OBJECTIVE AND SCOPE OF THE POLICY

The purpose of this AML & KYC Policy or Policy on The Prevention of Laundering Proceeds of Crime and Financing of Terrorism and Know your Customer procedures is:

1. To obtain information and develop employee awareness on the prevention of laundering proceeds of crime and financing of terrorism,
2. To comply with the obligations regarding local regulations and EU AML Directives and regulations (including, but not limited to AML Directive 4 and AML Directive 5) ,
3. To evaluate customers, transactions and services offered with a risk based approach and to mitigate those risks.

It is the policy of the Company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the financing of terrorist or any other criminal activities. Company is committed to comply with applicable requirements and regulations. The Company’s AML/CFT/KYC Policy, relevant procedures and internal controls will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

GUARANTEE

1. All Users of Luckynova.com Website ensure by accepting this Policy and Terms & Conditions at least the following:
   • The User has completed the registration form truthfully and correctly.
   • The User is not an individual under 18 years old or other legal age of majority in User's jurisdiction.
   • The User has registered personally and not on the behalf of someone else.
   • The User uses the account for personal use and has no commercial intentions.
   • The User has no knowledge about any bet result of the underlying bet before placing it.
   • The User does not have multiple accounts on luckynova.com website.
   • The User has read and accepted this Policy.
   • The User cannot sell, transfer, assign and/or acquire by any other means the accounts to/from other Users.
   • The User assures that he/she won’t use his/her account to transfer funds amongst his/her accounts

KNOW YOUR CUSTOMER (KYC) PROCEDURES

Both international and local regulations require Luckynova to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

One of the international standards for preventing illegal activity is customer due diligence (KYC). According to KYC, Luckynova hereby establishes its verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

Verification procedures consists of 2 steps:

a)Initial identification

Players are required to complete the registration process in order to perform any deposits or withdrawals.

1. During the registration process, the following information is required to complete the registration:
   • First name
   • Last name
   • Email address
   • Username
   • Permanent Residential Address
   • Identity reference number, where available
   • Country
   • Nationality (optionally)
   • Place and Date of Birth
   • Confirmation that the User is not a PEP (politically exposed person) and agree to KYC procedure
   • Acceptance of the Terms and Conditions and Privacy Policy
   • Consent to receive promo mails and offers (optionally)

The system will not allow players under 18 years of age to register or deposit. Upon depositing at least in amount of EUR 150, Luckynova will be collecting passport/ID card from the end user.

If User uses Bank id or other reliable methods for registration Luckynova reserves the right not to collect user’s passport / ID CARD when the player deposits in amount of EUR 150.

Luckynova reserves the right to collect the passport/ID card from the end user in case of deposits lower EUR 2000 when the user requests to withdraw the funds irrespective of the amount of such withdrawal.

b)Additional verification procedure

Luckynova identity verification procedure requires the User to provide Luckynova with reliable, independent source documents, data or information (e.g., national ID, international passport, driving license, bank statement, utility bill)

• i) in case of a first withdrawal for the sum equal to or exceeding 2000 euros or its equivalent;
• ii) in case of a deposit for the sum equal to or exceeding 2000 euros or its equivalent;
• iii) in case of depositing or withdrawing in amount of 2000 euros (or its equivalent) or more (cumulative, by several installments) by the same User.

The value of cumulative transactions will be calculated on a daily basis, taking into account all deposits/withdrawals effected by User since the establishment of the business relationship.

Luckynova can conduct the verification process by obtaining player’s information or documents for the KYC procedure from reliable sources such as banks or payment systems, such as Trustly Pay’n’Play service.

Please note that Luckynova can request you to undergo additional verification procedure under the present Policy before your first deposit that is lower than 2000 euros or its equivalent if such requirement is essential for processing payments through certain payment providers/institutions/banks.

We also acknowledge you that in view of the latest AML requirements targeted anonymous purchases and exchanges including virtual currencies and prepaid cards, the monthly transaction limit on prepaid cards was gone down to €150 to combat their use in criminal transactions and terrorist financing. It means that cards with higher limits shall undergo additional verification procedure and AML check in accordance with this Policy.

Luckynova also sets up a turnover limit of 50 000 EUR per month for additional verification procedure or EDD (Enhanced Due Diligence). We conduct aforementioned checks for every User and in any cases as soon as the User's turnover per month reaches 50k EUR.

