This Anti-Money Laundering and Know Your Customer Policy (the "Policy") explains, in a calm and orderly manner, which duties and procedures Lucky Boom (operated at fysiotherapiedongeradeel.nl by MAIREKE LIMITADA, a company incorporated in Costa Rica and licensed by the Anjouan Offshore Financial Authority) applies to prevent money laundering, terrorist financing and related financial crime. All players, transactions and accounts at fysiotherapiedongeradeel.nl fall under it. By registering and using the services, you confirm that you have read, understood and accepted it.

1. Basis and purpose

Lucky Boom operates under a licence of the Anjouan Offshore Financial Authority. Following international AML/CFT (Counter Financing of Terrorism) standards and the conditions of the licence, we apply proportionate controls to detect, prevent and report activity that may be money laundering or terrorist financing.

The Policy serves to:

• State the duties of Lucky Boom and of players concerning identity verification and checks on the source of funds;
• Define when, how and why we collect, verify and keep personal and financial documents;
• Explain how transactions are monitored on an ongoing basis;
• Describe the consequences of non-compliance, including restriction or closure of an account;
• Describe our reporting duties when suspicious activity is found.

It applies to all employees, contractors and third-party service providers acting for Lucky Boom, and to all registered players at fysiotherapiedongeradeel.nl.

2. Definitions

• AML — Anti-Money Laundering: the laws, rules and procedures that prevent criminals from disguising illegally obtained money as legitimate income.
• CFT — Counter Financing of Terrorism: measures that prevent money from supporting terrorist activity.
• KYC — Know Your Customer: the process of verifying a player's identity, address and, where required, the source of funds or wealth.
• CDD — Customer Due Diligence: the standard checks applied to every player.
• EDD — Enhanced Due Diligence: additional and more thorough checks for higher-risk players or transactions.
• PEP — Politically Exposed Person: a person who holds, or has held, a prominent public function, including close associates and family members.
• SAR — Suspicious Activity Report: a formal internal or external report made when money laundering or terrorist financing is suspected.
• MLRO — Money Laundering Reporting Officer: the person at Lucky Boom who receives and assesses internal SARs and makes external disclosures where required.

3. A risk-based approach

We assess the risk of every player and every transaction and apply controls that fit that risk. Not every player is examined to the same degree, but every player passes at least standard CDD before a withdrawal is approved.

Our assessment considers, among other things:

• The player's country of residence or nationality;
• The payment methods and currencies used;
• The frequency and volume of deposits and withdrawals compared with stated income;
• The nature and pattern of play;
• Whether the player is a PEP or appears on a sanctions list;
• Earlier suspicious activity or flagged transactions on the account;
• The source of funds that the player declares.

Where risk indicators are elevated, EDD is applied and further documents may be requested before a withdrawal is processed or the service continues.

4. Standard due diligence (KYC)

4.1 When KYC is required

Identity documents may be requested at any time after registration, and full KYC is always required before a withdrawal is approved. We encourage players to verify early, so that nothing delays a withdrawal. KYC may also be required when:

• Total deposits reach an internal risk threshold;
• A withdrawal is requested, whatever the amount;
• A transaction pattern seems inconsistent with earlier activity;
• The player is identified as a PEP or matches a sanctions database;
• Any indicator gives rise to suspicion of money laundering or fraud.

4.2 Standard documents

For standard CDD we ask every player for:

• Proof of Identity (POI) — a clear, full-colour copy of a valid government-issued photo ID (national identity card, passport or driving licence). It must not be expired, must show your full legal name, date of birth and photograph, and must be legible at all four corners.
• Proof of Address (POA) — a document issued in the last three months that confirms your residential address, such as a utility bill (gas, electricity, water or fixed-line telephone), a bank statement, a government letter or a council tax statement, showing your full name and current address.
• Proof of Banking Option (POPM) — confirmation that the payment method is yours. For bank cards, a photograph or screenshot showing the card number (middle eight digits hidden), your name and the expiry date; for e-wallets or bank transfers, a screenshot of the account showing your name and account details is usually sufficient.

