BetPanda's AML Claims vs Reality

Dear Olamanola,

Thank you for bringing this issue to our attention. We have contacted representatives of Betpanda.io and asked them to respond to this inquiry directly. We appreciate your patience during this time and hope to resolve this complaint soon.

Best Regards,
Betpack Team

Hello,

Apologies for the delay in responding, we had some issues gaining the right access to reply.

We are of course happy to address these claims and correct any misconceptions there might be.

There seems to be a confusion between Anti-Money Laundering and other types of monitoring as well as risk-scoring as these serve fundamentally different purposes.

AML monitoring, which is the one user refers to from our Anti-Money Laundering Statement, is meant to detect if the transaction has potentially illicit origins or purpose. If the automatic risk scoring obtained from the blockchain does not indicate that the transaction in question is high-risk, there won't be additional measures taken.

The user in question did indeed deposit money to us but also withdrew funds and gave no responsible gambling indicators until the email where they referred to these measures where they questioned these measures. In these emails they request a refund based on "activity occurred under conditions that appear to fall outside your own stated compliance framework" which, as we have covered and explained to the user, is mistaking the AML monitoring mentioned in the AML statement to be related to something different. This claim is not accurate and therefore we do not deem it to be basis for a refund of fund which were lost in normal gameplay.

It is wholly possible that the player is used to a different jurisdiction and measures taken under such legislation, but as we know, these measures vary greatly from one jurisdiction to another.

Should any player indicate to us that they are gambling beyond their means, the account will be immediately and permanently closed and we strongly urge such players to contact harm reduction professionals local to them as they are best equipped to provide them with assistance in such circumstances.

We hope that this clarifies the situation for you and if you have any further questions, please do let us know.

Thank you for your response.

I acknowledge the distinction you have made between Anti-Money Laundering monitoring and Responsible Gambling monitoring. I agree that AML controls are primarily concerned with identifying potentially illicit transactions and that an AML risk score does not, by itself, establish gambling-related harm.

However, this distinction does not resolve the substance of my complaint.

My complaint is not that the $19,000 in deposits automatically constituted an AML violation, nor am I claiming that every large cryptocurrency transaction should result in an account closure or refund.

The issue is whether BetPanda had functioning player-protection and responsible-gambling monitoring controls, as would ordinarily be expected from a properly regulated and responsibly operated online gambling platform, and whether those controls were actually applied to my account.

1. The activity was objectively unusual and escalated extremely rapidly

This was a newly created account.

Within a matter of hours, the account deposited approximately $19,000 USDT, with the deposits escalating from hundreds of dollars to several thousand dollars.

The activity occurred over a very short period of time and resulted in substantial losses.

I am not arguing that the amount alone proves gambling harm. Rather, I am asking BetPanda to explain what player-risk monitoring was applied to this objectively unusual pattern and what criteria were used to determine that no intervention was warranted.

A responsible-gambling framework should not depend exclusively on a player explicitly writing to the operator and stating that they are gambling beyond their means. Effective player-protection systems generally involve proactive monitoring of relevant behavioural indicators, including where appropriate rapid deposit escalation, unusually intense gambling activity, loss patterns, changes in betting behaviour and other indicators of potential risk.

2. Your response does not address Responsible Gambling monitoring

Your response states:

“The user in question did indeed deposit money to us but also withdrew funds and gave no responsible gambling indicators until the email where they referred to these measures.”

This statement raises an important question:

What specific responsible-gambling indicators did BetPanda monitor, and how did BetPanda determine that none were present?

Please clarify:

* What player-risk or responsible-gambling monitoring system was applied to my account?
* Was my account assigned a player-risk score or classification?
* What behavioural variables were considered?
* Were deposit frequency, deposit escalation, deposit velocity, gambling intensity, losses or session duration considered?
* Were there automated thresholds or triggers for responsible-gambling intervention?
* Did any automated alert or risk event occur during the period in question?
* Was my account ever manually reviewed?
* If not, why not?
* What objective criteria were used to conclude that my activity did not constitute a responsible-gambling risk?

Simply stating that no responsible-gambling indicators existed does not explain how that conclusion was reached.

