Anti-Money Laundering and Counter-Terrorist Financing Policy

Lucky Stripe Ltd || Last updated: 05.11.2025

1. Purpose and Scope

1.1. This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML/CTF Policy”, “Policy”) sets out the principles, rules and procedures implemented by Lucky Stripe Ltd (“Lucky Stripe”, “Company”, “we”, “us”) to prevent the use of its online gaming services for money laundering (“ML”) and terrorist financing (“TF”) or other financial crime.

1.2. Lucky Stripe operates an online gaming platform under a gaming license issued by the Anjouan Offshore Financial Authority (AOFA) and accepts players primarily from Chile and other LATAM markets.

1.3. This Policy applies to:

• the Board of Directors;
• the designated Compliance Officer / MLRO;
• all employees and contractors involved in customer-facing, payments, risk, compliance, fraud, product and operations functions;
• relevant external service providers (payment processors, KYC vendors) acting on behalf of Lucky Stripe.

2. Regulatory and Standards Framework

2.1. Lucky Stripe follows the AML/CTF requirements arising from:

• its Anjouan online gaming license;
• Financial Action Task Force (FATF) recommendations;
• online gambling AML best practices;
• AML/CTF obligations in agreements with PSPs, banks and KYC vendors.

2.2. Where there is any conflict, the stricter standard prevails.

3. Definitions

• Money Laundering (ML) – concealing the illicit origin of funds through placement, layering and integration.
• Terrorist Financing (TF) – provision/collection of funds intended for terrorist activities.
• Customer – a person holding or trying to open an account.
• KYC – Know Your Customer identification and verification procedures.
• EDD – Enhanced Due Diligence for high-risk profiles.
• PEP – Politically Exposed Person, including close associates and family members.
• MLRO – officer responsible for AML/CTF oversight.

4. Governance and Responsibilities

4.1. Board of Directors

• Approves and oversees AML/CTF frameworks.
• Ensures resources for compliance.

4.2. Compliance Officer / MLRO

• Oversees AML/CTF implementation.
• Manages KYC/EDD processes and transaction monitoring.
• Reviews alerts and suspicious cases.
• Maintains AML records and reporting logs.
• Coordinates with PSPs and regulators.

4.3. Employees

• Must follow AML rules and complete training.
• Must escalate suspicious activity.
• Must not tip off customers.

4.4. Third-Party Providers

• Must adhere to AML standards.
• Contracts must include AML, data sharing and confidentiality clauses.

5. Risk-Based Approach (RBA)

5.1. Lucky Stripe applies RBA, meaning higher risks → stronger controls.

5.2. Main risk factors:

• Customer-based risks: income sources, PEP status, behaviour.
• Geographical risks: high-risk jurisdictions; mismatch between IP and documents.
• Product/channel risks: fast deposits/withdrawals, bonus abuse, multiple wallets.
• Transaction risks: layering patterns, third-party payments, chargebacks.

5.3. MLRO maintains a company-wide ML/TF Risk Assessment, reviewed annually or after major changes.

6. Customer Acceptance & Prohibited Accounts

6.1. Lucky Stripe does not accept:

• anonymous accounts;
• underage customers (18+ only);
• customers from restricted/sanctioned jurisdictions;
• accounts funded by third parties;
• accounts acting as “money mules” or intermediaries.

6.2. The Company may refuse or suspend accounts where:

• KYC cannot be completed;
• documents are suspicious or falsified;
• ML/TF risk is unacceptable.

7. Customer Due Diligence (CDD / KYC)

7.1. When CDD is performed

• before first withdrawal;
• when deposits reach thresholds;
• when behaviour triggers alerts;
• when required by PSP or by regulator.

7.2. Data collected

• full name;
• date of birth;
• residential address;
• email and phone;
• account login details;
• preferred currency;
• payment details.

7.3. Identity Verification

• We may request:
• government-issued photo ID (passport, ID card, driving licence);
• proof of address (utility bill, bank statement, government mail);
• additional verification such as:
• selfie with ID;
• live video verification;
• phone call to registered number;
• enhanced questioning about personal data;
• comparison of IP/device fingerprint with submitted documents.
• All KYC documents must be clear, complete, readable and valid.

7.4. Payment Method Verification

• To verify ownership of payment instruments:
• masked card photo showing name;
• bank statement showing name & IBAN;
• screenshots of e-wallet accounts;
• crypto wallet ownership proofs (if applicable).
• Third-party payments are prohibited.

7.5. Ongoing CDD

• KYC data may be revalidated periodically;
• updated documents may be requested;
• changes in behaviour may trigger new checks.

8. Enhanced Due Diligence (EDD)

• Enhanced Due Diligence is automatically triggered when customer withdrawals exceed internal financial thresholds within specified timeframes. These thresholds are based on the Company’s risk assessment and international AML guidelines for remote gaming.

8.1. EDD applies to:

• PEPs;
• customers from FATF high-risk jurisdictions;
• high-value or unusual transactions;
• multiple accounts linked to same entity;
• customers hiding IP/geolocation;
• users showing ML/TF red flags.
• 8.2 EDD is required when:
• a customer requests a withdrawal above the Company’s predefined single-transaction threshold;
• cumulative withdrawals within a 24-hour period exceed the internal limit;
• cumulative withdrawals within a rolling 30-day period exceed the internal limit;
• the withdrawal behaviour is inconsistent with the customer’s known profile, declared income, or gameplay patterns.

