AML/CFT/KYC POLICY

Lotozal is committed to have procedures in place for the prevention of the misuse of its services provided to account holders for money laundering, terrorism financing, fraud and other criminal purposes. This policy is written based on the international standards set by the FATF and the national legislation on AML. Combined these regulations provide a solid, internationally accepted standard for the procedures maintained for the prevention of the misuse of the services provided by the Company. Proper identification of account holders, verification of the identity, monitoring of player activities and reporting of suspicious activities are part of the measures the company has in place in an effort to mitigate industry related risks. The company is committed to the highest national and international AML and FATF standards when providing its services and requires management and employees to follow these standards.

Procedures

In an effort to be compliant with the applicable rules, regulations and international standards, the Company has procedures in place to which it attains itself to when providing services to account holders. These procedures include:

• Know Your Client;
• Monitoring of player activities;
• Risk management;
• Reporting of unusual transactions;
• Recordkeeping.

1. Know your client procedure

By agreeing to these Terms, you authorize the Company to regularly conduct various checks at the Company’s sole discretion or if required by third parties (including regulatory agencies), in order to verify your identity and contact information ("Verification").

An individual cannot participate in a game for money unless that individual is an account holder. To be registered as a player, an individual must register personally and submit an application for registration. The following information must be provided:

• date of birth together with valid identification showing that he/ she is over eighteen (18) years of age or the applicable legal age of majority as stipulated in the jurisdiction of your residence. Identification documents which must be submitted include: copy of a valid Passport, copy of other identification paper and a proof of address;
• player’s first and last name;
• player’s full residential address;
• player’s valid email address;
• a username and a password. The Company reserves the right to request additional documentation and perform additional checks in order to verify the information provided. An account may be suspended until satisfactory information is provided.

The Company reserves the right to suspend your account, if we are unable to ascertain that you have reached the Eligible Age. If, while using the Website services associated with gambling, you were below the Eligible Age:

• your account will be closed;
• all transactions made during this period of time will be annulled, and the money deposited to your account will be returned;
• all your bets made during this period of time will be cancelled and refunded;
• all your winnings accumulated during the period of time when your age was under the Eligible Age will be lost, and you will have to refund the Company with all the amounts withdrawn from your account at the Company’s request;
• a deposit made to your account will not be refunded due to Company policy violation. In the event that the information provided by you proves to be false, incomplete, inaccurate or misleading, and also if the information specified during registration does not correspond to your passport data, these Terms and Conditions shall be considered violated, and the Company may immediately close your account and cancel all funds in your balance, in addition to other actions at the Company’s sole discretion, including refusal to provide use of the Website services.

2. The monitoring of account holder activities

The company has its own transaction monitoring department in charge with the monitoring of all player activities together with the related deposits and bets. The Company is constantly investing in the best software of the industry in order to mitigate industry related risks such as money laundering, terrorism financing, fraud and other criminal activities.

Prevention of multiple accounts The system maintained for the monitoring of the activities comprises of an IP address control uncovering any attempt to register multiple accounts. Whenever an account holder requests for a withdrawal of funds from his/ her account, the system will check the presence of multiple accounts and further checks whether the account holder has used a false proxy server. At the presence of multiple accounts, all the accounts will be closed and the account holder will be denied the opening of a new account.

Unusual activities If an account holder has unusual deposits and gets flagged by the system, the department manager will contact the account holder to get an explanation of the abnormal use. In case no satisfactory answer or information is provided, the manager will suspend the account until necessary papers and explanation are in place. If the account holder has not provided satisfying information within 30 days, the account will be closed. The manager will proceed with the reporting of the unusual/suspicious transaction to the relevant authority.

Withdrawal or pay out of funds The Company will not deposit withdrawn funds to another source from which it was originated unless sufficient information or documentation is provided substantiating the request. The pay out of prizes or winnings will only be deposited on the bank account of the account holder. Transfers or pay outs to a third-party account will not be affected unless sufficiently substantiated and to the discretion of the Company. The fact that the Company does not have offline betting shops simplifies the monitoring of all deposits and the control of all user activities.

3. Risk management

Based on the industry related risks, the Company maintains a nondiscretionary approach. All account holders are required to comply with the requirements as detailed in the KYC procedure and are submitted to the regular monitoring of their activities.

4. Reporting of unusual transactions

Any suspicious transactions or circumstances for which the transaction monitoring department has not received sufficient explanation may give rise to a report to the appropriate authority of Curaçao. The department will hold a list of all instances in which it did not consider it necessary to report to the relevant authority. The decision not to report will need to be sufficiently justified.

5. Recordkeeping

The Company maintains a record of all relevant documentation on a separate database for at least five years after ending a business relationship. The Company may perform a quick search for information about individual transactions, including the amounts, currencies and type of transactions, if necessary. In specific circumstances, if ordered by rule of law and permitted by national law and the relevant authorities, the Company may provide copies of the records maintained.