3. AML monitoring and Responsible Gambling monitoring are separate issues

I accept your explanation that the AML monitoring described in your AML Statement is primarily intended to identify potentially illicit transactions.

However, that makes the distinction between the two systems even more important.

If BetPanda maintains separate AML and Responsible Gambling controls, please explain what Responsible Gambling controls were applicable to my account and how they operated in practice.

A reliable online gambling operator should not rely exclusively on AML transaction screening to identify player-protection risks.

The relevant question is therefore not:

“Was the $19,000 deposit AML-related?”

The relevant question is:

“What player-protection assessment was performed when a newly created account exhibited this level and velocity of gambling activity?”

4. KYC and enhanced due diligence

I also note that my account remained marked as:

“NOT_VERIFIED”

I understand that KYC does not necessarily have to be completed immediately for every customer and that different jurisdictions may impose different requirements.

However, reputable operators generally maintain risk-based KYC, customer due diligence and enhanced due diligence procedures that can be triggered by factors such as unusual activity, transaction patterns, risk indicators or other circumstances identified in the operator’s own policies.

I therefore ask BetPanda to clarify:

* What KYC policy was applicable to my account on 18 April 2026?
* What events or thresholds triggered KYC?
* What events triggered enhanced due diligence?
* Was source-of-funds verification available as an intervention?
* Why was no KYC or enhanced review initiated despite the activity described above?
* Was my account classified as low, medium or high risk at any point during this activity?

Again, I am not asserting that the law necessarily required immediate KYC solely because I deposited $19,000. I am asking BetPanda to explain how its own risk-based compliance framework operated in this specific case.

5. Responsible Gambling should not begin only after the player asks for help

Your response states:

“Should any player indicate to us that they are gambling beyond their means, the account will be immediately and permanently closed…”

I appreciate that policy.

However, that appears to describe the operator’s response once a player explicitly self-identifies as experiencing gambling-related harm.

That is different from proactive player-risk monitoring.

If BetPanda’s responsible-gambling framework contains proactive monitoring or intervention mechanisms, I would expect those mechanisms to operate before a player necessarily contacts the operator and explicitly identifies themselves as experiencing harm.

Therefore, please provide the specific policy or procedure that explains how BetPanda identifies players who may be at risk before they make such an explicit declaration.

6. The existence of withdrawals does not resolve the issue

You also state that I deposited funds but also withdrew funds.

The existence of withdrawals does not, by itself, establish that the account presented no responsible-gambling risk.

A player can deposit, withdraw and continue gambling while still exhibiting potentially relevant behavioural indicators.

The relevant question remains whether the totality of the activity was monitored and assessed against BetPanda’s responsible-gambling criteria.

Please therefore provide the basis on which the existence of withdrawals was considered relevant to the conclusion that there were no responsible-gambling indicators.

7. What I am asking BetPanda to provide

I am not asking BetPanda to disclose proprietary source code, confidential AML algorithms or commercially sensitive information.

I am asking for a transparent explanation of the controls that were applicable to my account and the decisions made in response to my activity.

Specifically, please provide:

1. The Responsible Gambling Policy applicable on 18 April 2026.
2. The KYC/Customer Due Diligence policy applicable on that date.
3. The relevant player-risk monitoring and intervention criteria.
4. Confirmation of whether my account was assigned a player-risk classification.
5. Confirmation of whether any automated risk alerts were generated.
6. Confirmation of whether any manual compliance or responsible-gambling review occurred.
7. The objective basis for the statement that there were no responsible-gambling indicators.
8. The applicable licensing jurisdiction and regulatory framework governing my account at the time.
9. An explanation of why no KYC, enhanced due diligence, responsible-gambling intervention, deposit restriction, cooling-off measure or other player-protection measure was triggered during the relevant period.

8. Requested resolution

To be clear, I am not asking BetPanda to refund losses simply because I lost money gambling.

My position is that the operator should demonstrate that the account was handled consistently with its own stated compliance, responsible-gambling and player-protection framework.

