BetRebels Casino - プレイヤーの引き出しはアカウント確認プロセスにより遅延されます。

I would like to request the assistance of the Casino Guru arbitration team to ensure that proper conduct is followed in my case. I have concerns that BetRebels may be misusing the Source of Funds (SOF) process to delay or potentially deny the payment of my legitimate withdrawal.

My BetRebels account is new, and I have only made a single deposit of €400 via bitcoin.

After playing in the casino, I happened to win several thousand euros while completing my first deposit bonus. I requested a withdrawal on December 3, but it was rejected, despite the fact that I had already passed the full KYC verification successfully on November 24.

I have no problems with appropriate, relevant checks, but this does not appear to be the case here. My deposit history consists of only a single €400 deposit, and my overall gaming activity was this far kind of minimal, as I had only been playing on the site for a short period. Given this short period of activity, the scope and nature of the documentation the casino is demanding do not seem proportionate or justified. I am concerned that the casino may be using the SOF process in a potentially improper way to find an excuse to avoid paying my legitimate winnings.

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My reasoning:

Under Maltese law (PMLFTR), FIAU Implementing Procedures Part I, and EU AML Directives, a player is responsible only for proving the source of the specific funds used to transact with the casino — in this case, the €400 deposit. This is the core meaning of Source of Funds (SOF) under AML/CFT rules.

Below is the relevant regulatory framework supporting this.

1. FIAU Implementing Procedures Part I — Proportionality & Relevance

Section 4.3

"The information requested shall be limited to that which is necessary to understand the customer’s profile and the source of the funds used in the transaction."

This means my responsibility extends only to the funds actually used — €400, not my entire wallet history, all my wealth, or unrelated past crypto movements.

2. Malta PMLFTR Regulation 7(1)(c)

Casinos must obtain information to establish the origin of the funds that are to be or have been used in the business relationship.

"Funds used in the business relationship" refers specifically to the deposit I made. It does not mean the casino may request the entire historic activity of my crypto wallet, nor does it include winnings, which originate from the casino itself.

3. Enhanced Due Diligence Still Has Limits

FIAU IP Part I, Section 4.9 states:

"Enhanced due diligence measures must be commensurate with the level of risk and must not exceed what is strictly necessary."

A €400 deposit is low-risk and can be verified with simple, limited documentation. Requests for unlimited or lifetime crypto history do not meet the proportionality requirement.

4. EU AMLD4/5 — Risk-Based, Transaction-Focused Checks

EU Directive 2015/849 requires customer due diligence to be applied on a risk-sensitive basis, appropriate to the level of risk.

A €400 deposit is treated as low-risk under this framework. AML checks must focus on the origin of that deposit, not on unrelated financial history.

5. GDPR Article 5(1)(c) — Data Minimisation

Personal data collected must be adequate, relevant, and limited to what is necessary.

Requesting documentation showing the origin of the €400 is compliant. Demanding six months of unrelated financial records, or a complete historical audit of my crypto activity, is not compliant and violates data minimisation principles.

Conclusion

Under AML regulations, I am responsible only for proving the origin of the actual funds deposited — the €400. Specifically:

I must demonstrate where the €400 came from.

I am not required to prove the origin of all other crypto I hold.

I am not required to provide lifetime wallet history.

I am not required to justify unrelated crypto transfers or any historical fund movements.

I am not required to provide Source of Wealth information, as this is not applicable to such a small deposit.

This interpretation aligns with FIAU, MGA, PMLFTR, and EU AML Directives.

Request for Casino Guru Arbitration Team

For these reasons, I respectfully request the Casino Guru arbitration team to oversee and evaluate the casino’s handling of my SOF review to ensure that:

The AML requests remain proportionate and directly relevant to the €400 deposit;

The casino is not demanding excessive, irrelevant, or impossible documentation;

The process complies with the proportionality, data minimisation, and risk-based requirements under Maltese and EU regulations;

My withdrawal is not delayed or obstructed through misuse of AML procedures.

I remain fully willing to provide any documentation that is legitimately necessary and proportionate to verify the origin of the specific funds deposited.

I can provide Casino Guru further details as required.

Important notice:

Casino Guru will never ask for payments or access to your accounts to complete KYC. If someone claims to be from Casino Guru and does that, do not share any information.

We only contact players through this official complaint thread or via @casino.guru e-mail addresses. Always check the sender’s domain and verify your complaint resolver’s e-mail address by clicking on their avatar visible inside the official complaint thread.

If anything seems suspicious, contact us directly.

Stay safe.

Hello,

Thank you very much for submitting your complaint. I’m sorry to hear about your negative experience with BetRebels Casino. I reviewed the source of funds requirements you received from the casino and concluded, these are not out of the ordinary.

Please allow me to ask you a few questions so I can better understand the situation.

• Could you please explain in your own words what constitutes your verifiable income?
• Which documents regarding the source of funds have you already submitted to the casino?

I hope we will be able to help you resolve this issue as soon as possible. Thank you very much in advance for your reply.

Best regards,

Tomas