This Anti-Money Laundering and Know Your Customer Policy (the "Policy") describes the duties and procedures that Lucky Boom (operated at dagvoorzitterspreker.nl 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. Every player, transaction and account at dagvoorzitterspreker.nl falls under this Policy. By registering an account and using our services, you confirm that you have read, understood and accepted what follows.

1. Legal Framework and Purpose

Lucky Boom operates under the licence of the Anjouan Offshore Financial Authority. In line with internationally recognised AML/CFT (Counter Financing of Terrorism) standards and the conditions of that licence, we must apply proportionate controls to detect, prevent and report activity that may be money laundering or terrorist financing.

This Policy aims to:

• Set out the duties of Lucky Boom and its players regarding identity verification and source-of-funds checks;
• Define when, how and why we collect, verify and keep personal and financial documents;
• Explain how we monitor transactions on an ongoing basis;
• State the consequences of non-compliance, including restriction or closure of an account;
• Describe our reporting duties when suspicious activity is found.

This Policy applies to all employees, contractors and third-party service providers acting for Lucky Boom, and to all registered players at dagvoorzitterspreker.nl.

2. Definitions

• AML — Anti-Money Laundering: the laws, rules and procedures that stop criminals from passing illegally obtained money off as legitimate income.
• CFT — Counter Financing of Terrorism: measures that stop money from being used to support terrorist activity.
• KYC — Know Your Customer: the process through which we verify a player's identity, address and, where needed, the source of funds or wealth.
• CDD — Customer Due Diligence: the standard checks applied to every player.
• EDD — Enhanced Due Diligence: extra, deeper checks for higher-risk players or transactions.
• PEP — Politically Exposed Person: someone who holds or has held a prominent public position, including close associates and family members.
• SAR — Suspicious Activity Report: a formal internal or external report made when money laundering or terrorist financing is suspected.
• MLRO — Money Laundering Reporting Officer: the person at Lucky Boom who receives internal SARs, evaluates them and makes external disclosures where required.

3. Risk-Based Approach

Lucky Boom takes a risk-based approach to AML and KYC. We assess the risk linked to each player and each transaction and apply controls that match it. Not every player is checked equally closely, but every player goes through at least standard CDD before a withdrawal is approved.

Factors in our risk assessment include, among others:

• The player's country of residence or nationality;
• The payment methods and currencies used;
• How often and how much the player deposits and withdraws compared with the income they state;
• The nature and pattern of play;
• Whether the player is a PEP or appears on a sanctions list;
• Earlier suspicious activity or flagged transactions on the account;
• The source of funds the player declares.

Where risk indicators are high, we apply EDD and may ask for more documents before processing any withdrawal or continuing to provide services.

4. Customer Due Diligence — Standard KYC Requirements

4.1 When KYC Is Triggered

Lucky Boom may ask for identity documents at any time after registration, and always requires full KYC before approving a withdrawal. We encourage players to complete verification early, so they do not wait when they want to withdraw. KYC can also be triggered by:

• Total deposits reaching an internal risk threshold;
• A withdrawal request, whatever the amount;
• A transaction pattern that does not fit earlier activity;
• Identifying the player as a PEP or finding a match in a sanctions database;
• Any indicator that raises suspicion of money laundering or fraud.

4.2 Standard Identity Documents

For standard CDD we need the following from every player:

• Proof of Identity (POI) — a clear, full-colour copy of a valid government-issued photo ID, such as a national identity card, passport or driving licence. It must be current (not expired), show your full legal name, date of birth and photograph, and be readable in all four corners.
• Proof of Address (POA) — a document that confirms your home address and was issued within the last three months, for example a utility bill (gas, electricity, water or landline telephone), a bank statement, a government letter or a council tax statement. It must show your full name and current home address.
• Proof of Banking Option (POPM) — confirmation that the payment method belongs to you. For bank cards this can be a photo or screenshot showing the card number (middle eight digits hidden), your name and the expiry date. For e-wallets or bank transfers, a screenshot of the account showing your name and account details is usually enough.

4.3 Selfie and Liveness Verification

In some cases we may ask for a selfie together with your identity document, or for a liveness check in our verification system. This confirms that the person sending the documents is the one shown on the ID and the registered account holder.

