This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Virtual Connect Sociedad de Responsabilidad Limitada, the operator of luckygem casino at luckysgem.org, and the responsibilities of all players using the platform. luckygem is committed to preventing money laundering, terrorist financing and financial crime. This Policy applies to every player account, every transaction and every interaction on luckysgem.org.

1. Operator Details and Legal Basis

luckygem casino is owned and operated by Virtual Connect Sociedad de Responsabilidad Limitada and is accessible at luckysgem.org. The platform holds a Costa Rica gaming licence. Although Costa Rica does not mandate a prescriptive AML statute equivalent to those of EU-regulated jurisdictions, Virtual Connect Sociedad de Responsabilidad Limitada voluntarily adopts internationally recognised AML and KYC standards consistent with the Financial Action Task Force (FATF) Recommendations and general best practice in the online gaming industry. This Policy is binding on all players, regardless of their country of residence, who access luckysgem.org.

2. Purpose and Scope

The purpose of this Policy is to:

• Detect, prevent and report attempts to use luckysgem.org for money laundering or terrorist financing;
• Verify the identity of all players before processing withdrawals and, where risk warrants it, before accepting deposits;
• Maintain accurate and complete records of player identities, transactions and any suspicious activity;
• Ensure that luckygem's payment infrastructure — spanning bank transfers (ING, Rabobank, ABN AMRO, SNS Bank, ASN Bank, N26), Revolut, Apple Pay, Visa, Mastercard and cryptocurrency — is not exploited for illicit purposes;
• Protect luckygem, its players and the wider financial system from financial crime.

This Policy applies to all accounts registered at luckysgem.org, all deposits and withdrawals processed through the platform, all bonus and rakeback credits, and all customer support and compliance interactions.

3. Definition of Money Laundering

For the purposes of this Policy, money laundering is understood as any act or attempted act to conceal, disguise, convert or transfer funds that are derived from criminal activity, or to assist any person involved in such activity to evade the legal consequences thereof. The three classic stages are:

• Placement: Introducing criminal proceeds into the financial system, including through online casino deposits;
• Layering: Conducting multiple transactions to obscure the origin of funds, such as repeated deposits and withdrawals, account-to-account transfers or currency conversions;
• Integration: Returning laundered funds to the criminal as apparently legitimate income.

Terrorist financing — providing or collecting funds with the intention or knowledge that they will be used to carry out a terrorist act — is treated with equal seriousness and is subject to the same controls as money laundering under this Policy.

4. Know Your Customer (KYC) — Overview

luckygem applies a risk-based KYC framework. Every player must successfully complete identity verification before their first withdrawal is approved. Verification may also be triggered at any earlier point — including after registration or during a deposit sequence — if the player's activity, transaction size or risk profile warrants it. luckygem reserves the right to suspend account activity, including access to the 10% rakeback balance and any bonus funds, until KYC is satisfactorily completed.

5. KYC Trigger Events

A full KYC review is mandatory in any of the following circumstances:

• The player's first withdrawal request, irrespective of amount (minimum withdrawal on luckysgem.org is €40);
• Cumulative deposits reaching an internal threshold that indicates elevated risk;
• Any single transaction or pattern of transactions that appears unusual or inconsistent with the player's stated profile;
• A player reaching a higher VIP tier (from Saffieren Meester, levels 11–15, upward) where withdrawal limits increase significantly;
• A progressive jackpot win or any win that triggers full lump-sum payment above €10,000, which is paid in full outside the standard monthly cap;
• A request to change account details such as name, address or payment method;
• Grounds for suspicion of fraudulent activity, bonus abuse or multi-accounting;
• Any request from a regulatory authority or law enforcement agency.

6. Required KYC Documents

When a KYC review is initiated, the player will be asked to provide some or all of the following documents. All documents must be valid, legible and unaltered.

6.1 Proof of Identity

• A government-issued photo ID such as a national identity card, passport or driving licence;
• The document must clearly show the player's full legal name, date of birth, photograph and document number;
• The document must not be expired.

6.2 Proof of Address

• A utility bill, bank statement or official government letter issued within the last three months;
• The document must display the player's full name and residential address as registered on their luckygem account.

6.3 Proof of Payment Method

• For bank accounts (ING, Rabobank, ABN AMRO, SNS Bank, ASN Bank, N26, Revolut): a screenshot or copy of the account statement or the account detail screen confirming the account holder's name and account number;
• For cards (Visa, Mastercard): a photograph of the card showing the cardholder's name, the last four digits and the expiry date — the full card number and CVV must be obscured;
• For Apple Pay: confirmation of the linked bank account or card, as appropriate;
• For cryptocurrency: the wallet address used for the deposit transaction.

6.4 Source of Funds and Source of Wealth

Where a player's deposits, withdrawal requests or overall wagering activity suggest that the amounts involved are material relative to a typical personal income, luckygem may request evidence of source of funds or source of wealth. Acceptable documentation includes, but is not limited to:

• Recent payslips or employment contract;
• Bank statements covering a relevant period;
• Evidence of business ownership, investment income or inheritance;
• Tax return or assessment notice.

Providing source-of-funds documentation does not guarantee that a withdrawal will be approved if other concerns remain outstanding.

7. Document Submission Process

Players can submit KYC documents by:

• Uploading them directly through the verification section of their luckysgem.org account portal; or
• Sending them by e-mail to [email protected].

The compliance team reviews submitted documents as promptly as possible. Players are encouraged to submit clear, high-resolution scans or photographs. Blurred, cropped or otherwise unreadable images will be rejected and the player will be asked to resubmit. luckygem aims to confirm the outcome of a standard KYC review within the same timeframe as its two-banking-day withdrawal processing window, though complex cases may require additional time. Withdrawal processing will not commence until KYC is fully approved.

