This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of luckygem, operated by Virtual Connect Sociedad de Responsabilidad Limitada ("we", "us", "the Company") at luckygem-cassino.com, to prevent money laundering, terrorist financing, and related financial crime. All registered players and prospective players are required to read and comply with this Policy. By registering an account or conducting any transaction on luckygem-cassino.com, you confirm that you have read, understood, and accepted the terms set out below.

1. Operator Details and Regulatory Framework

luckygem-cassino.com is owned and operated by Virtual Connect Sociedad de Responsabilidad Limitada, a company incorporated and licensed under the laws of Costa Rica. The Company holds a Costa Rica gaming licence and conducts its operations in accordance with applicable Costa Rican legislation governing online gaming and financial crime prevention.

Although Costa Rica does not prescribe a single mandatory AML statute identical to those of EU member states, the Company voluntarily adopts internationally recognised standards — including the recommendations of the Financial Action Task Force (FATF) — as the foundation of this Policy. This reflects our commitment to operating a safe, transparent, and responsible gaming environment.

This Policy applies to:

• All accounts registered on luckygem-cassino.com;
• All deposits, withdrawals, bonus claims, and wagering activity conducted through the platform;
• All members of staff, contractors, and third-party agents acting on behalf of the Company.

2. Purpose and Scope

The purpose of this Policy is to:

• Prevent luckygem-cassino.com from being used, intentionally or otherwise, as a vehicle for money laundering or the financing of terrorism;
• Establish clear procedures for identifying and verifying the identity of players (Know Your Customer);
• Define the standards for monitoring transactions and detecting suspicious activity;
• Specify the record-keeping obligations the Company applies to all customer data and transaction history;
• Set out escalation and reporting procedures when suspicious activity is identified.

This Policy covers all payment methods available on luckygem-cassino.com, including bank transfers via ING, Rabobank, ABN AMRO, SNS, ASN Bank, N26, and Revolut; card payments via Visa and Mastercard; Apple Pay; and cryptocurrency transactions.

3. Definition of Money Laundering

Money laundering is the process by which criminally obtained funds are introduced into the legitimate financial system so as to disguise their origin. For the purposes of this Policy, money laundering includes the following stages:

• Placement: The introduction of illicit funds into the financial system, for example by depositing cash-derived proceeds onto a gaming account.
• Layering: The concealment of the origin of funds through a series of complex transactions designed to create distance between the funds and their criminal source, such as repeated deposits and withdrawals with minimal wagering activity.
• Integration: The re-introduction of laundered funds into the legitimate economy as apparently clean money.

The Company also recognises the risk of terrorist financing, whereby legitimately or illegitimately obtained funds are channelled towards terrorist activities. Both money laundering and terrorist financing are treated with equal seriousness under this Policy.

4. Know Your Customer (KYC) Policy

4.1 General Obligation

The Company is committed to verifying the identity of every player to a standard sufficient to confirm that the individual is who they claim to be, that they are of legal age, and that the funds they use are derived from legitimate sources. KYC is not merely a one-time check at registration; it is an ongoing process that continues throughout the player's relationship with luckygem-cassino.com.

4.2 Triggering Events for KYC

KYC verification is required, and the player's first withdrawal will be held pending satisfactory completion, in the following circumstances:

• First withdrawal request: KYC documents must be submitted and approved before any withdrawal is processed. This is mandatory for every account on luckygem-cassino.com without exception.
• Cumulative deposits or withdrawals reaching internal risk thresholds: Where a player's total transaction volume reaches a level that triggers enhanced due diligence under our internal risk framework.
• Any transaction or pattern of behaviour that raises a reasonable suspicion of money laundering or fraud.
• Periodic review: The Company reserves the right to request updated documentation at any point during the account lifecycle, even where KYC was previously completed.
• Changes to account details: Including changes to payment methods, registered address, or other personal information.

