acknowledge acceptance of the Complaints Policy (e.g., via a tick box, pop-up, or email confirmation).
  • The operator may also incorporate acceptance of the Complaints Policy into the registration workflow.

This Complaints Policy reflects regulatory obligations under the LOK and does not alter applicable private law, including provisions of Book 6 of the Civil Code of Curaçao on general terms and conditions. Operators remain independently responsible for meeting all civil law requirements and should obtain appropriate legal advice to ensure their complaints procedures and Terms and Conditions align with private law.

2. Definitions

2.1 Player Interaction

Any written message initiated by a player and addressed to the operator’s customer support team, including general inquiries, feedback, or requests for information, assistance, or clarification.

2.2 Complaint

A written statement from a player expressing dissatisfaction with the operator’s services, decisions, terms, or conduct, indicating an expectation of a response or remedy. For Reporting purposes (Clause 6), a complaint exists when a Complaint Submission Form (Clause 3.2 paragraph 3) has been submitted to the operator and/or the matter has been escalated to ADR.

2.3 Dispute

A complaint that remains unresolved to the player’s satisfaction following the internal process and has been escalated either within the organization or to an independent third party (e.g., an ADR provider or a court).

3. Complaint Submission Process

3.1 Complaint Window

  1. This Policy applies to all players of operators licensed under the LOK from the date their licence is issued, and to operators licensed under the NOOGH framework from the moment they were granted a green or orange dynamic seal.
  2. Players may submit a complaint free of charge at any time within six months of the bet settlement or the incident prompting the complaint.
  3. For P2P (e.g., poker) or ante-post fixed-odds betting, the six-month period begins after settlement or the conclusion of the specific event, not at wager placement.
  4. For in-running sports betting complaints, customers should be advised that although a complaint may be filed within six months, prompt action might be required if the investigation relies on data which—due to the nature of in-running betting—may no longer be available after a short time, where the operator cannot reasonably be expected to retain such data longer…

3.2 Stages/Escalation of Complaint Resolution

  1. Only the registered player may file a complaint. Article 1.3(c) of the LOK prohibits a player from selling, donating, renting, leasing, pawning, or pledging any claim against a CGA-licensed operator.
  2. As a first step, the operator must provide customer support via email and/or live chat.
  3. An official Complaint Submission Form must be made available to players.
    1. The form may be downloadable (to complete and submit by email or upload) and/or provided as an online form to be completed and submitted on the website.
    2. At minimum, the form must include:
      1. Complainant’s name, address, and place of residence.
      2. Complainant’s account number (if applicable).
      3. Dates of the complaint and of the disputed event.
      4. A description of the conduct being disputed (with selectable predefined categories where applicable).
    3. The form must be available in English and in the language of the site/domain used by the player.
    4. The operator may request supporting documentation from the player. Any additional requests must be reasonable in the context of resolving the complaint.
  4. The operator must provide players with an ADR option, subject to Clause 5.
  5. Except where mutually agreed under specific ADR terms (Clause 5), the operator must not restrict the player’s right to pursue legal action personally.

3.3 Role of the CGA

  1. The operator must clearly describe the CGA’s role to players within the Terms and Conditions.
  2. The CGA does not resolve or adjudicate individual player complaints concerning gambling transactions on operator websites.
  3. Unless handling is deemed inadequate, decisions by the operator and/or ADR provider will not be reviewed or overturned by the CGA.
  4. Notwithstanding 2. and 3., the operator must not prevent players from contacting the CGA directly regarding issues such as malpractice, licence breaches, or whistleblowing.
  5. While the CGA does not mediate individual disputes, it may use complaint information to inform supervisory and enforcement activities.

4. Complaint Resolution Process

4.1 Timeline: Responsible Gaming Complaints

Complaints relating to responsible gaming must be prioritized due to potential impacts on player welfare. A complaint should be categorized as responsible gaming where it concerns targeting of Vulnerable Players, the availability or timely application of self-exclusion/cooling-off and the required outcomes defined in the Responsible Gaming policy.

Operators must use best efforts to resolve such cases within five business days.

Within two days of receiving a complaint, the operator will:

  • Acknowledge receipt in writing.
  • Explain the steps of the complaint handling process.
  • Indicate the typical timeframe for resolution of such cases.

If additional time is needed to reach a reasonable, informed decision, the player must be notified. Any operator-caused delay may not exceed two weeks. If the delay is due to missing or slow player responses, the period may be extended by no more than an additional two weeks.

4.2 Timeline: All Other Complaint Types

The operator will evaluate and respond within four weeks. Where justified by complexity or incomplete information, this may be extended once by a further four weeks, with prior written notice to the player.

Within one week of receiving a complaint, the operator will:

  • Confirm receipt in writing.
  • Outline how the complaint will be processed.
  • Provide the average expected resolution timeline.

4.3 Response and Resolution

The player will always receive a written final decision.

