Aml & Kyc Policy

Scope and Purpose

Crazy Luck maintains this Anti-Money Laundering and Know Your Customer policy (the Policy) to prevent the use of its gaming platform for money laundering, terrorist financing, or other illicit activity. The Policy applies to all Crazy Luck products, including online casino, live dealer games, sports wagering where offered, payment processors, and any third‑party service integrated with the platform. It sets out the minimum controls, data collection, verification, monitoring, and reporting obligations required by applicable laws and regulatory guidance.

Definitions

  • Money Laundering refers to the process of concealing the origins of illegally obtained funds or assets.
  • Terrorist Financing refers to providing or procuring funds or resources to support terrorist activities, irrespective of the source of funds.
  • Customer means any person or entity that registers to use Crazy Luck services and is subject to KYC checks.
  • Beneficial Owner means the natural person(s) who ultimately own or control a customer accounting for ownership or control of a customer.
  • Politically Exposed Person (PEP) denotes an individual who is or has been entrusted with prominent public functions and their immediate family and close associates.
  • Source of Funds means the origin of the funds used to establish or maintain the business relationship.
  • Source of Wealth means the overall origin of a customer’s wealth from which funds are drawn.
  • Enhanced Due Diligence (EDD) refers to heightened verification and monitoring for higher‑risk customers or transactions.
  • Suspicious Activity includes any transaction or pattern that may signify money laundering, terrorist financing, or other criminal activity.

Regulatory Framework

Crazy Luck complies with applicable anti‑money laundering (AML) and counter‑terrorist financing (CTF) statutes, regulations, and supervisory guidance in the jurisdictions in which it operates. A designated AML Compliance Officer oversees policy implementation, periodic risk assessments, and reporting obligations. The Company will implement updates to the Policy to reflect changes in law, guidance, or material risk findings.

Customer Identification and Verification (KYC)

Crazy Luck will identify and verify the customer’s identity prior to or during the course of providing services, using a risk‑based approach. Verification steps may be performed on onboarding and at intervals thereafter as risk dictates.

  1. Identity information: collect full legal name, date of birth, residential address, country of residence, and contact details. The information must be accurate and verifiable.
  2. Documentary evidence: obtain copies of valid documents such as a passport, national identity card, or driving license; and documentation confirming current address (e.g., utility bill, bank statement) not older than six months.
  3. Payment method ownership: where applicable, obtain evidence of ownership of payment methods used (e.g., a front and back copy of a payment card, a screenshot of the e‑wallet, or a recent bank statement) not older than six months.
  4. Non‑face‑to‑face verification: for remote onboarding, Crazy Luck may request a live selfie with holding a valid Identification Document; if required, notarised or certified ID may be requested under applicable law.
  5. Age verification: confirm that the customer is at least 18 years old; underage participation is strictly forbidden.

Verification must be completed before permitting deposits, bets, or withdrawals to commence, and not‑completed verification may result in restricted account activity or closure with funds retained as permitted by law.

Beneficial Ownership, Sanctions and PEP Screening

Crazy Luck conducts ongoing screening for beneficial ownership, sanctions, and PEP status as part of customer due diligence. If a match or adverse risk is identified, the customer relationship will be reviewed and may be escalated for enhanced due diligence or terminated in accordance with applicable law. Any confirmed sanction or PEP risk triggers immediate review, potential temporary restrictions, and reporting to the relevant authorities where required.

Risk-Based Approach and Enhanced Due Diligence

The Company applies a risk‑based framework to determine the level of due diligence and ongoing monitoring required. Risk factors include customer risk, geographic risk, product risk, and channel risk. High‑risk scenarios—such as large or unusual transaction patterns, non‑resident customers, or PEP status—trigger enhanced due diligence, including intensified verification, longer record retention, and more frequent review of the customer profile.

  • Onboarding risk classification: low, medium, high.
  • EDD triggers: large or unusual transactions, rapid movement of funds, or discrepancies in documentation.
  • Enhanced monitoring intervals: at least monthly for high risk, with ongoing review as activity changes.

Source of Funds and Source of Wealth

Customers must provide a credible explanation of the source of funds used for the Crazy Luck account, including supporting documentation. Acceptable documentation may include recent payslips, tax returns, bank statements, or other information sufficient to verify declared sources. For substantial deposits or atypical activity, the customer must supply additional documentation or declarations showing the origin and legitimacy of the funds. Failure to provide requested information within 30 days may result in restrictions or account termination, with pending funds treated in accordance with applicable law.

Ongoing Monitoring and Transaction Surveillance

Transactions are continuously monitored for suspicious activity. Crazy Luck uses automated screening to detect patterns inconsistent with the customer’s profile, including rapid funds movement, inconsistent source data, and anomalies in gaming or betting activity. Suspicious activity is escalated to the AML Compliance Officer for investigation and, if appropriate, reported to the relevant authorities. Customer activity that remains unexplained or unverifiable may lead to temporary restrictions or closure of the account and withholding of funds as permitted by law.

Recordkeeping and Data Retention

Crazy Luck retains records related to customer identification, due diligence, risk assessments, transactions, and any reports of suspicious activity for a period consistent with applicable law. In general, records are kept for no less than five years after the termination of the customer relationship or after the last material activity, whichever is later. Records include copies of identification documents, verification results, source of funds/wealth declarations, transaction data, and correspondence related to KYC and AML matters.

Data Privacy and Security

Personal data processed under this Policy is handled in accordance with Crazy Luck’s privacy policy and applicable data protection laws. Data is stored securely, access is role‑based and restricted, and all processing is documented for auditing purposes. In the event of a data breach, Crazy Luck will follow its incident response procedures and regulatory notification requirements as applicable.

Roles, Responsibilities, and Oversight

The Board retains ultimate responsibility for the policy. An AML Compliance Officer is appointed to oversee day‑to‑day implementation, risk assessment, monitoring, and reporting. The Compliance Team conducts customer due diligence, trains staff, and coordinates internal and external reporting. Internal audit reviews AML controls on a scheduled basis or as required by regulatory changes.

Training and Awareness

Crazy Luck provides initial and ongoing training to all staff involved in customer onboarding, payments, and risk assessment. Training covers regulatory requirements, identification of suspicious activity, internal escalation procedures, and updates to the AML/CTF framework.

Reporting Suspicious Activity and Cooperation with Authorities

Any knowledge or reasonable suspicion of money laundering, terrorist financing, or other criminal activity must be reported through the internal escalation channel to the AML Compliance Officer and, where required, to relevant authorities in accordance with law. Crazy Luck will cooperate with law enforcement and regulatory authorities, providing information requested in connection with investigations, while maintaining the confidentiality of customers as permitted by law.

Account Restrictions, Withholding Funds, and Disclosures

Crazy Luck may suspend or restrict a customer’s activity, withhold deposits or withdrawals, or terminate access to the platform if verification cannot be completed, if suspicious activity is detected, or if required documentation is not provided. Any funds withheld are handled in accordance with applicable law and internal procedures, including possible freezing pending authorities’ guidance or court orders.

Policy Review and Updates

This Policy is reviewed at least annually and when regulatory changes or material risk developments occur. Revisions are communicated in accordance with Crazy Luck’s governance framework, and customers are informed of material changes as required by law or regulation.