4.4 Document Submission

Send all KYC documents through your account profile or by email to support@dagvoorzitterspreker.nl. Our 24/7 live chat team can also walk you through it in real time. Documents must be readable, unaltered and complete. We may reject documents that look manipulated, cropped or otherwise tampered with.

4.5 Verification Outcome and Timeline

We aim to process standard KYC submissions quickly. When your documents are complete and in order, verification is normally finished within our published payout approval window of two business days. If we need more information, our team will contact you directly. While a verification review is open, withdrawals are on hold until KYC is completed satisfactorily.

5. Enhanced Due Diligence

When a player or transaction is judged higher risk, Lucky Boom applies EDD. This is not a punishment; it is a regulatory and legal duty. EDD can require one or more of the following on top of standard CDD:

5.1 Source of Funds (SOF)

We may ask you to show where the money used for gambling came from. Acceptable evidence includes, among other things:

• Recent payslips or an employment contract showing your salary;
• Bank statements showing regular salary payments or receipt of the funds in question;
• A letter from an accountant or employer confirming your income;
• Papers confirming an inheritance, the proceeds of a property sale or investment dividends;
• Business accounts or tax returns for the self-employed.

5.2 Source of Wealth (SOW)

With very high transaction volumes, or where a player's overall wealth deserves a closer look, we may ask for Source of Wealth documents. This is broader than SOF: it seeks to understand how the player built up the assets they hold, not only where the deposited money came from.

5.3 PEP and Sanctions Screening

All players are screened against recognised PEP lists and international sanctions databases at registration and on an ongoing basis. If a player is identified as a PEP or matches a sanctions list, EDD is applied automatically. Lucky Boom may decline to open an account for, or may close the account of, anyone who appears on a sanctions list or presents an unacceptable level of risk as a PEP.

5.4 High-Value Player Monitoring

Players who use the High Roller Bonus (deposits of €500 or more), or who approach the weekly withdrawal cap of €20,000 or the monthly cap of €50,000 for non-jackpot wins, are monitored more closely. Where jackpot winnings are involved, which fall outside the normal monthly cap, extra source-of-funds verification may be required before the full payout is processed.

6. Ongoing Monitoring

KYC is not a one-off event. Lucky Boom monitors all accounts continuously for as long as the player relationship lasts. Ongoing monitoring includes:

• Real-time and retrospective review of deposits and withdrawals against the player's stated profile;
• Watching deposit and withdrawal patterns against the published limits (minimum deposit €20, minimum withdrawal €40, weekly cap €20,000, monthly cap €50,000);
• Spotting unusual betting patterns, such as large quick deposits followed at once by withdrawal requests with minimal play;
• Detecting structuring, for example splitting deposits to stay below internal thresholds;
• Periodic re-verification of identity and address, particularly when account details are updated or a quiet period is followed by high-value activity;
• Cross-checking VIP status claims: players who ask for a VIP status match by sending screenshots from another operator may be looked at more closely.

If monitoring reveals activity that does not fit a player's profile or that raises suspicion, the account is escalated internally for review, and access to withdrawals or continued play may be restricted temporarily while we investigate.

7. Suspicious Activity and Reporting

7.1 Internal Reporting

Any member of the Lucky Boom compliance or operations team who identifies or suspects money laundering, terrorist financing or related financial crime must report it immediately to the MLRO under the internal SAR procedure. The MLRO assesses the report, decides whether grounds for suspicion exist and whether an external disclosure is needed.

7.2 External Disclosure

Where the MLRO decides that reasonable grounds for suspicion exist, an external report is made to the appropriate financial intelligence unit or regulatory body, as required by our Anjouan licence and applicable international standards. These disclosures are made without telling the player concerned (the "tipping-off" prohibition).

7.3 Tipping-Off Prohibition

Lucky Boom strictly prohibits tipping off. No employee, contractor or representative may tell a player or any third party that they are the subject of a SAR or an AML investigation. Any breach is treated as a serious disciplinary matter and may be a criminal offence under applicable law.