8. Withdrawal Policy in the Context of KYC

The following withdrawal rules interact directly with luckygem's KYC obligations:

Players whose VIP tier entitles them to elevated or unlimited daily withdrawal limits will be subject to enhanced KYC and ongoing monitoring commensurate with the higher transaction volumes involved. luckygem may request additional source-of-funds documentation before approving withdrawals above standard thresholds.

9. Anti-Money Laundering Controls

9.1 Transaction Monitoring

luckygem monitors all transactions — deposits, withdrawals, rakeback credits and bonus activity — on an ongoing basis. Automated and manual controls are in place to flag patterns that may indicate money laundering, including but not limited to:

• Rapid deposit and withdrawal sequences with minimal or no gameplay;
• Structured deposits designed to remain below internal reporting thresholds;
• Multiple payment methods used to fund a single account;
• Frequent changes to payment details or account information;
• Deposits significantly exceeding the player's declared income or apparent financial profile;
• Use of third-party payment methods not registered in the player's own name;
• Cryptocurrency transactions linked to high-risk wallet addresses or mixing services.

9.2 Politically Exposed Persons (PEPs)

luckygem applies enhanced due diligence to players who are identified as Politically Exposed Persons — individuals who hold or have held prominent public functions — as well as their immediate family members and known close associates. PEPs are subject to senior management approval before an account relationship is established or continued, and are monitored on an ongoing basis throughout their time as a player.

9.3 Sanctions Screening

Player names, nationalities and payment details are screened against applicable international sanctions lists, including those published by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN). Any match will result in the immediate freezing of the account and funds pending further investigation and, where required, reporting to the relevant authority.

9.4 Prohibited Practices

The following are strictly prohibited on luckysgem.org and will result in account suspension, forfeiture of funds and reporting to relevant authorities where appropriate:

• Depositing funds on behalf of a third party;
• Allowing a third party to use your account or payment credentials;
• Using a payment method not registered in your own name;
• Creating multiple accounts to circumvent KYC requirements or withdrawal limits;
• Attempting to use luckysgem.org as a mechanism to convert illicit funds into apparently legitimate winnings;
• Providing false, altered or forged documentation during KYC.

10. Record-Keeping

luckygem retains all KYC documentation, transaction records and account activity logs for a minimum period consistent with applicable legal and regulatory requirements and standard industry practice. Records include, but are not limited to:

• Copies of all identity and address verification documents submitted;
• Full transaction histories, including dates, amounts, methods and balances;
• Records of any suspicious activity identified and action taken;
• Correspondence related to KYC reviews and compliance investigations.

These records are stored securely and are accessible to the compliance team and, upon lawful request, to competent authorities.

11. Suspicious Activity Reporting

Where luckygem's compliance team identifies or reasonably suspects that a player is engaged in money laundering, terrorist financing or any related financial crime, luckygem will:

• Suspend account activity immediately, including the processing of deposits and withdrawals;
• Preserve all relevant records and documentation;
• File a Suspicious Activity Report (SAR) or equivalent disclosure with the competent authority in the relevant jurisdiction;
• Refrain from alerting the player to the fact that a report has been made ("tipping-off" is prohibited).

luckygem will cooperate fully with any subsequent investigation by law enforcement or regulatory authorities.

12. Player Responsibilities

By creating an account at luckysgem.org, each player agrees to:

• Provide truthful, accurate and complete information at registration and throughout the account relationship;
• Submit valid KYC documents promptly when requested;
• Notify luckygem immediately of any changes to personal information, including name, address or payment details;
• Use only payment methods registered in their own name;
• Ensure that all funds deposited at luckysgem.org originate from a legitimate and verifiable source;
• Not engage in any practice designed to circumvent the controls set out in this Policy.

Failure to comply with any of the above may result in account restriction, suspension or permanent closure, forfeiture of pending withdrawals and, where evidence of criminal conduct exists, referral to law enforcement.

13. Account Closure and Fund Confiscation

luckygem reserves the right to close any account and withhold or void funds where:

• KYC documentation is not provided within a reasonable time following a request;
• Documents provided are found to be fraudulent, altered or otherwise invalid;
• The player is identified on a sanctions list;
• There is reasonable suspicion of money laundering, terrorist financing or fraud;
• The player breaches any other term of this Policy or the general Terms and Conditions of luckysgem.org.

Where funds are withheld pending investigation, luckygem will act in accordance with its legal obligations, which may include transferring funds to a relevant authority.

14. Responsible Gambling and AML Intersection

luckygem recognises that problem gambling and financial crime can overlap — for example, where a player deposits funds disproportionate to their means, or where unusual deposit and withdrawal patterns may indicate that an account is being used other than for genuine recreational play. Where a player's financial activity raises concerns under both this Policy and luckygem's responsible gambling framework, both sets of controls will be applied concurrently. Players who need support with gambling-related concerns are encouraged to contact the support team at [email protected] or to use the responsible gambling tools available within their account.

15. Amendments to This Policy

Virtual Connect Sociedad de Responsabilidad Limitada reserves the right to amend, update or replace this Policy at any time. Material changes will be communicated to players via the luckysgem.org website. Continued use of the platform following the publication of any updated Policy constitutes acceptance of the revised terms. Players are encouraged to review this page periodically.

16. Contact

Any questions relating to this AML / KYC Policy, or any concerns about account verification, should be directed to the luckygem compliance and support team:

• E-mail: [email protected]
• Live chat: Available 24/7 via luckysgem.org

luckygem takes its obligations under this Policy seriously and aims to handle all compliance matters with professionalism, confidentiality and minimum delay.