4.3 Selfie and liveness verification

In some cases we may ask for a selfie together with your identity document, or for a liveness check in our verification system, to confirm that the person sending the documents is the person on the ID and the registered account holder.

4.4 Submitting documents

KYC documents are submitted through your account profile or by email to support@fysiotherapiedongeradeel.nl. Our 24/7 live chat team can guide you through the process. Documents must be legible, unaltered and complete, and we may reject documents that appear manipulated, cropped or tampered with.

4.5 Outcome and timeline

Standard KYC submissions are processed promptly. If your documents are complete and satisfactory, verification is normally completed within our published payout approval window of two business days. If more information is needed, our team will contact you directly. While a review is open, withdrawals are held until KYC has been completed satisfactorily.

5. Enhanced due diligence

When a player or transaction is assessed as higher risk, EDD is applied. It is a regulatory and legal obligation, not a penalty. In addition to standard CDD it may require one or more of the following:

5.1 Source of funds (SOF)

You may be asked to show where the funds used for gambling came from. Acceptable evidence includes, among other things:

• Recent payslips or an employment contract showing salary;
• Bank statements showing regular salary credits or receipt of the funds concerned;
• A letter from an accountant or employer confirming income;
• Documents confirming an inheritance, the proceeds of a property sale or investment dividends;
• Business accounts or tax returns for self-employed persons.

5.2 Source of wealth (SOW)

Where volumes are very high, or where a player's overall wealth warrants examination, Source of Wealth documents may be requested. This is wider than SOF and concerns how the player accumulated their assets, not only where the deposit came from.

5.3 PEP and sanctions screening

All players are screened against recognised PEP lists and international sanctions databases at registration and continuously afterwards. A PEP or sanctions match leads automatically to EDD. Lucky Boom may decline to open, or may close, the account of anyone who appears on a sanctions list or presents an unacceptable level of risk as a PEP.

5.4 High-value players

Players who use the High Roller Bonus (deposits of €500 or more), or who approach the weekly withdrawal cap of €20,000 or the monthly cap of €50,000 for non-jackpot wins, are monitored more closely. Where jackpot winnings, which fall outside the monthly cap, are involved, further source-of-funds verification may be required before the full payout.

6. Ongoing monitoring

KYC is not a one-time event. All accounts are monitored throughout the relationship, including through:

• Real-time and retrospective review of deposits and withdrawals against the stated profile;
• Comparison of deposit and withdrawal patterns with the published limits (minimum deposit €20, minimum withdrawal €40, weekly cap €20,000, monthly cap €50,000);
• Identification of unusual betting, such as large quick deposits followed at once by withdrawal requests after minimal play;
• Detection of structuring, for example splitting deposits to stay under internal thresholds;
• Periodic re-verification of identity and address, particularly after account details are updated or after a quiet period followed by high-value activity;
• Cross-checking of VIP status claims: players who ask for a status match with screenshots from another operator may be examined more closely.

If monitoring shows activity that does not fit a player's profile or raises suspicion, the account is escalated for internal review, and withdrawals or continued play may be restricted temporarily while we investigate.

7. Suspicious activity and reporting

7.1 Internal reporting

Any member of the compliance or operations team who identifies or suspects money laundering, terrorist financing or related crime must report it immediately to the MLRO under the internal SAR procedure. The MLRO assesses the report, decides whether suspicion is justified and whether an external disclosure is required.

7.2 External disclosure

Where the MLRO finds reasonable grounds for suspicion, an external report is made to the appropriate financial intelligence unit or regulatory body, as required by the Anjouan licence and applicable international standards, without informing the player concerned (the "tipping-off" prohibition).

7.3 Prohibition of tipping off

Tipping off is strictly prohibited. No employee, contractor or representative may inform a player or a third party that a SAR or an AML investigation exists. A breach is a serious disciplinary matter and may be a criminal offence.