If BetPanda can demonstrate that:

* appropriate player-risk monitoring was applied;
* the relevant behavioural indicators were assessed;
* the applicable risk thresholds were not met;
* no intervention was warranted under its policies; and
* the account was handled in accordance with the regulatory framework applicable to it,

then I will consider that explanation.

However, the current response does not establish any of those points. It primarily explains the purpose of AML monitoring, while my complaint also concerns the separate question of responsible-gambling and player-risk monitoring.

I therefore respectfully request that BetPanda address those specific points rather than treating the complaint solely as an AML matter.

Given the amount and speed of the activity involved, I believe an independent review of the account’s risk-monitoring records, intervention logs and applicable responsible-gambling procedures is appropriate.

I look forward to BetPanda’s substantive response.

Hello,

Thank you for getting back to us and apologies for the delayed reply.

Please note that we did not mention that there would be a difference in “Anti-Money Laundering monitoring” and “Responsible Gambling monitoring”, as we never referred to the latter in our response, this is merely an assumption made based on the angle which you chose for your response.

To respond to your questions in order:

1. In certain jurisdictions, this might constitute a “Red flag” under the responsible gambling regulations of that jurisdiction, but this all depends on the checks performed on the player. This is however jurisdiction dependent and objective, hence it cannot and should not be applied to every jurisdiction by default.

2. That is correct, the response does not address it as your initial complaint does not concern it. Your complaint refers to what is stated in our Terms & Conditions and AML Statement and how you perceived that our actions would contradict this, which we disagree with.

We are not at the liberty to publicly discuss what measures are taken as this could enable players to avoid these measures.

3. We agree, they are separate issues and we did not mention “ Responsible Gambling monitoring” in our response.

4. Again, this is sensitive operational information and revealing this in public could allow nefarious actors to devise ways to bypass, deceive or somehow abuse the system and we are not in a position to share this information publicly.

5. We did not mention that the player directly mentioning to us that they suffer of gambling related harm is the only situation where action is taken from a Responsible Gambling perspective, this is an assumption that is not based on what we stated in our reply.

6. Of course not, the fact that funds were withdrawn from the account is not a sole indicator of responsible gambling indicators being or not being present. Again, we did not state that it would be a decision making measure as was falsely claimed in your response.

However, the case was presented in a manner which would suggest that only deposits were made without any withdrawals (this information was omitted from the initial complaint), so in order to establish a more complete picture of the circumstances, we felt like this was relevant information.

7. All the publicly available information can be found from our website.

8. We have acted fully within the regulations which govern our operations.

We would like to point out that in your initial complaint you refer to “AML Statement”, and ask the following question:

“If transaction monitoring, risk scoring, and compliance controls exist, how was a newly created account able to deposit and lose approximately 19,000 USDT in a matter of hours without triggering any enhanced review whatsoever?”

However, when you provided your reply to our response, you were referring to something different and to policies, regulations and practices which are not relevant to the jurisdiction or to your initial complaint. Many of the measures mentioned appear to be either from a different jurisdiction or possibly several different jurisdictions which are not again relevant to this complaint or our operations.

We have comprehensively replied to your initial complaint and addressed any concerns surrounding our AML Statement and Anti-Money Laundering related monitoring, as stated by the initial complaint, but the latest reply is trying to shift the conversation to something that is not related to the initial complaint.

Should you have any further questions, please do let us know.

Thank you for your response.

I believe the discussion can be clarified quite simply.

I accept your position that you cannot publicly disclose proprietary risk thresholds, algorithms, internal controls or other sensitive operational information. I am not requesting that information.

However, your response still does not identify the fundamental information necessary to determine whether the handling of my account was compliant.

You state that:

“We have acted fully within the regulations which govern our operations.”

I therefore ask you to identify those regulations.

Specifically, please provide:

1. The full legal name of the entity that operated my account on 18 April 2026.
2. The licensing jurisdiction applicable to my account on that date.
3. The name and licence number of the relevant gambling regulator.
4. The applicable regulatory framework governing my account on 18 April 2026.
5. The applicable Terms and Conditions and Responsible Gambling/Player Protection policy in force on that date.
6. The applicable complaints and/or alternative dispute resolution procedure for my account.