7.4 Red Flags

The following are examples of activity that may lead to an internal review or a SAR at Lucky Boom. The list is illustrative, not complete:

• A player repeatedly depositing the minimum (€20) in quick succession to reach a larger total without triggering a review of a single large deposit;
• Deposits through several payment methods or cards with no clear link to the player's verified account;
• A withdrawal request of €40 or more right after a deposit, with little or no real play in between;
• A mismatch between the occupation or income a player declares and their deposit or wagering volumes;
• A player who cannot or will not provide satisfactory KYC documents within a reasonable time;
• A player trying to exploit bonus terms, free-spin awards or rakeback credits in a way that does not fit genuine recreational play;
• Third-party deposits, where funds appear to come from a payment method that does not belong 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

Lucky Boom does not accept deposits from, or process withdrawals to, payment methods that do not belong to the registered account holder. All deposits must come from a payment method registered in the name of the Lucky Boom account holder, and withdrawals go back to the same method used for the deposit wherever possible.

If the account holder's name does not match the payment method, we ask for Proof of Banking Option documents before any transaction is processed. Persistent use of third-party payment methods, or failure to explain it satisfactorily, may lead to suspension of the account and escalation to the MLRO.

9. Record Keeping

Lucky Boom keeps all KYC documents, transaction records, account activity logs and SAR-related records for at least five years from the date of the last transaction on an account, or longer if our licence conditions or the law require. Records are stored securely and are available to the MLRO and the compliance team for audit and reporting.

Player documents and personal data collected for KYC are processed in line with our Privacy Policy. We collect only what is necessary, keep it only as long as required and use it for nothing but compliance, fraud prevention and providing our services.

10. Player Obligations

By registering an account at dagvoorzitterspreker.nl, you confirm and warrant that:

• You are at least 18 years old;
• You are the only registered user of your account and will not let anyone else access or operate it for you;
• All money you deposit at Lucky Boom comes from lawful sources and is not the proceeds of crime;
• You are not using the site to launder money or to facilitate terrorist financing or any other illegal activity;
• All information and documents you give Lucky Boom at registration or during KYC are accurate, complete and up to date;
• You will tell Lucky Boom promptly if any registered detail changes, including your name, address or payment methods;
• You understand that if you do not cooperate with KYC requests, your account may be restricted or closed and withdrawals withheld pending regulatory review.

11. Consequences of Non-Compliance

If a player does not provide satisfactory KYC documents within a reasonable time, or if we decide that an account poses an unacceptable AML or fraud risk, Lucky Boom may take any or all of these steps:

• Suspend deposit and withdrawal access pending verification;
• Void bonus funds or rakeback credits earned on the account;
• Close the account permanently;
• Withhold any balance pending regulatory guidance or a finding that the funds come from a lawful source;
• Report the matter to the relevant financial intelligence authority or law enforcement body as our licence obligations require.

Lucky Boom acts in good faith in all such decisions and, where possible, gives the player a chance to fix a documentation problem before taking irreversible action. Where a legal duty to act exists, for example when a sanctions match is confirmed, we may act at once and without prior notice.

12. Responsible Gambling and AML Interaction

Our AML and responsible gambling frameworks run in parallel. When monitoring finds behaviour that may point to problem gambling, such as more frequent deposits, large deposits followed by distressed withdrawal requests, or patterns suggesting someone is gambling beyond their means, we share these observations with our responsible gambling team. In the same way, responsible gambling signals can trigger an AML review, for example when a player says they cannot afford losses while making high-value deposits.

Players who wish to set limits, take a break or get help with gambling-related issues can contact our 24/7 support team through live chat or at support@dagvoorzitterspreker.nl at any time.

13. Staff Training

All Lucky Boom employees and contractors who handle player accounts, transactions or compliance receive AML and KYC training suited to their role. It covers spotting suspicious activity, internal reporting duties, the tipping-off prohibition and the requirements of this Policy. Training is given at onboarding and refreshed regularly to reflect changes in regulatory guidance or internal procedures.

14. Policy Review

The Lucky Boom compliance function reviews this Policy at least once a year, and more often when changes to our licence conditions, the law or the risk environment require. The current version is published at dagvoorzitterspreker.nl and replaces all earlier versions. Players are encouraged to look at this page from time to time.

15. Contact

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

We are committed to keeping Lucky Boom a safe, fair and legally compliant place. This Policy reflects that commitment, and we thank our players for helping us uphold it.