AML/KYC Policy (the "Policy"). Lucky Boom, operated at luckyy-boom.nl by MAIREKE LIMITADA (Costa Rica) and licensed by the Anjouan Offshore Financial Authority, applies the obligations and procedures below to prevent money laundering, terrorist financing and related financial crime. They cover all players, transactions and accounts at luckyy-boom.nl. Registering an account and using the services confirms that the player has read, understood and accepted this Policy.

1. Legal basis and purpose

Lucky Boom operates under the licence of the Anjouan Offshore Financial Authority. International AML/CFT (Counter Financing of Terrorism) standards and the licence conditions require proportionate controls to detect, prevent and report money laundering and terrorist financing.

Objectives:

• Define the obligations of Lucky Boom and players regarding identity verification and source-of-funds checks;
• Define when, how and why documents are collected, verified and retained;
• Describe ongoing transaction monitoring;
• Set the consequences of non-compliance, including restriction or closure of accounts;
• Describe reporting duties for suspicious activity.

Scope: all employees, contractors and third-party providers acting for Lucky Boom, and all registered players at luckyy-boom.nl.

2. Definitions

• AML — Anti-Money Laundering: laws, rules and procedures that prevent illegally obtained funds from being passed off as legitimate income.
• CFT — Counter Financing of Terrorism: measures that prevent funds from supporting terrorist activity.
• KYC — Know Your Customer: verification of identity, address and, where required, source of funds or wealth.
• CDD — Customer Due Diligence: standard checks on all players.
• EDD — Enhanced Due Diligence: deeper checks on higher-risk players or transactions.
• PEP — Politically Exposed Person: a person with a prominent public function, past or present, including close associates and family.
• SAR — Suspicious Activity Report: an internal or external report of suspected money laundering or terrorist financing.
• MLRO — Money Laundering Reporting Officer: the officer who receives and evaluates internal SARs and makes external disclosures.

3. Risk-based approach

Risk is assessed per player and per transaction, and controls are proportionate. All players pass at least standard CDD before a withdrawal is approved; scrutiny beyond that varies.

Risk factors include:

• Country of residence or nationality;
• Payment methods and currencies;
• Deposit and withdrawal frequency and volume against stated income;
• Nature and pattern of play;
• PEP status or sanctions-list match;
• Previous suspicious activity or flagged transactions;
• Declared source of funds.

With elevated risk, EDD applies and further documents may be requested before withdrawals or continued service.

4. Standard CDD

4.1 Triggers

Documents may be requested at any time after registration; full KYC is always required before a withdrawal is approved, and early verification is recommended. Other triggers:

• Cumulative deposits reaching an internal risk threshold;
• Any withdrawal request;
• A pattern inconsistent with earlier activity;
• PEP identification or a sanctions match;
• Any indicator of suspected money laundering or fraud.

4.2 Documents

Standard CDD requires from every player:

• Proof of Identity (POI) — a clear, full-colour copy of a valid government-issued photo ID (national identity card, passport or driving licence); not expired, showing full legal name, date of birth and photograph, legible at all four corners.
• Proof of Address (POA) — a document dated within the last three months showing full name and current residential address: utility bill (gas, electricity, water or fixed-line telephone), bank statement, government letter or council tax statement.
• Proof of Banking Option (POPM) — proof that the payment method is the player's: for bank cards a photo or screenshot with the middle eight digits of the number obscured, the name and the expiry date; for e-wallets or bank transfers a screenshot of the account with name and details.

4.3 Selfie and liveness

A selfie with the ID, or a liveness check, may be requested to confirm that the submitter is the person on the ID and the account holder.

4.4 Submission

Documents are submitted in the account profile or by email to support@luckyy-boom.nl; 24/7 live chat can guide the process. Documents must be legible, unaltered and complete; those that appear manipulated, cropped or tampered with may be rejected.

4.5 Outcome and timing

Complete, satisfactory submissions are normally verified within the published payout approval window of two business days. Further information, if needed, is requested directly. Withdrawals are held while a review is open.

5. Enhanced due diligence

EDD applies to higher-risk players or transactions as a regulatory and legal obligation, not a penalty, and may require, in addition to CDD:

5.1 Source of funds (SOF)

Evidence of where the gambling funds originated, such as:

• Recent payslips or an employment contract showing salary;
• Bank statements showing regular salary credits or receipt of the funds;
• A letter from an accountant or employer confirming income;
• Documents for an inheritance, property sale or investment dividends;
• Business accounts or tax returns for self-employed persons.

5.2 Source of wealth (SOW)

For very high volumes or where overall wealth warrants examination: documentation on how the assets were accumulated, wider than SOF.

5.3 PEP and sanctions screening

All players are screened against PEP lists and international sanctions databases at registration and continuously. A PEP or sanctions match triggers EDD automatically; Lucky Boom may decline or close the account of anyone on a sanctions list or with unacceptable PEP risk.

5.4 High-value monitoring

Players using the High Roller Bonus (deposits of €500 or more) or approaching the weekly withdrawal cap of €20,000 or the monthly cap of €50,000 for non-jackpot wins are monitored more closely. Jackpot winnings, outside the monthly cap, may require additional source-of-funds verification before full payout.