4.3 Standard KYC Documents Required

To complete standard (basic) KYC verification, the following documents must be submitted:

• Proof of Identity: A government-issued photo ID, such as a national identity card, passport, or driving licence. The document must be valid (not expired), clearly legible, and show your full name, date of birth, and photograph.
• Proof of Address: A recent utility bill, bank statement, or official correspondence issued within the last three months, showing your full name and current residential address. PO box addresses are not accepted.
• Payment Method Verification: Where a player has deposited using a debit or credit card, a copy of both sides of the card must be provided. For security purposes, only the first six and last four digits of the card number need to be visible — all other digits should be obscured. The cardholder name and expiry date must be clearly legible.
• Bank Statement: A recent bank statement confirming ownership of the bank account used to deposit or receive withdrawals.

All documents must be submitted in a clear, high-resolution format. Documents that are blurred, cropped, or partially illegible will not be accepted and the player will be asked to resubmit. The Company aims to review and process standard KYC submissions promptly; approval timelines will not exceed the withdrawal processing window of two banking days in straightforward cases.

4.4 Enhanced Due Diligence (EDD)

Enhanced due diligence may be required in addition to standard KYC where a player's profile, behaviour, or transaction history presents a heightened risk. Circumstances that may trigger EDD include, but are not limited to:

• High-value transactions or withdrawal requests that approach or exceed the monthly withdrawal limit of €10,000;
• Rapid or large deposits followed by immediate withdrawal requests with little or no wagering activity;
• Player accounts that reach higher VIP tiers and transact at elevated volumes;
• Inconsistencies between stated occupation and observed transaction volumes;
• Players identified as Politically Exposed Persons (PEPs), their family members, or close associates;
• Players whose country of residence or nationality is associated with a high-risk jurisdiction on the FATF grey or black list;
• Any other circumstance that, in the reasonable judgement of the Company's compliance team, warrants additional scrutiny.

EDD measures may include, but are not limited to:

• Requesting proof of source of funds (e.g., payslips, tax returns, company accounts, dividend statements, inheritance documentation);
• Requesting proof of source of wealth;
• Senior management review and approval before processing transactions;
• More frequent ongoing monitoring of account activity;
• Verification of information against independent, reliable sources.

The Company reserves the right to suspend, restrict, or close any account where EDD requirements are not satisfied within a reasonable period, or where the information provided is insufficient to resolve concerns satisfactorily.

4.5 Age Verification

luckygem-cassino.com strictly prohibits access to and participation by minors. All players must be at least 18 years of age. Age verification forms part of the standard KYC process, and the Company reserves the right to request age-confirming documentation at any stage. Where a player is found to be under 18, their account will be immediately closed, all funds returned (less any amounts required to reverse unauthorised activity), and the matter reported to relevant authorities where legally required.

4.6 Account Suspension Pending KYC

Where KYC documentation has been requested but not yet received, or where submitted documentation is undergoing review, the Company may place a temporary restriction on withdrawal processing. Deposits and wagering may continue at the Company's discretion during this period. The Company is not liable for delays to withdrawal processing that arise from a player's failure to provide requested KYC documentation promptly and in the required format.

5. Customer Due Diligence (CDD) Framework

5.1 Risk-Based Approach

The Company applies a risk-based approach to customer due diligence. This means that the level of scrutiny applied to any given player or transaction is proportionate to the assessed risk that player or transaction presents. Not all customers present the same level of risk, and our procedures are calibrated accordingly.

Risk factors considered when assessing a player's profile include:

• Country or jurisdiction of residence;
• Payment methods used and their associated risk profiles;
• Volume, frequency, and pattern of transactions;
• Whether the player has been identified as a PEP;
• Nature and consistency of wagering activity relative to deposit and withdrawal behaviour;
• Any adverse media, sanctions screening results, or prior flags on the account.

5.2 Ongoing Monitoring

KYC is not a single event. The Company conducts ongoing monitoring of all active accounts, including:

• Continuous transaction monitoring to detect patterns inconsistent with a player's stated profile or established behaviour;
• Periodic re-verification of player identity and, where appropriate, source of funds;
• Automated and manual review of accounts that exhibit red-flag indicators (see Section 7);
• Screening of all players against international sanctions lists and PEP databases on an ongoing basis.