I am not asking you to disclose how your internal risk systems work. I am asking you to identify the legal and contractual framework under which you say that my account was operated in full compliance.

Your repeated statement that certain measures are “jurisdiction dependent” makes identifying the applicable jurisdiction particularly important.

Regarding the substance of my complaint, I also accept that AML monitoring and responsible-gambling monitoring are distinct matters. I am no longer asking you to treat them as the same.

My concern is that a newly created account deposited approximately 19,000 USDT within a matter of hours, with rapidly escalating deposits and substantial gambling losses. You have stated that the account was handled fully in accordance with the regulations applicable to your operations, but you have not identified which regulatory framework that conclusion is based upon.

You have also stated that you cannot publicly disclose the measures used by your systems. I understand that position. However, that does not prevent you from confirming whether the account was subject to any automated or manual compliance/player-protection review, whether any intervention occurred, and what general regulatory obligation or policy governed that process.

I therefore request that you answer the following specific questions:

* Was my account subject to any compliance, risk or player-protection review during the relevant period?
* Was any intervention, restriction, alert or escalation generated in relation to my account?
* If you cannot disclose the underlying methodology, please simply confirm whether such an event occurred.
* What regulatory or contractual framework determined whether an intervention was required?
* What entity and regulator had responsibility for my account?

For clarity, I am not asserting that a $19,000 deposit automatically creates a right to a refund, nor am I asking you to disclose proprietary risk thresholds.

I am asking you to substantiate your statement that my account was operated in full compliance with the legal and contractual framework applicable to me.

If BetPanda maintains that no refund is warranted, please provide the specific legal and contractual basis for that position, together with the identity of the applicable licensed entity and regulator.

If this information cannot be provided through BetPack, please provide the formal complaints/ADR procedure and the competent regulatory authority to which this matter may be escalated.

I reserve all rights in relation to the approximately $19,000 in net losses incurred during this period.

I would appreciate a substantive response to the above points rather than a further discussion regarding whether AML monitoring and responsible-gambling monitoring are conceptually different matters.

Hello,

Thank you for getting back to us.

We have provided you with all the necessary information in the statement that we have acted fully within the regulations which govern our operations, as this encompasses the answers to all of the questions.

As your funds were lost in normal gameplay, as per our terms and conditions, we are not in a position to offer you a refund for such losses.

Also as mentioned earlier, you can find the answer to all the questions which you have posed to us from our Terms and Conditions and other information publicly available on our website.

If you have further questions, please do let us know.

Hello,

Thank you for getting back to us.

We have provided you with all the necessary information in the statement that we have acted fully within the regulations which govern our operations, as this encompasses the answers to all of the questions.

As your funds were lost in normal gameplay, as per our terms and conditions, we are not in a position to offer you a refund for such losses.

Also as mentioned earlier, you can find the answer to all the questions which you have posed to us from our Terms and Conditions and other information publicly available on our website.

If you have further questions, please do let us know.

Thank you for your response.

I note your position that:

1. BetPanda considers that it acted fully within the regulations governing its operations; and
2. BetPanda considers that the approximately $19,000 in losses constitute “normal gameplay” and therefore are not refundable under your Terms and Conditions.

However, neither statement actually addresses the underlying issue or substantiates the basis for your conclusion.

You state that all relevant information can be found in your Terms and Conditions and publicly available information. I have reviewed the information provided, and referring me generally to your website is not a substantive response to a specific dispute concerning the operation of my individual account.

For the avoidance of doubt, I am not asking you to disclose proprietary algorithms, internal risk thresholds or security-sensitive information.

I am asking you to identify the legal and contractual basis upon which you conclude that my account was operated in compliance with the applicable regulatory framework.

In particular, please confirm:

* The legal entity that operated my account on 18 April 2026.
* The gambling licence and regulator applicable to my account on that date.
* The jurisdiction governing my player account.
* The specific Terms and Conditions applicable to my account on 18 April 2026.
* The applicable complaints and ADR procedure.
* The competent regulatory authority to which this dispute may be referred.

Your statement that you have “acted fully within the regulations which govern our operations” is a specific assertion of regulatory compliance. If you maintain that position, it should be possible to identify the regulatory framework and licensing authority applicable to the account.