During additional verification procedure an individual User provides the following identification information to Luckynova:

1. a high resolution scanned copy or photo of pages of an unexpired government-issued document containing photographic evidence of identity such as:
   • a valid unexpired passport or
   • a valid unexpired national or other government-issued identity card or
   • a valid unexpired residence card or
   • a valid unexpired driving license.
2. A clear and high resolution photo of the User or his/her selfie
3. a high resolution electronic copy of a document not older than 6 months, verifying the residential address and the full name of the customer. Either one of the electronic copies of documents listed below will suffice:
   • a recent statement or reference letter issued by a recognized credit institution;
   • a recent utility bill issued in relation to a fixed line telephone service at the customer’s residential address;
   • correspondence from a central or local government authority, department or agency;
   • a record of a visit to the address by a senior official of the subject person;
   • any identification document listed above, where a clear indication of residential address is provided;
   • an official conduct certificate;
   • any other government-issued document not mentioned above; or
   • any other document as may be specified in sectoral implementing procedures issued by the FIAU.

All mentioned documents shall be clearly dated and cannot be accepted by Luckynova if the date cannot be seen and checked easily.

Luckynova will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Luckynova reserves the right to investigate certain Users who have been determined to be risky or suspicious as stated at the present Policy below

c)Verification ad hoc

Luckynova reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past in suspicious cases or if the User can be considered as a High or Medium Risk User or/and originates from the high risk third-party countries which defined by European Commission as "jurisdictions having strategic deficiencies in their regime on anti-money laundering and countering terrorist financing” (in order to see the list, please follow the linkhttps://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R1675-20201001,https://ec.europa.eu/commission/presscorner/detail/en/IP_19_781)

With regard to High and Medium Risk Users or/and if there’s strong grounds to believe that there’s risk of commitment of fraud, money-laundering or any abuse on the part of the User Luckynova can request the User to provide (by email or via chart, not automatically) with another high-resolution electronic copy of a clearly dated document verifying his/her identification details (this document must be different from the document already obtained for the purposes of fulfilling the requirement of additional verification and shall contain the following User’s data:

1. Official full name;
2. Place and date of birth;
3. Permanent residential address;
4. Identify reference number, where available, and
5. Nationality

The User is obliged to collaborate with regard to the AML/ KYC check and to provide any information and document deemed necessary by Luckynova.

During additional verification procedure and ad hoc check, the User cannot withdraw his/her funds until he/she provides all necessary documents. In case the User does not provide the documents in the requested form and any other information requested within 30 days from the day of request to satisfy the AML/KYC check, Luckynova may deny the User’s withdrawal or “freeze” the account of the User for playing (in case of KYC check during depositing) until such document or information is provided.

Luckynova will make all reasonable efforts to prevent players from restricted countries mentioned at p. 2.5 of Terms & Conditions to reach the games.

In case the automatic procedures fail, Luckynova shall contact the User by email or other means to obtain the information and documents needed. In case the User does not provide the documents in the requested form and any other information requested within 30 days from the day of request to satisfy the AML/KYC check, Luckynova may deny the User’s withdrawal or “freeze” the account of the User for playing (in case of KYC check during depositing) until such document or information is provided.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Luckynova Privacy Policy and related regulations including European Data Protection Regulations.

Luckynova uses outside services to carry out KYC check and comply with legislative rules and standards of such procedure. For such purposes there’s a written agreement with SUM AND SUBSTANCE LTD to carry out KYC check of the Users on its part as a processor of personal data of its Users.

SUM AND SUBSTANCE LTD as well as Luckynova guarantees that all personal data of the Users received during KYC check of such Users are kept safely and securely and can be processed only in compliance with rules of GDPR and Privacy Policy.

Luckynova or partners on behalf of Luckynova (third party providers) check all users during KYC process against following sanctions list (it can be changed without additional notifications):