5.3 Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds or has held a prominent public function, or is an immediate family member or known close associate of such a person. PEPs are subject to enhanced due diligence by default, regardless of their transaction volumes. The Company screens all players against recognised PEP databases. PEP accounts require senior management approval to open and to continue operating, and are subject to more frequent review.

5.4 Sanctions Screening

The Company screens all new registrations and existing players against relevant international sanctions lists, including those published by the United Nations, the European Union, and other applicable regulatory authorities. Players who appear on a sanctions list will have their accounts immediately frozen, pending further review and, where applicable, reporting to the relevant authority. Funds held in sanctioned accounts will not be released until the Company has received appropriate legal guidance.

6. Payment Methods and AML Considerations

luckygem-cassino.com supports a range of payment methods, each of which carries its own risk profile. The Company applies additional scrutiny appropriate to each method.

The Company operates a strict same-method withdrawal policy: funds are returned to the method used to deposit. No third-party deposits or withdrawals are permitted under any circumstances. Where a third-party source of funds is identified, the deposit will be reversed and the account reviewed.

7. Red-Flag Indicators and Suspicious Activity

The Company's compliance team and automated monitoring systems are trained to identify behavioural and transactional patterns that may indicate money laundering or other financial crime. The following non-exhaustive list of red flags will trigger an internal review and may result in account suspension, enhanced due diligence, or a suspicious activity report:

• Depositing funds and then requesting a withdrawal of substantially the same amount with little or no wagering activity;
• Multiple rapid deposits up to the maximum withdrawal limit (€10,000/month) followed immediately by a withdrawal request;
• Consistent deposits just below internal monitoring thresholds (structuring);
• Use of multiple payment methods to fund an account in rapid succession without a clear legitimate reason;
• Requests to change registered payment methods immediately before or after a large withdrawal;
• A player's transaction volumes appearing inconsistent with their stated occupation or financial profile;
• Attempts to circumvent account limits, verification requirements, or bonus terms in a manner that suggests deliberate obfuscation;
• Unusual cryptocurrency transaction patterns, including funds traced to high-risk wallets or mixers;
• Account sharing or evidence that multiple individuals are operating a single registered account;
• Inconsistencies between information provided during registration and information revealed during KYC documentation review.

8. Withdrawal Limits and Large Win Procedures

The following withdrawal limits apply to all accounts on luckygem-cassino.com:

Wins exceeding €10,000 (other than progressive jackpot wins, which are paid in full as a single payment) will be paid in monthly instalments of up to €10,000 each. This instalment process allows the Company to conduct proportionate ongoing AML checks as larger sums are released. Progressive jackpot wins are paid in full without instalments, though full KYC and, where applicable, enhanced due diligence must be completed before the payment is released.

All withdrawal requests are processed within two banking days following approval. The minimum withdrawal is €40. Withdrawal requests will not be approved until KYC requirements are satisfied in full.

9. Record Keeping

The Company maintains comprehensive records in accordance with its AML obligations and general data protection principles. Records kept include:

• Copies of all KYC documents submitted by players, including identity documents, proof of address, payment method verification, and source-of-funds documentation;
• Full transaction history for every account, including all deposits, withdrawals, bonus transactions, and wagering activity;
• Records of all internal risk assessments, compliance reviews, and enhanced due diligence investigations;
• Records of any suspicious activity reports (SARs) filed, including the date, nature of the concern, and outcome;
• Communications between the Company and the player that are relevant to AML or KYC matters.

Records are retained for a minimum of five years from the date of the last transaction or the closure of the account, whichever is later, in line with international best-practice standards. Records are stored securely and access is restricted to authorised personnel only.