6. Ongoing monitoring

KYC continues throughout the relationship, including:

• Real-time and retrospective review of deposits and withdrawals against the stated profile;
• Monitoring against the published limits (minimum deposit €20, minimum withdrawal €40, weekly cap €20,000, monthly cap €50,000);
• Detection of unusual betting, such as large rapid deposits followed by immediate withdrawal requests with minimal play;
• Detection of structuring, for example splitting deposits to stay below internal thresholds;
• Periodic re-verification of identity and address, particularly after account updates or inactivity followed by high-value activity;
• Cross-checking of VIP status claims; players requesting a status match with screenshots from another operator may face additional scrutiny.

Activity inconsistent with the profile or raising suspicion leads to internal escalation, and withdrawals or play may be restricted temporarily pending investigation.

7. Reporting

7.1 Internal

Staff who identify or suspect money laundering, terrorist financing or related crime must report immediately to the MLRO under the internal SAR procedure; the MLRO assesses the report and decides whether an external disclosure is needed.

7.2 External

Where reasonable grounds for suspicion exist, the MLRO makes an external report to the competent financial intelligence unit or regulator under the Anjouan licence and international standards, without notifying the player (tipping-off prohibition).

7.3 Tipping off

Tipping off is strictly prohibited. No employee, contractor or representative may tell a player or third party about a SAR or AML investigation. Breach is a serious disciplinary matter and may be a criminal offence.

7.4 Red flags

Examples that may lead to review or a SAR (illustrative, not exhaustive):

• Repeated minimum deposits (€20) in quick succession to build a larger total without a single large-deposit review;
• Deposits through several payment methods or cards unconnected to the verified account;
• A withdrawal request of €40 or more immediately after a deposit with little or no meaningful play;
• Inconsistency between declared occupation or income and deposit or wagering volumes;
• Inability or unwillingness to provide satisfactory KYC documents within a reasonable time;
• Exploitation of bonus terms, free-spin awards or rakeback credits inconsistent with genuine recreational play;
• Third-party deposits from payment methods not belonging to the registered player;
• Activity consistent with chip dumping or collusion in live casino or sports betting;
• Requests to transfer account balances to third parties.

8. Third-party payments

Deposits from, and withdrawals to, payment methods not belonging to the account holder are not accepted. Deposits must come from a method in the holder's name; withdrawals return to the same method wherever possible.

On a name mismatch, Proof of Banking Option documents are requested before processing. Persistent third-party use, or an unsatisfactory explanation, may lead to suspension and escalation to the MLRO.

9. Record keeping

KYC documents, transaction records, activity logs and SAR-related records are kept for at least five years from the last transaction, or longer if the licence or the law requires, stored securely and accessible to the MLRO and compliance team for audit and reporting.

KYC data is processed under the Privacy Policy: only what is necessary is collected, retained only as long as required and used only for compliance, fraud prevention and provision of services.

10. Player obligations

By registering at luckyy-boom.nl the player confirms and warrants that:

• He or she is at least 18 years old;
• He or she is the sole registered user of the account and allows no third party to access or operate it;
• Deposited funds come from lawful sources and are not the proceeds of crime;
• The site is not used for money laundering, terrorist financing or other illegal activity;
• All information and documents provided at registration or during KYC are accurate, complete and up to date;
• Changes to registered details, including name, address or payment methods, will be notified promptly;
• Failure to cooperate with KYC may lead to restriction or closure of the account and withholding of withdrawals pending regulatory review.

11. Non-compliance

If satisfactory KYC documents are not provided within a reasonable period, or an account poses unacceptable AML or fraud risk, Lucky Boom may:

• Suspend deposits and withdrawals pending verification;
• Void bonus funds or rakeback credits;
• Close the account permanently;
• Withhold the balance pending regulatory guidance or confirmation of lawful origin;
• Report to the financial intelligence authority or law enforcement as the licence requires.

Determinations are made in good faith, with an opportunity to resolve documentation issues before irreversible action where possible; where the law requires immediate action, such as a confirmed sanctions match, action may be immediate and without notice.

12. Responsible gambling and AML

The two frameworks operate in parallel. Indicators of problem gambling found in monitoring (escalating deposit frequency, large deposits followed by distressed withdrawal requests, play beyond means) are shared with the responsible gambling team, and responsible gambling signals may prompt AML review, for example a claimed inability to afford losses alongside high-value deposits.

Limits, breaks and help: contact the 24/7 support team by live chat or at support@luckyy-boom.nl at any time.

13. Staff training

Employees and contractors handling accounts, transactions or compliance receive role-appropriate AML and KYC training on suspicious activity, internal reporting, tipping off and this Policy, at onboarding and regularly thereafter.

14. Review

The compliance function reviews this Policy at least annually and when licence conditions, law or risk require. The current version is published at luckyy-boom.nl and supersedes earlier ones.

15. Contact

Questions on this Policy, KYC procedures or a verification request:

Lucky Boom is committed to a safe, fair and legally compliant environment. This Policy reflects that commitment, and players' cooperation is appreciated.