1. • Pakistan Public Procurement Regulatory Authority Blacklisted
   • Firm s Pakistan
   • Israel Bar Association Suspended and Removed Lawyers - NEW Israel
   • Canada Chartered Professional Accountant of Ontario Canada
   • Canada Law Society Tribunal Canada
   • Canadian Securities Commission Part 2 Canada
   • Canadian Securities Commission Part 3 Canada
   • Canadian Securities Commission Part 4 Canada
   • Canadian Securities Commission Part 5 Canada
   • Insurance Council of Manitoba Disciplinary Decisions Canada
   • Mutual Fund Dealers Association of Canada Enforcement
   • Hearings Canada
   • The Manitoba Securities Commission ( Suspended) Canada
   • Canada Public Works and Government Services Canada
   • Ineligible and suspended suppliers CanadaMexico - National Banking Securities Commission Mexico
   • Mexico Comision Nacional Bancaria De Valores Sanctions Mexico
   • Entity List (EL) - US Bureau of Industry and Security United States
   • Federal Deposit Insurance Corporation Failed Bank List United States
   • Fitness Probity US Medicaid Exclusions Lists OIG LEIE United States
   • Florida Agency for Healthcare Admin Medicaid Sanctioned
   • Providers United States
   • SEC Trading Suspensions United States
   • United States Department of Justice Executive Office for
   • Immigration Review Disciplined Practitioners United States
   • 19 United States FDIC Prohibition under Section 19 United States
   • United States Federal Reserve Section 19 Letters United States
   • United States System for Award Management Exclusions excl
   • OFAC United States
   • US Alabama Medicaid Suspended Providers United States
   • US Arkansas Department of Health Excluded Providers List United States
   • US Connecticut Department of Social Services Administrative
   • Actions List United States
   • US Consumer Financial Protection Bureau United States
   • US Excluded or Terminated Montana Medicaid Providers United States
   • US FDA Clinical Investigators Disqualification Proceedings List United States
   • US FDA Debarment List Enforcement Actions Drug Product
   • Applications United States
   • US Georgia Bureau of Investigation United States
   • US Georgia OIG Exclusions List United States
   • US Hawaii Medicaid Excluded Providers United States
   • US KY Medicaid Termination and Exclusion List United States
   • US Louisiana Department of Health Hospitals Exclusion List United States
   • US Maine Medicaid Exclusion List United States
   • US Maryland Dept of Health Mental Hygiene Exclusions List United States
   • US Massachusetts Health and Human Services List of
   • Suspended or Excluded MassHealth Providers United States
   • US Michigan Department of Community Health List of
   • Sanctioned Providers United States
   • US Minnesota Department of Human Services Excluded Provider
   • Lists United States
   • US Mississippi Gaming Commission Exclusion List United States
   • US Missouri Department of Social Services Medicaid List of
   • Terminated Providers United States
   • US Nevada Gaming Control Board Excluded United States
   • US Nevada GCB Most Wanted United States
   • US New Jersey Office of the State Comptroller Consolidated
   • Debarment Report United States
   • US New York Office of the Medicaid Inspector General List of
   • Exclusions United States
   • US OCC Enforcement Actions List Archive til 2011 United States
   • US State Department AECA Debarments United States
   • US-Chicago Board Options Exchange DIsciplinary United States
   • US-Nasdaq Trader PHLX Disciplinary Actions United States
   • US-NYSE Regulation: Disciplinary Actions United States
   • United States Military Health System Excluded Providers
   • Organisation United States
   • United States Military Health System Excluded Providers Person United States
   • United States Federal Housing Finance Agency Suspended
   • Counterparty Program Person United States
   • United States Federal Housing Finance Agency Suspended
   • Counterparty Program Organisation United States
   • United States Federal Trade Commission Entities Banned from
   • Debt Relief United States
   • Canada Canadian Institute of Chartered Accountants Ontario
   • Disciplined Accountants Decisions Canada
   • ASIC Disqualified Organisations Australia
   • Australia ARPA Disqualifications Australia
   • Australia ASIC Notices Australia
   • Australia Disqualified Officers Australia
   • Fitness Probity Australia APRA Disqualification Register Australia
   • Australia Office of the Registrar of Indigenous Corporations
   • Disqualified Directors Australia
   • New Zealand FMA Management Bans New Zealand
   • New Zealand Serious Fraud Office New Zealand
   • Brazil Banco Central Disqualifications Brazil
   • Brazil Comptroller General Leniency Agreements Brazil
   • Chile Unidad de Análisis Financiero Chile
   • Colombia Financial Superintendence Colombia
   • Paraguay National Directorate of Public Procurement Penalties and Disqualifications

ADDITIONAL DUE DILIGENCE MEASURES FOR PARTNERS, CONTRACTORS

Company must undertake following additional due diligence measures while establishing and maintaining correspondent relationships with partners or contractors:

1. Obtaining sufficient information about a respondent institution to avoid any relationships with “shell-companies”;
2. Determining from publicly available sources of information the reputation of a respondent institution, including whether it has been subject to a money laundering or terrorist financing investigation or other regulatory action;
3. Assessing the respondent institution’s anti-money laundering and terrorist financing controls on the periodic basis;

ANTI-FRAUD AND MONEY-LAUNDERING PREVENTION GUIDELINES

Luckynova declares that it is unlawful to deposit money from ill-gotten means and fraud will not be tolerated. Any suspicious activity will be investigated and knowing our customer is of vital importance, all strategies implemented to identify our customer are aimed at ensuring a level playing field and maximum fraud prevention.

