This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations and procedures that luckyboom (operated at lucky-booms.com by MAIREKE LIMITADA, a company incorporated in Costa Rica, and licensed by the Anjouan Offshore Financial Authority) applies to prevent money laundering, terrorist financing, and related financial crime. All players, transactions, and accounts at lucky-booms.com are subject to this Policy. By registering an account and using our services, you confirm that you have read, understood, and accept the terms set out below.

1. Legal Framework and Purpose

luckyboom operates under the licence granted by the Anjouan Offshore Financial Authority. In accordance with internationally recognised AML/CFT (Counter Financing of Terrorism) standards and the conditions of that licence, we are required to implement proportionate controls to detect, prevent, and report activity that may constitute money laundering or the financing of terrorism.

The purpose of this Policy is to:

• Establish the obligations of luckyboom and its players in relation to identity verification and source-of-funds checks;
• Define when, how, and why we collect, verify, and retain personal and financial documentation;
• Explain how we monitor transactions on an ongoing basis;
• Set out the consequences of non-compliance, including account restriction or closure;
• Describe our reporting obligations where suspicious activity is identified.

This Policy applies to all employees, contractors, and third-party service providers acting on behalf of luckyboom, as well as to all registered players at lucky-booms.com.

2. Definitions

• AML — Anti-Money Laundering: the set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.
• CFT — Counter Financing of Terrorism: measures designed to prevent funds being used to support terrorist activity.
• KYC — Know Your Customer: the process by which we verify the identity, address, and, where required, the source of funds or wealth of our players.
• CDD — Customer Due Diligence: standard verification checks applied to all players.
• EDD — Enhanced Due Diligence: additional, more thorough checks applied to higher-risk players or transactions.
• PEP — Politically Exposed Person: an individual who holds or has held a prominent public function, including close associates and family members.
• SAR — Suspicious Activity Report: a formal internal or external report raised where money laundering or terrorist financing is suspected.
• MLRO — Money Laundering Reporting Officer: the designated individual at luckyboom responsible for receiving internal SARs, evaluating them, and making external disclosures where required.

3. Risk-Based Approach

luckyboom adopts a risk-based approach to AML and KYC compliance. This means we assess the level of risk associated with each player and each transaction and apply controls that are proportionate to that risk. Not every player will be subject to the same level of scrutiny, but every player is subject to at least standard CDD before withdrawals are approved.

Factors that influence our risk assessment include, but are not limited to:

• The player's country of residence or nationality;
• The payment methods and currencies used;
• Deposit and withdrawal frequency and volumes relative to stated income;
• The nature and pattern of gameplay;
• Whether the player is identified as a PEP or appears on a sanctions list;
• Any prior suspicious activity or flagged transactions on the account;
• The source of funds declared by the player.

Where risk indicators are elevated, we will apply EDD and may request additional documentation before processing any withdrawals or continuing to provide services.

4. Customer Due Diligence — Standard KYC Requirements

4.1 When KYC Is Triggered

luckyboom may request identity verification documents at any point after registration, and will always require full KYC completion before approving a withdrawal. In practice, we encourage players to complete verification proactively after registration to avoid delays when they come to withdraw. KYC may also be triggered by:

• Cumulative deposits reaching an internal risk threshold;
• A withdrawal request being submitted, regardless of amount;
• A transaction pattern that appears inconsistent with prior activity;
• Identification of the player as a PEP or a match against a sanctions database;
• Any indicator that gives rise to suspicion of money laundering or fraud.

4.2 Standard Identity Documents

To satisfy standard CDD, we require the following from all players:

• Proof of Identity (POI) — a clear, full-colour copy of a valid government-issued photo ID. Acceptable documents include a national identity card, passport, or driving licence. The document must be current (not expired), must show your full legal name, date of birth, and photograph, and must be legible in all four corners.
• Proof of Address (POA) — a document confirming your residential address, issued within the last three months. Acceptable documents include a utility bill (gas, electricity, water, or fixed-line telephone), a bank statement, a government-issued letter, or a council tax statement. The document must display your full name and current residential address.
• Proof of Banking Option (POPM) — confirmation that the payment method used belongs to you. For bank cards, this may mean a photograph or screenshot showing the card number (with the middle eight digits obscured), your name, and the expiry date. For e-wallets or bank transfers, a screenshot of the account showing your name and account details is typically sufficient.

4.3 Selfie and Liveness Verification

In certain circumstances, we may ask you to submit a selfie photograph alongside your identity document, or to complete a liveness check through our verification system. This is to confirm that the person submitting documentation is the same individual pictured on the identity document and the registered account holder.