The response will consist of one of the following:

  1. A reasoned final outcome/resolution, with supporting evidence where necessary or appropriate.
  2. Detailed reasons for declining to handle the complaint. If further information is needed to fully address the matter, the operator must have requested it within the initial four-week period. If the player fails to provide it within that period, the operator may reject the complaint.
  3. If the player remains dissatisfied and lodges a further complaint, they must be advised of the option to escalate to an independent ADR body.

4.4 Artificial Intelligence (AI)

AI tools may be used under this Policy subject to the following conditions:

  1. Where a complaint is identified as a Responsible Gaming matter (Clause 4.1), communications must be handled by a human agent rather than AI.
  2. Complaints reasonably deemed complex must be managed by a human, not AI.
  3. AI outputs must be monitored to ensure recommendations are reasonable and consistent across similar complaints.

5. Alternative Dispute Resolution

To comply with LOK licensing conditions, every licensed operator must make independent ADR services available to players in line with the ADR Policy.

  1. The operator’s Terms and Conditions must include complete information about the ADR process.
  2. Within one month of publication of the Certified ADR Providers on the official website, operators must upload to the CGA Portal an agreement with at least one CGA-certified ADR entity.
  3. If a complaint cannot be resolved internally, players may escalate to an independent ADR provider free of charge; the operator bears all ADR costs.
  4. Once an ADR process is concluded, it cannot be restarted by either party with a different ADR entity.
  5. If the player withdraws from an ongoing ADR process, they should not be able to revive the dispute at a later date.
  6. Provision of ADR is mandatory. If the operator sets ADR parameters to deter abuse (e.g., requiring ADR before legal action, the binding nature of outcomes on the player, or a minimum claim threshold), the CGA recommends careful consideration and independent legal advice regarding applicable civil law.

The CGA will consider all relevant circumstances when evaluating whether anti-abuse measures are justified. For example, in very low-value claims, concerns about misuse may be legitimate.

Nonetheless, each case must be assessed on its own merits. For instance, where a claim involves admission of a self-excluded person, the CGA expects it to be treated seriously regardless of monetary value.

6. Record-Keeping and Reporting

The operator will:

  1. Submit reports to the CGA on January 15 and June 15 summarizing complaints submitted since the previous period via the Complaint Submission Form. The first reports are due January 2026.
  2. Include in the report:
    1. Total number of complaints received.
    2. Total number of resolved complaints (upheld and rejected).
    3. Number of pending or unresolved cases.
    4. Breakdown by complaint category.
    5. Number escalated to ADR.
    6. Number and details of complaints where legal action has been initiated by a player.
  3. Maintain transparency and compliance with ADR outcomes and regulatory changes.
  4. Note that ADR providers have their own reporting duties under the CGA’s ADR Policy.
  5. Retain records of unresolved complaints and those escalated to ADR or legal proceedings for the lesser of five years or the period required by data protection, limitation statutes, or other applicable laws/guidelines.
  6. Recognize that the CGA may request access at any time to complaint records and information on pending disputes.

7. Terms and Conditions

A statement of the Complaints Procedure must be clearly visible and accessible on the operator’s website as a separate link or document.

The Complaints Procedure must also be explicitly described within the Terms and Conditions.

At a minimum, the information must include:

  1. Links to customer support and details on how to contact the operator.
  2. A description of the information required to submit a complaint and links to the online form and/or downloadable PDF/Word document.
  3. Timelines for acknowledgment, response, and resolution.
  4. Player rights to complain, including access to ADR services and regulatory escalation.
  5. An explanation of the potential effects of an ADR decision and how it may impact the player’s right to further legal or judicial remedies.
  6. Details of the ADR process and player entitlements.
  7. Contact details for the ADR provider(s).
  8. A clear statement that the CGA does not mediate individual disputes; however, players who believe the operator has breached regulations may contact the CGA.

8. Reasons for Complaint

Players may raise a complaint about any aspect of their relationship with the operator or any incident linked to participation in games of chance, including (but not limited to):

  1. Deposit problems
  2. Withdrawal problems
  3. Bonus terms and conditions
  4. Account closures or limitations
  5. Alleged errors or unfair outcomes in games
  6. Responsible gaming concerns
  7. Treatment of player balances
  8. KYC and verification
  9. Data protection
  10. Technical or software issues
  11. AML-related concerns
  12. Matters involving minors
  13. Fraudulent games
  14. Fraudulent practices
  15. Licensing or regulatory issues

1. Company Policy

1.1 It is the policy of Malibu Club Casino (the "Company") to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company strives to comply with all applicable requirements under the legislations in force in the jurisdictions in which the Company operates, to prevent the use of the financial system for the purpose of money laundering and terrorist financing.

2. Objective of the Policy

2.1 The Company is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

2.2 The Company will endeavor to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organization and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.