Luckynova undertakes to cooperate with competent authorities and organizations to enable its compliance with recent EU Regulation (including, but not limited to AML Directive 4 and AML Directive 5).

All transactions shall be checked in order to prevent money laundering. Luckynova shall report any suspicious transactions to the relevant competent authorities in Malta. If Luckynova becomes aware of any suspicious activity relating to any of the Games of the Website, Luckynova must report this to the Authority immediately. Luckynova may suspend, block or close an Account and withhold funds if requested to do so in accordance with the Prevention of Money Laundering Act.

Luckynova’s obligations towards responsible gaming and AML legislation trump commercial conditions.

ACTIVITIES THAT LUCKYNOVA CONSIDERS POSSIBLE INDICATIONS OF MONEY LAUNDERING INCLUDE:

1. • The User showing unusual apprehension or reservations about Luckynova’s anti-money laundering policies.
   • The User’s interest in conducting financial transactions which are contrary to good business sense or are inconsistent with the User’s business policy.
   • The User failing to provide the proof of legitimate sources for their funds.
   • The User providing false information regarding the source of their funds.
   • The User having a history of being the subject of news that is indicative of civil or criminal violations.
   • The User seems to be acting as a ‘front man’ for an unrevealed person or business, and does not satisfactorily respond to requests for identifying this person or business.
   • The User not able to easily describe the nature of his/her activities.
   • The User maintains multiple accounts and conducts an unusually high number of inter-account or 3rd party transactions.
   • The User’s previously usually inactive account starts receiving a surge of wire activity
   • User deposits considerable amounts during a single session by means of multiple prepaid cards
   • User makes small wagers even though he has significant amounts deposited, followed by a request to withdraw well in excess of any winnings
   • User makes frequent deposits and withdrawal requests without any reasonable explanation
   • User enquires about the possibility of moving funds between accounts belonging to the same gaming group
   • User carries out transactions which seem to be disproportionate to his/her wealth, known income or financial situation
   • User seeks to transfer funds to the account of another customer or to a bank account held in the name of a third party
   • User displays suspicious behaviour in playing games that are considered as high risk.
   • Client participates in any type of collusion with other Users;
   • Client developed and used strategies aimed at obtaining unfair winnings;
   • Client committed fraudulent actions against Luckynova or its payment providers;
   • Client used third party software or analysis systems;
   • Client was engaged in creating of two or more accounts, using unfair external factors or influences.

The above list is by no means an exhaustive list. Luckynova monitors its User and account activity in light of several other red flags and takes appropriate measures to prevent money- laundering.

MONITORING AND REPORTING OF SUSPICIOUS TRANSACTIONS/ACTIVITY

1. All personnel must be diligent in monitoring for any unusual or suspicious transactions/activity basing on the relevant criteria applicable in the jurisdiction where the Company operates;
2. The reporting of suspicious transactions/activity must comply with the laws/regulations of the respective jurisdiction;
3. MLRO must be informed about all suspicious transaction/activity on a monthly basis;
4. Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
5. Establishing procedures for reporting suspicious and/or fraudulent use of identification documents to relevant law enforcement authorities and dedicated regulators as appropriate;
6. Establishing procedures for reporting suspicious activity internally and to relevant law enforcement authorities as appropriate;

RECORD KEEPING

1. Records must be kept of all documents obtained for the purpose of identification and all transaction data as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations;
2. All records must be kept for at least for 6 years;
3. In case a User account is closed, related information about the account is saved for six (6) year from the time the account is closed and ten (10) years in case of suspicion of or proved fraudulent or money-laundering actions on the part of User. Such retention is made through our Data Processor account. Related information includes User name, address, phone, email and account transactional details.

MLRO

The Money-Laundering Officer (MLRO) is the person, duly authorized by Luckynova, whose duties are to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the MLRO’s responsibility to supervise all aspects of Luckynova anti-money laundering and counter-terrorist financing, including but not limited to:

• Collecting necessary Users’ identification information
• Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable AML laws and regulations.
• Monitoring transactions and investigating any significant deviations from normal activity.
• Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
• Updating risk assessment regularly.
• Providing law enforcement with information as required under the AML applicable laws and regulations.

The Money-Laundering Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

TRAINING

1. Training on anti-money laundering must be provided to those new employees who work directly with customers and to those employees who work in other areas that may be exposed to money laundering and terrorist financing threats;
2. Follow-up trainings must take place not less than once a year
3. Training and awareness for all dedicated employees and contractors;