AML Policy

1. Introduction

3-102-940062 SRL (“LuckyAnon” or the “Company”) is a Costa Rican company with its registered office located at Provincia de Puntarenas 06, Canton 11, Garabito, Jaco, 61101, Costa Rica. It operates the online casino www.luckyanon.com under gaming license issued by the Anjoan Gaming Authority.

This policy (the “AML Policy”) sets out LuckyAnon's approach to preventing and countering Money Laundering (“ML”) and Terrorist Financing (“TF”). In developing this policy, LuckyAnon has considered international AML and Countering the Financing of Terrorism (“CFT”) standards and best practices for the gaming sector.

LuckyAnon acknowledges that its products and services are at risk from individuals or groups seeking to launder criminal proceeds or facilitate funds designated for the financing of terrorism. As such, LuckyAnon is committed to fostering and promoting a compliance culture throughout the company which highlights the importance of preventing ML and TF.

2. Policy Statement and Objectives

LuckyAnon prohibits the use of its products and services for any form of illicit activity, including ML, TF and sanctions violations, and is committed to following global best practices in guarding against such use. Those best practices include:

• Adopting a written policy, and procedures and controls, reasonably designed to guard against ML, TF and sanctions violations;
• Designating a compliance officer to oversee the implementation of the policy, procedures and controls;
• Providing appropriate education and training to relevant personnel; and
• Conducting independent reviews, monitoring and maintenance of the policy, procedures and controls.

The objectives of this AML Policy are to set out the main procedures, systems, and controls LuckyAnon has implemented to follow the above best practices, and in particular to prevent and detect ML and TF.

3. Chief Compliance Officer

LuckyAnon has appointed a Chief Compliance Officer (“CCO”), who is responsible for coordinating the implementation of the AML Policy. The CCO's duties also include developing AML initiatives, working with other stakeholders to revise the AML policy, assessing new regulatory requirements and investigating and reporting potentially suspicious or unusual activity.

The CCO has an independent and direct reporting line to the Board, and will act on his/her own authority. The CCO will be authorized to submit suspicious transaction reports (“STRs”) to the relevant Financial Intelligence Unit without requiring approval to do so.

4. Responsibility of Employees, Directors and Officers

All of LuckyAnon's employees, directors and officers, regardless of their position, are required to comply with this policy, and have a duty to be aware of the need to prevent ML and TF. Should they have reason to believe or suspect that any transaction, or potential transaction, could involve the proceeds of criminal conduct, they must report this to the CCO without delay. Failure to do so may result in disciplinary action.

As the business grows and the number of employees increases, LuckyAnon will ensure that employees are trained to identify and report suspicious activity. LuckyAnon will provide AML training to its employees on a regular basis.

5. Automated Monitoring and Technical Solutions

LuckyAnon employs a range of automated monitoring systems and technical solutions to detect and prevent money laundering while respecting user privacy. Our approach prioritizes technological solutions over intrusive documentation requirements where possible.

6. Know-Your-Customer Measures

While LuckyAnon prioritizes automated technical measures, in some cases basic KYC measures may be necessary:

• Risk-Based Verification: Documentation is only requested based on risk triggers from our automated systems
• Tiered Approach: Documentation requirements scale with risk level and transaction volume
• Privacy-Focused: Only collecting the minimum information necessary to meet compliance obligations

7. Reporting

If a customer is identified as being on a sanctions list, or linked to ML or TF or other criminal activities, LuckyAnon will make an appropriate report to the relevant Financial Intelligence Unit.

8. Compliance Review and Improvement

LuckyAnon regularly reviews and enhances its technical solutions and monitoring systems to:

• Adapt to new money laundering techniques
• Incorporate advancements in blockchain analytics
• Reduce false positives that might impact legitimate users
• Ensure compliance with evolving regulatory standards

This policy will be reviewed and updated as necessary to maintain effectiveness while balancing regulatory compliance with user experience.