AML / KYC Policy

1. Purpose and Scope

This Anti-Money-Laundering and Know-Your-Customer Policy ("AML/KYC Policy") sets out the measures Lottorbit takes to prevent money laundering, terrorist financing, fraud and other financial crime. It applies to every user, account and transaction on the Platform. By registering and using the Platform you agree to comply with this policy, including providing accurate identification and source-of-funds information when requested.

The Platform is licensed and regulated by the Tobique Gaming Commission and complies with applicable AML laws and regulations.

2. Customer Due Diligence (CDD)

We perform risk-based Customer Due Diligence on every user before allowing deposits, play and withdrawals. This includes:

• Identity verification: full legal name, date of birth and address.
• Contact verification: email address and phone number ownership.
• Documentary KYC: government-issued photo identification and proof of address.
• Enhanced Due Diligence (EDD): additional screening for higher-risk users, jurisdictions or transaction patterns.

3. Sanctions and PEP Screening

We screen every applicant against applicable sanctions lists, watchlists and Politically Exposed Persons (PEP) registries before account activation, and we re-screen periodically. Accounts linked to sanctioned individuals or entities are blocked and reported to the relevant authority where required.

4. Source of Funds and Source of Wealth

For larger deposits, withdrawals or where a higher risk is identified, we may request evidence of the source of funds and, where relevant, the source of wealth. Acceptable evidence may include payslips, bank statements, sale agreements or other documentation. We will only process transactions where the source of funds is reasonably explained and lawful.

5. Transaction Monitoring

The Platform monitors transactions in real time for patterns that may indicate money laundering or suspicious activity. Examples include, without limitation:

• Structuring deposits or withdrawals to avoid reporting thresholds.
• Deposits followed rapidly by withdrawals with little or no play.
• Activity inconsistent with a user's known profile or expected behavior.
• Use of multiple accounts by the same individual.

Where suspicious activity is detected, the Platform may suspend the account, freeze associated funds and file a Suspicious Activity Report (SAR) with the relevant authority.

6. Reporting and Record Keeping

We maintain records of identity verification, transactions and AML decisions for the minimum period required by applicable law (typically at least five years from the end of the customer relationship or the date of the transaction). These records are available to competent authorities on request.

7. Responsible Gaming and Account Restrictions

Our AML/KYC controls work alongside our Responsible Gaming tools. Where a user is identified as vulnerable or self-excludes, the Platform applies account-level restrictions in line with our Responsible Gaming Policy. Self-excluded users may not create new accounts, and we may share exclusion data across accounts to enforce this.

8. What This Means for You

• You may be asked to provide identity and source-of-funds documents at any time.
• Deposits and withdrawals may be delayed while verification is completed.
• The Platform may refuse, block or reverse a transaction to comply with AML law.
• Providing false or misleading information is a serious violation and may result in account closure, forfeiture of funds and reporting to authorities.

9. Contact Us

For any questions about this AML/KYC Policy, contact our compliance team via the Help Center.

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