8.3. EDD measures may include:

• additional ID/POA;
• Source of Funds (SoF): salary slips, contracts, invoices, bank statements;
• Source of Wealth (SoW): proof of assets, property sales, investments;
• deep behavioural analysis;
• video interview with compliance;
• limits on payments;
• senior management approval.

9. Transaction Monitoring

9.1. Lucky Stripe monitors transactions in real time for:

• rapid deposit/withdraw cycles;
• low/no gaming with high velocity funds;
• inconsistent geolocation;
• bonus abuse patterns;
• chargebacks;
• payment method changes;
• use of VPNs/proxies;
• multiple accounts from same device or IP.

9.2. Monitoring uses:

• automated alerts;
• manual reviews;
• PSP feedback;
• cross-checks with earlier behaviour.

9.3. Red flags:

• deposits followed by immediate withdrawals;
• repeated failed card attempts;
• high-risk payment sources;
• mismatched KYC vs device/behavior;
• structured deposits just below thresholds;
• back-to-back use of different cards/wallets.

9.4. Actions upon detection:

• request info or documents;
• freeze transactions;
• suspend account;
• restrict bonuses;
• escalate for investigation.
• 9.5 Behavioural Risk Indicators
• The following patterns may indicate ML/TF or other financial crime:
• deposit behaviour unrelated to entertainment use of gaming services;
• attempts to use the platform primarily for movement, conversion or consolidation of funds;
• minimal gameplay followed by withdrawal attempts;
• sudden changes in gameplay, deposit or withdrawal patterns;
• attempts to avoid verification or to submit altered, incomplete or inconsistent documents;
• repeated creation of accounts using similar personal, device or network attributes;
• attempts to circumvent account limits or cooldown mechanisms;
• repeated failed payments followed by successful large transactions;
• excessive use of account features immediately after registration;
• mismatches between account data, customer communication history and transactional patterns.
• Detection of these indicators triggers immediate review and potential escalation to Compliance.

9.6. Bonus Misuse as AML Indicator

• Bonus misuse, including circular wagering, multi-accounting for promotional benefits, or any pattern indicating exploitation of promotional tools, is treated as a potential ML/TF risk.
• Such behaviour may result in:
• suspension of bonus eligibility;
• transaction review;
• EDD;
• account restrictions or closure.

10. Suspicious Activity Handling & Reporting

10.1. All employees must escalate suspicious activity to MLRO immediately.

10.2. MLRO tasks:

• investigate alerts;
• request additional documents;
• block/suspend account if justified;
• decide whether a Suspicious Activity Report (SAR) is required;
• coordinate with PSP or regulators (if applicable).

10.3. Tipping-off is strictly prohibited.

• Customers must not be informed about AML investigations.

11. Record Keeping

11.1. Records retained for minimum 5 years after account closure or last transaction.

11.2. Records include:

• identity documents;
• address proofs;
• payment method proofs;
• transaction history;
• monitoring logs;
• SAR/STR logs (where allowed).

11.3. Records stored securely under restricted access.

12. Sanctions & PEP Screening

12.1. All customers are screened for:

• global sanctions lists;
• PEP status;
• adverse media referencing financial crime.

12.2. Matches trigger:

• account review;
• EDD;
• potential rejection or closure;
• PSP/regulator coordination when required.

12.3. High-Risk Customer Register

• The Company maintains an internal register of high-risk customers, including those subject to EDD, PEP profiles, adverse-media matches or ongoing investigations.
• Customers included in this register are:
• monitored more frequently;
• subject to stricter transactional limits;
• periodically re-verified;
• reviewed by Compliance at predefined intervals.
• Placement on the register is determined by the Compliance Officer based on observed risk indicators and internal scoring.

13. Payments, Withdrawals & Controls

13.1. AML-related controls:

• deposits must be wagered at least once before withdrawal;
• withdrawals returned, where possible, to same payment method;
• unusual withdrawals may trigger AML review;
• refunds/chargebacks monitored for fraud/ML patterns.

13.2. High-risk patterns may lead to:

• withdrawal delays;
• account freezing;
• rejection of funds;
• SAR escalation.

14. Interaction with PSPs & Financial Institutions

14.1. Lucky Stripe cooperates with PSPs to:

• share fraud and AML alerts;
• provide KYC data where contractually allowed;
• respond to chargeback investigations;
• jointly monitor unusual payments.

14.2. Lucky Stripe only partners with PSPs that maintain adequate AML/CTF controls.

15. Training

• All staff performing KYC, payments, risk or support functions must undergo:
• onboarding AML/CTF training;
• annual refresher training;
• ad-hoc training after incidents or regulatory changes.
• Training includes:
• AML basics;
• document verification;
• detecting red flags;
• escalation procedures;
• prohibition of tipping-off.

16. Internal Audit & Review

16.1. AML controls are reviewed at least once per year or upon significant operational/regulatory changes.

16.2. MLRO performs ongoing quality checks of:

• KYC files;
• EDD decisions;
• monitoring effectiveness.

16.3. Board of Directors reviews AML performance and approves updates.

17. Enforcement

17.1. Breaches of this Policy may result in:

• disciplinary measures;
• suspension of access;
• escalation to authorities;
• termination of employment (if internal).

17.2. All employees must comply with this Policy without exception.