Player Funds Segregation

Player funds — every deposit, every winning, every bonus credit — are held in segregated client accounts that are legally and operationally separate from the operator’s own working capital. We do not use player funds to pay our staff, our suppliers, our marketing budget, or our taxes. Player funds fund player withdrawals; nothing else.

This is a regulatory obligation, not a marketing claim:

• Anjouan Offshore Financial Authority (AOFA) License Conditions §5 requires segregation of player balances from operator working capital.
• The bank holding the segregated account contractually acknowledges that the funds belong to players and not to the operator. The bank confirms this annually.
• Daily reconciliation (see §3) detects any discrepancy between the player wallet ledger and the segregated bank balance, and surfaces it to the AOFA on demand.

Your fiat deposits are placed into a segregated client-trust account at:

• Bank: TBC upon licensing approval.
• Bank jurisdiction: TBC upon licensing approval.
• Account type: a client-trust / escrow account. The legal owner of the funds in the account is the player community in aggregate, not the operator.

The specific bank-account number is not published — disclosing it would expose the operation to fraud (test deposits, denial-of-service, account-number-spray attacks). Account details are filed with the AOFA and are available to the regulator’s auditors on demand.

We choose banking partners that are regulated in stable jurisdictions and that accept gambling-industry clients. We do not use offshore shell banks. The banking-partner relationship is itself reviewed annually by our Compliance Officer (CO TBC) and disclosed in our regulatory filings.

Every working day:

• We snapshot the segregated bank balance from the bank’s reporting feed.
• We snapshot the sum of player wallet balances from our own ledger.
• We compare the two. They must match within a tolerance of zero (we may carry a small operating buffer in the segregated account in the operator’s name to absorb in-flight payments — this buffer is documented and excluded from the comparison).
• Any discrepancy is investigated within the same working day and remediated before the next reconciliation cycle. A persistent discrepancy is a material incident and is notified to the AOFA per License Conditions §12.

A monthly attestation, signed by the operator’s Money-Laundering Reporting Officer (MLRO TBC) and the finance lead, certifies that all daily reconciliations passed in the previous month or that any failures were notified and resolved. The attestations are held in our immutable audit trail (see Privacy Policy §5 for retention) and are available to the AOFA on demand.

If the operator becomes insolvent — for any reason — the segregated client-trust account is not part of the operator’s estate available to creditors. The insolvency administrator’s sole obligation in respect of those funds is to distribute them to players whose balances they represent.

The protection works because the funds are legally owned by the player community, not by the operator. The bank-acknowledgement letter described in §1 formalises this and is a key document in any insolvency proceeding.

This means:

• Your wagered balance, your deposit balance, and any uncredited but earned winnings are protected.
• Promotional credits and bonus balances that have not yet converted to cash may not be protected — these are typically recorded as liabilities of the operator rather than client funds. Treat your bonus balance as conditional, not guaranteed.
• Cryptocurrency holdings are protected through the cold-wallet custody policy described in §6. The protection mechanism is technically different but the principle is the same: the assets are not the operator’s to spend on operating costs.

When you withdraw funds, the money comes from the segregated account, not from the operator’s working capital. This is true regardless of the payment-method you choose.

Operationally:

• Your withdrawal request is validated (KYC, AML, balance check) and a payment instruction is queued.
• On execution, funds move from the segregated client account to the payment processor or directly to your bank instrument.
• The internal ledger is updated atomically with the bank movement; both legs of the entry are reconciled the same working day.

We do not mix withdrawal funds with operator income, marketing budget, or payable accounts. If a payment is delayed for compliance reasons (KYC review, AML hold, sanctions check), the funds remain in the segregated account in your name until the hold is released or the funds are refunded.

Where the platform accepts cryptocurrency deposits, we apply a custody policy that mirrors the segregation principle:

• Cold storage majority. The bulk of player crypto holdings sits in offline (cold) wallets controlled by multi-signature keys distributed across several physical locations. Compromising the cold storage requires cooperative action by multiple key-holders.
• Hot wallet float. A working float covering at most a few days of expected withdrawals is held in hot wallets to make payouts fast. The hot float is replenished from cold storage in batched, controlled operations.
• Multi-signature controls. Both cold and hot wallets require multi-signature authorisation for material movements. No single person can move player crypto.
• Exchange-rate snapshots. When a crypto deposit is made, we snapshot the fiat-equivalent exchange rate at the time of receipt; your wallet balance is denominated in your account currency from that point. Subsequent crypto-rate movements do not affect your fiat balance.
• Insurance. Where commercially available and proportionate, crypto custody is covered by insurance against operator-side compromise. Cover limits and conditions are disclosed in our regulatory filings.

Independent auditors, appointed in agreement with the AOFA, review the segregation arrangements at least annually. Their report is filed with the regulator. We may publish a redacted summary on this page once an audit cycle has been completed, but the full report is regulatory-confidential.

As a player, you have the right to request written confirmation of your wallet balance and its segregation status at any time. Email legal@huli.bet and we will respond within five working days with a signed statement of your balance and a confirmation that those funds sit within the segregated account described in §2.

This policy mirrors Anjouan Offshore Financial Authority (AOFA) License Conditions APR-2026 §5. It is drafted in good faith but is subject to final review by qualified counsel before relied upon for any specific legal purpose.