2.3 The Company's policies, procedures and internal controls are designed to ensure compliance with all applicable laws, rules, directives and regulations relevant to the Company's operations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place.

3. Player Identification Program

3.1 The Company will take reasonable steps to establish the identity of any person for whom it is proposed to provide its service (hereinafter "Players"). For this purpose the process for the registration of Players provided for under the General Terms and Conditions of the Company provides for the due diligence process that must be carried out before the opening of a user account.

3.2 The Company will keep at all times a secure online list of all registered Players and information and documents will be retained in accordance with the applicable data protection obligations.

3.3 The Company will collect certain minimum Player identification information from each Player who opens an account. The Company will not accept to open anonymous accounts or accounts in fictitious names such that the true beneficial owner is not known. The information required will include at least:

  • Player's date of birth (showing that the player is over eighteen (18) years of age);
  • Player's first and last name;
  • Player's place of residence;
  • Player's valid email address; and
  • Player's username and a password.

3.4 Documents to verify the identity information received will be requested from the Player if and when there is considered to be risk or uncertainty about the information provided and prior to any payment in excess of EUR 3,000 per occasion or when payments to the account are made in excess of EUR 3,000. These documents shall include, to the extent permitted under the relevant data protection regulations:

  • A copy of a valid identity card or passport;
  • Proof of address;

3.5 The Company may supplement the use of documentary evidence by using other means, which may include:

  • Independently verifying the Player's identity through the comparison of information provided by the Player with information obtained from a reporting agency, public database or other source;
  • Checking references with financial institutions; or
  • Obtaining a financial statement.

3.6 The Company will inform relevant Players that the Company may seek identification information to verify their identity.

3.7 Any employee of the Company who becomes aware of an uncertainty in relation to the accuracy and truthfulness of the Player information provided shall immediately notify the AML Compliance Person, who will review the materials and determine whether further identification is required and or so that it may be determined whether a report is to be sent to the relevant authorities.

3.8 If a potential or existing Player either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the Company will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, the AML Compliance Person will be notified so that it may be determined whether a report is to be sent to the relevant authorities.

3.9 If a Player has been identified as attempting or participating in any criminal or unlawful activity, the Company will take the appropriate steps to immediately freeze the account of the Player.

3.10 If any material personal information of a Player changes, verification documents will be requested.

4. Continuous transaction due diligence

4.1 The Company will monitor account activity with special attention, and to the extent possible, the background and purpose of any more complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.

4.2 Monitoring will be conducted through the following methods: Transactions will be automatically monitored and reviewed daily for all transactions above a certain threshold along with all the details of the users making those transactions. Documents may be required at the determination of the AML Compliance Person.

4.3 The AML Compliance Person will be responsible for this monitoring, will review any activity that the monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the relevant authorities.

4.4 Parameters that signal possible money laundering or terrorist financing include, but are not limited to:

  • Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent reason.
  • Many small, incoming wire transfers or deposits made using checks and money orders.
  • Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent specific purpose.

4.5 When an employee of the Company detects any activity that may be suspicious, he or she will notify the AML Compliance Person. AML Compliance Person will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or filing a report.

4.6 The Company will not accept cash or non-electronic payments from Players. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method approved by the Company or respective regulators.

4.7 The Company will only transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.

4.8 To the extent the Company utilizes a third party to process and record payments to and from Player and accounts, the Company will use best efforts to ensure the services provider has transaction monitoring systems in place which will allow for screening of the transactions pursuant to these provisions and in accordance with the applicable legislation. The AML Compliance Person shall be responsible to review the relevant service agreement with the service provider to ensure the adequacy of the agreement.

4.9 Records relating to the financial transactions shall be maintained in accordance with the data protection and retention requirements in the applicable jurisdiction of Curaçao.

5. Suspicious Transactions and Reporting

The AML Compliance Person will report any suspicious transactions (including deposits and transfers) conducted or attempted by, at or through a Player account where the AML Compliance Person knows, suspects or has reason to suspect:

5.1 The Player is included on any list of individuals assumed associated with terrorism or on a sanctions list;

5.2 The transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade laws or regulations or to avoid any transaction reporting requirement under law or regulation;

5.3 The transaction has no ordinary lawful purpose or is not the sort in which the Player would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or

5.4 The transaction involves the use of the Company to facilitate criminal activity.

6. Training Programs

6.1 The Company will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. The training will occur on at least an annual basis. It will be based on the Company's size, its Player base, and its resources and be updated as necessary to reflect any new developments in the law.

6.2 The training will include, at a minimum:

  • how to identify red flags and signs of money laundering that arise during the course of the employees' duties;
  • what to do once the risk is identified (including how, when and to whom to escalate unusual Player activity or other red flags for analysis;
  • what employees' roles are in the Company's compliance efforts and how to perform them;
  • the Company's record retention policy;
  • the disciplinary consequences for non-compliance with legislation.