10. Suspicious Activity Reporting

Where the Company identifies, or reasonably suspects, that a transaction or pattern of activity may involve money laundering, terrorist financing, or the proceeds of crime, it will take the following steps:

• The compliance team will prepare an internal suspicious activity report (SAR) documenting the nature of the concern, the relevant account details, and the transactions in question;
• The SAR will be reviewed by a senior compliance officer, who will determine whether to escalate the matter to the relevant authority;
• Where escalation is required, the Company will file a report with the appropriate authority in accordance with applicable law and will take such further steps as that authority directs;
• The Company will not "tip off" the player that a SAR has been filed or that they are under investigation, as this is itself a criminal offence under applicable AML legislation;
• The account may be frozen pending the outcome of any investigation, and no funds will be released without authorisation from the relevant authority where such authorisation is required.

11. Staff Training and Internal Controls

The Company is committed to ensuring that all relevant staff are adequately trained to identify and respond to money laundering and terrorist financing risks. Internal controls maintained by the Company include:

• AML and KYC training for all staff involved in player account management, payments processing, and compliance;
• Clear internal escalation procedures for reporting concerns to the senior compliance officer;
• Regular review and updating of this Policy to reflect changes in applicable law, guidance, and best practice;
• Appointment of a designated compliance officer responsible for overseeing the day-to-day operation of this Policy and acting as the primary contact for AML matters;
• Periodic internal audits of compliance procedures to assess their effectiveness and identify areas for improvement.

12. Player Obligations

Players have the following obligations under this Policy:

• To provide accurate, truthful, and complete information at the time of registration and at any subsequent point when information is requested by the Company;
• To submit all requested KYC documentation promptly and in the format specified by the Company;
• To notify the Company immediately of any changes to personal details, including name, address, or payment method;
• Not to use luckygem-cassino.com to deposit, wager, or withdraw funds derived from criminal activity;
• Not to conduct any transaction on behalf of a third party without the Company's prior written consent;
• Not to attempt to circumvent the Company's AML or KYC procedures by any means, including structuring deposits to avoid monitoring thresholds.

Failure to comply with these obligations may result in the suspension or permanent closure of the player's account, the withholding of funds pending investigation, and, where appropriate, reporting to relevant law enforcement or regulatory authorities.

13. Account Closure and Refusal of Service

The Company reserves the right, at its sole discretion, to:

• Decline to open an account for any applicant who fails to satisfy KYC requirements;
• Suspend or permanently close any existing account where KYC or EDD requirements are not met, or where suspicious activity is identified;
• Withhold or freeze funds in any account pending the resolution of an AML or KYC investigation;
• Refuse to process any deposit or withdrawal where the Company has reasonable grounds to suspect that it may be connected to money laundering, terrorist financing, or other financial crime.

Where an account is closed for AML or KYC reasons, the Company will deal with any funds held in the account in accordance with its legal obligations and, where applicable, the instructions of the relevant authority.

14. Responsible Gaming and Financial Safety

luckygem-cassino.com recognises that responsible gaming and financial crime prevention are interconnected. Problem gambling behaviour — including chasing losses with escalating deposits — can itself be a vulnerability exploited by money launderers or may indicate that a player is using funds they cannot afford. Our responsible gaming tools, including deposit limits, session limits, and self-exclusion options, form part of our broader commitment to player safety and financial integrity. Players are encouraged to contact our support team at any time if they have concerns about their own gambling behaviour. Our support team is available 24 hours a day, seven days a week via live chat and at [email protected].

15. Contact and Complaints

If you have a question about this Policy, wish to submit KYC documentation, or wish to raise a concern about a compliance matter, please contact the luckygem compliance team using the details below:

• Email: [email protected]
• Live Chat: Available 24/7 via luckygem-cassino.com

The Company will aim to acknowledge compliance-related enquiries within one business day and to resolve them as promptly as the nature of the matter allows.

16. Policy Review and Updates

This Policy is reviewed at least annually by the Company's compliance officer, and is updated whenever changes in applicable law, regulatory guidance, or the Company's operational practices require it. The current version of this Policy is always available on luckygem-cassino.com. Players are encouraged to check this page periodically. Continued use of luckygem-cassino.com following the publication of an updated Policy constitutes acceptance of the revised terms.

This Policy was last reviewed and updated in 2026. Virtual Connect Sociedad de Responsabilidad Limitada — luckygem-cassino.com.