I also note that you continue to characterize the losses simply as “normal gameplay”. That does not, by itself, establish that all applicable player-protection, compliance, KYC or other regulatory obligations were satisfied during the relevant period.

The relevant facts remain that this was a newly created account and that approximately $19,000 USDT was deposited and lost within a very short period following registration. These facts are documented and are not disputed by you.

I am therefore requesting a final substantive response identifying the regulatory and contractual basis for your refusal to consider reimbursement.

If BetPanda's position is that no regulatory or contractual provision applicable to my account was breached and that there is therefore no basis whatsoever for reimbursement, please state that clearly and identify the applicable regulatory framework and competent regulator.

If you maintain that this matter cannot be reviewed internally any further, please provide the formal escalation/ADR procedure and the competent regulatory authority.

I consider this an important distinction because I am not asking BetPanda to refund a loss merely because I lost money through gambling. I am disputing whether the account was operated in accordance with the regulatory and contractual obligations applicable to it.

Please treat this message as a formal request for your final position on the matter.

I reserve all rights in relation to the approximately $19,000 in net losses and any further regulatory, ADR, consumer-protection or legal remedies available to me.

I look forward to your final substantive response.

Hello,

Thank you for getting back to us.

If you examine our Terms and Conditions, you can find the information which you request and all the relevant information remains publicly available for anyone to see.

We can confirm that we have acted within the regulatory and contractual obligations which pertain to our operations. It is worth pointing out that upon creating an account with us, you agreed to the Terms and Conditions of our service and we assume that all players familiarise themselves with them before opening an account with us.

Do let us know if you have any further questions.

Thank you.

I understand your position.

However, referring me generally to your Terms and Conditions does not answer the specific regulatory questions raised in this dispute.

I have not asked whether I agreed to your Terms and Conditions. I am asking you to identify the specific legal entity, licence, regulator and regulatory framework under which my account was operated on 18 April 2026, and the specific contractual provision you rely upon to reject my claim.

Your statement that you “have acted within the regulatory and contractual obligations” is a conclusion, not an explanation of the basis for that conclusion.

Accordingly, please provide the following:

1. The legal entity that operated my account.
2. The gambling licence and licence number applicable to my account on 18 April 2026.
3. The regulator responsible for supervising that licence.
4. The jurisdiction governing my account.
5. The specific Terms and Conditions provision upon which you rely to reject reimbursement.
6. The formal complaints/ADR procedure and the competent authority to which I may escalate this dispute.

If all of this information is genuinely publicly available, providing the exact links or references should not present any difficulty.

For the avoidance of doubt, I am not requesting confidential algorithms, internal thresholds or proprietary risk-management information.

I am requesting the basic regulatory and contractual information necessary to understand and independently verify your assertion that my account was operated in compliance with the applicable framework.

I also do not accept that the mere fact that I agreed to the Terms and Conditions resolves the issue. Contractual terms do not, by themselves, establish compliance with applicable regulatory obligations.

Please consider this my final request for the relevant regulatory and contractual information and your final position regarding my claim.

If you decline to provide this information, please expressly confirm that you are refusing to identify the licence, regulator and applicable jurisdiction governing my account, and provide the formal external escalation/ADR route available to me.

I reserve all rights in relation to my approximately $19,000 net losses.

Hello,

Thank you for getting back to us.

As mentioned earlier, you can find the answers to the questions which you posed from our Terms and Conditions:

https://betpandacasino.io/en/info/terms/

We are not and have not refused to provide any information. On the contrary, we have advised where you can find this information on multiple occasions. Should you not wish to view the information, this cannot be considered to be our responsibility.

You can find the relevant clause below:

14. Refund Policy
14.1 Conditions for Returns
In order for the Betpanda.io Balance to be eligible for a return, please make sure that:
- The Betpanda.io Balance was not used in wagers of any kind (this means after the purchase you did not do any actions involving Betpanda.io Balance on Your Account).

We have already provided the final answer to your claim and we have not received any information which would warrant a change in this stance.

Please do let us know if you have any further questions.