4.4 Document Submission

All KYC documents should be submitted through your account profile or via email to [email protected]. Our 24/7 live chat team can also guide you through the process in real time. Documents must be legible, unaltered, and complete. We reserve the right to reject documents that appear manipulated, cropped, or otherwise tampered with.

4.5 Verification Outcome and Timeline

We aim to process standard KYC submissions promptly. Where your documents are complete and satisfactory, verification will typically be completed within the timeframe consistent with our published payout approval window of within two business days. If additional information is required, our team will contact you directly. During any open verification review, withdrawals will be held pending satisfactory completion of KYC.

5. Enhanced Due Diligence

Where a player or transaction is assessed as higher risk, luckyboom will apply EDD. This is not a punitive measure — it is a regulatory and legal obligation. EDD may require one or more of the following in addition to standard CDD:

5.1 Source of Funds (SOF)

We may ask you to demonstrate where the specific funds used for gambling activity originated. Acceptable evidence includes, but is not limited to:

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

5.2 Source of Wealth (SOW)

In cases of very high transaction volumes or where the overall wealth of the player warrants examination, we may request Source of Wealth documentation. This is broader than SOF and seeks to understand how a player accumulated the assets they hold, not just the immediate origin of deposited funds.

5.3 PEP and Sanctions Screening

All players are screened against recognised PEP lists and international sanctions databases at the point of registration and on an ongoing basis. Where a player is identified as a PEP or as a match against a sanctions list, EDD is automatically applied. luckyboom reserves the right to decline to open an account for, or to close the account of, any individual who appears on a sanctions list or who presents an unacceptable level of risk as a PEP.

5.4 High-Value Player Monitoring

Players making use of the High Roller Bonus (deposits of €500 or more) or those approaching the weekly withdrawal cap of €20,000 or the monthly cap of €50,000 for non-jackpot wins will be subject to enhanced transaction monitoring. Where jackpot winnings are involved — which fall outside the standard monthly cap — additional source-of-funds verification may be required before the full payout is processed.

6. Ongoing Monitoring

KYC is not a one-time event. luckyboom monitors all accounts on a continuous basis throughout the player relationship. Ongoing monitoring includes:

• Real-time and retrospective review of deposits and withdrawals against stated player profiles;
• Monitoring of deposit and withdrawal patterns relative to the published limits (minimum deposit €20, minimum withdrawal €40, weekly cap €20,000, monthly cap €50,000);
• Identification of unusual betting patterns, including large rapid deposits followed by immediate withdrawal requests with minimal play;
• Detection of structuring behaviour — for example, splitting deposits to remain below internal thresholds;
• Periodic re-verification of player identity and address, particularly where account details are updated or a period of inactivity is followed by high-value activity;
• Cross-referencing of VIP status claims — players who request a VIP status match by submitting screenshots from another operator may be subject to additional scrutiny.

Where ongoing monitoring reveals activity that is inconsistent with a player's profile or that raises suspicion, the relevant account will be escalated internally for review, and access to withdrawals or continued play may be temporarily restricted pending investigation.

7. Suspicious Activity and Reporting

7.1 Internal Reporting

Any member of the luckyboom compliance or operations team who identifies or suspects money laundering, terrorist financing, or any related financial crime must report this immediately to the MLRO via the internal SAR procedure. The MLRO will assess the report, determine whether grounds for suspicion are established, and decide whether an external disclosure is required.

7.2 External Disclosure

Where the MLRO determines that reasonable grounds for suspicion exist, an external report will be made to the appropriate financial intelligence unit or regulatory body as required under the terms of our Anjouan licence and applicable international standards. Such disclosures will be made without notifying the player concerned (the "tipping-off" prohibition).

7.3 Tipping-Off Prohibition

luckyboom strictly prohibits tipping off. No employee, contractor, or representative of the business may inform a player or any third party that they are the subject of a SAR or an ongoing AML investigation. Any breach of this prohibition is treated as a serious disciplinary matter and may constitute a criminal offence under applicable law.