7.4 Red flags

Examples of activity that may lead to an internal review or a SAR (illustrative, not exhaustive):

• Repeated deposits of the minimum amount (€20) in quick succession to reach a larger total without a single large deposit being reviewed;
• Deposits through several payment methods or cards without a clear link to the verified account;
• A withdrawal request of €40 or more immediately after a deposit, with little or no meaningful play in between;
• Inconsistency between declared occupation or income and deposit or wagering volumes;
• A player who is unable or unwilling to provide satisfactory KYC documents within a reasonable time;
• An attempt to exploit bonus terms, free spins or rakeback credits in a way that does not fit genuine recreational play;
• Third-party deposits, where funds appear to come from a payment method that does not belong to the registered player;
• Activity consistent with chip dumping or collusion in live casino or sports betting;
• Requests to transfer account balances to third parties.

8. Third-party payments

Deposits from, and withdrawals to, payment methods that do not belong to the registered account holder are not accepted. Deposits must be made from a method in the name of the account holder, and withdrawals are returned to the same method wherever possible.

If the name of the account holder differs from that of the payment method, we request Proof of Banking Option documents before processing any transaction. Persistent use of third-party payment methods, or an unsatisfactory explanation, may lead to suspension of the account and escalation to the MLRO.

9. Record keeping

KYC documents, transaction records, account activity logs and SAR-related records are retained for at least five years from the last transaction on an account, or for longer where the licence conditions or the law require. They are stored securely and are available to the MLRO and the compliance team for audit and reporting.

Documents and personal data collected for KYC are processed in accordance with our Privacy Policy. We collect only what is necessary, keep it only as long as required and use it solely for compliance, fraud prevention and the provision of our services.

10. Obligations of players

By registering an account at fysiotherapiedongeradeel.nl, you confirm and warrant that:

• You are at least 18 years old;
• You are the only registered user of your account and will not allow any third party to access or operate it;
• All funds you deposit at Lucky Boom come from lawful sources and are not the proceeds of crime;
• You will not use the site to launder money, to finance terrorism or for any other illegal activity;
• All information and documents you give at registration or during KYC are accurate, complete and up to date;
• You will promptly tell us of any change in your registered details, including name, address or payment methods;
• You understand that failure to cooperate with KYC requests may lead to restriction or closure of your account and to withdrawals being withheld pending regulatory review.

11. Non-compliance

If a player fails to provide satisfactory KYC documents within a reasonable period, or if an account is judged to carry an unacceptable AML or fraud risk, Lucky Boom may take any or all of the following steps:

• Suspend deposits and withdrawals pending verification;
• Void bonus funds or rakeback credits accumulated on the account;
• Close the account permanently;
• Withhold the balance pending regulatory guidance or a finding that the funds are of lawful origin;
• Report the matter to the relevant financial intelligence authority or law-enforcement body, as the licence requires.

We act in good faith in all such decisions and, where possible, give the player an opportunity to resolve a documentation issue before taking irreversible steps. Where a legal obligation requires immediate action, for example a confirmed sanctions match, we may act at once and without prior notice.

12. Responsible gambling and AML

The AML and responsible gambling frameworks operate side by side. If monitoring reveals behaviour that may point to problem gambling (increasing deposit frequency, large deposits followed by distressed withdrawal requests, or play beyond one's means), these observations are shared with the responsible gambling team. Equally, responsible gambling signals may prompt an AML review, for instance when a player says they cannot afford losses while making high-value deposits.

If you wish to set limits, take a break or seek help with gambling-related matters, you can contact our 24/7 support team by live chat or at support@fysiotherapiedongeradeel.nl at any time.

13. Staff training

All employees and contractors who handle player accounts, transactions or compliance functions receive AML and KYC training suited to their role, covering the recognition of suspicious activity, internal reporting, the prohibition of tipping off and the requirements of this Policy. Training is given at the start and refreshed regularly.

14. Review of this Policy

Our compliance function reviews this Policy at least once a year, and more often when changes in licence conditions, the law or the risk environment require. The current version is published at fysiotherapiedongeradeel.nl and replaces all earlier versions. We invite players to consult this page from time to time.

15. Contact

If you have questions about this Policy, our KYC procedures or a verification request you received, please contact us:

We are committed to keeping Lucky Boom a safe, fair and legally compliant place. This Policy reflects that commitment, and we thank our players for their cooperation in upholding it.