7.4 Red Flags

The following are examples of activity that may trigger an internal review or SAR at luckyboom. This list is illustrative, not exhaustive:

• A player depositing the minimum amount (€20) repeatedly in quick succession to reach a higher total without triggering a single large-deposit review;
• Deposits made using multiple payment methods or cards with no clear connection to the player's verified account;
• A player requesting a withdrawal of €40 or more immediately after depositing, with little or no meaningful gameplay in between;
• Inconsistency between a player's declared occupation or income and their deposit or wagering volumes;
• A player unable or unwilling to provide satisfactory KYC documentation within a reasonable timeframe;
• A player seeking to exploit bonus terms, free spins awards, or rakeback credits in a manner inconsistent with genuine recreational play;
• Third-party deposits — where funds appear to originate from a payment method not belonging to the registered player;
• Activity consistent with chip-dumping or collusion in live casino or sports betting contexts;
• Requests to transfer account balances to third parties.

8. Third-Party Payments

luckyboom does not accept deposits from, or process withdrawals to, payment methods that do not belong to the registered account holder. All deposits must be made from a payment method registered in the name of the luckyboom account holder, and all withdrawals will be returned to the same method used for deposit wherever possible.

Where a mismatch between the account holder's name and the payment method is detected, we will request Proof of Banking Option documentation before any transaction is processed. Persistent use of third-party payment methods, or an inability to satisfactorily explain such use, may result in account suspension and escalation to the MLRO.

9. Record Keeping

luckyboom retains all KYC documentation, transaction records, account activity logs, and SAR-related records for a minimum of five years from the date of the last transaction on an account, or for such longer period as may be required by our licence conditions or applicable law. Records are stored securely and are accessible to the MLRO and compliance team for audit and reporting purposes.

Player documentation and personal data collected for KYC purposes is processed in accordance with our Privacy Policy. We collect only what is necessary, retain it only for as long as required, and do not use it for any purpose other than compliance, fraud prevention, and the provision of our services.

10. Player Obligations

By registering an account at lucky-booms.com, you confirm and warrant that:

• You are at least 18 years of age;
• You are the sole registered user of your account and will not allow any third party to access or operate it on your behalf;
• All funds you deposit at luckyboom are from lawful sources and are not the proceeds of crime;
• You are not using the site to launder money or to facilitate the financing of terrorism or any other illegal activity;
• All information and documentation you provide to luckyboom during registration or KYC is accurate, complete, and up to date;
• You will notify luckyboom promptly if any of your registered details change, including your name, address, or payment methods;
• You understand that failure to cooperate with KYC requests may result in your account being restricted or closed and any withdrawals being withheld pending regulatory review.

11. Consequences of Non-Compliance

Where a player fails to provide satisfactory KYC documentation within a reasonable period, or where we determine that an account poses an unacceptable AML or fraud risk, luckyboom reserves the right to take any or all of the following steps:

• Suspend deposit and withdrawal access pending verification;
• Void any bonus funds or rakeback credits accumulated on the account;
• Permanently close the account;
• Withhold any balance pending regulatory guidance or a determination that the funds are from a lawful source;
• Report the matter to the relevant financial intelligence authority or law enforcement body as required under our licence obligations.

luckyboom will act in good faith in all such determinations and will, wherever possible, give the player an opportunity to resolve any documentation issue before taking irreversible action. However, where a legal obligation to act exists — for example, where a sanctions match is confirmed — we may act immediately and without prior notice.

12. Responsible Gambling and AML Interaction

Our AML and responsible gambling frameworks operate in parallel. Where monitoring identifies behaviour that may indicate problem gambling — such as escalating deposit frequency, large deposits followed by distressed withdrawal requests, or patterns suggesting a player is gambling beyond their means — these observations are shared with our responsible gambling team. Equally, responsible gambling indicators may prompt AML review where, for example, a player claims an inability to afford losses while simultaneously making high-value deposits.

Players who wish to set limits, take a break, or seek help with gambling-related issues may contact our 24/7 support team via live chat or at [email protected] at any time.

13. Staff Training

All luckyboom employees and contractors who handle player accounts, transactions, or compliance functions receive AML and KYC training appropriate to their role. This training covers the recognition of suspicious activity, internal reporting obligations, the tipping-off prohibition, and the requirements of this Policy. Training is provided at onboarding and refreshed on a regular basis to reflect any changes in regulatory guidance or internal procedures.

14. Policy Review

This Policy is reviewed at least annually by the luckyboom compliance function, and more frequently where required by changes to our licence conditions, applicable law, or the risk environment in which we operate. The current version of this Policy is published at lucky-booms.com and supersedes all previous versions. Players are encouraged to review this page periodically.

15. Contact

If you have any questions about this Policy, our KYC procedures, or a specific verification request you have received, please contact us:

We are committed to maintaining a safe, fair, and legally compliant environment at luckyboom. This Policy reflects that commitment, and we thank our players for their co-operation in helping us uphold it.