This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Lalabet Casino, operated at lalabet.io under a Curaçao eGaming licence, to detect, prevent and report financial crime. It applies to every customer account, every transaction and every member of staff involved in the operation of lalabet.io. By opening an account and using our services, you agree to cooperate fully with our verification procedures.

1. Introduction and Purpose

Lalabet Casino is committed to the highest standards of Anti-Money Laundering ("AML") compliance and the prevention of terrorist financing ("CTF"). As a Curaçao-licensed operator, we are required to maintain robust controls that deter criminals from using lalabet.io to launder the proceeds of unlawful activity or to fund terrorism. This Policy exists to:

• Establish clear procedures for identifying and verifying our customers;
• Define how we monitor transactions and account behaviour for suspicious activity;
• Set out our obligations to report concerns to the appropriate authorities;
• Protect Lalabet Casino, its staff, and its genuine customers from exposure to financial crime;
• Ensure ongoing compliance with applicable laws, regulations and licence conditions issued by the Curaçao eGaming authority.

This Policy is reviewed regularly and updated whenever relevant legislation, regulatory guidance or our own risk assessment indicates that a revision is necessary.

2. Scope

This Policy applies to:

• All registered customers of lalabet.io, regardless of their country of residence or the payment method they use;
• All deposits, withdrawals and bonus transactions processed through the platform;
• All products available on lalabet.io, including the casino, live casino, sportsbook and any instant-win or crash games;
• All employees, contractors, and third-party service providers who process or have access to customer data or financial information on behalf of Lalabet Casino.

3. Risk-Based Approach

Lalabet Casino applies a risk-based approach to AML and KYC. This means that the level of scrutiny we apply to a customer, a transaction or a business relationship is proportionate to the assessed risk of money laundering or terrorist financing associated with it. Factors that influence our risk assessment include, but are not limited to:

• The customer's country of residence and source of funds;
• The payment methods and currencies used — including cryptocurrency transactions involving Bitcoin, Ethereum and Litecoin;
• The volume, frequency and value of deposits and withdrawals;
• Whether the customer is identified as a Politically Exposed Person ("PEP") or appears on any sanctions list;
• Unusual or inconsistent account activity relative to the customer's stated profile;
• Any information received from third parties, payment processors or law enforcement agencies.

Higher-risk customers and transactions are subject to Enhanced Due Diligence ("EDD") as described in Section 6 below.

4. Know Your Customer (KYC) — Customer Due Diligence

Customer Due Diligence ("CDD") is the cornerstone of our KYC programme. We collect and verify information about our customers to confirm that they are who they claim to be, that their funds are legitimate, and that they are not subject to any sanctions or restrictions that would prevent us from serving them.

4.1 When Verification is Required

We will request identity verification at any of the following trigger points:

• When a customer registers an account on lalabet.io;
• Before processing any withdrawal request, regardless of amount;
• When cumulative deposits reach an internal risk threshold;
• When a customer requests a withdrawal that exceeds defined internal limits;
• When account activity, transaction patterns or other indicators raise a concern;
• When a customer is identified as a PEP or appears on a sanctions screening list;
• At any other point where we consider it necessary to satisfy our regulatory obligations.

Lalabet Casino reserves the right to suspend withdrawals and place deposits into a restricted holding state until satisfactory verification documentation has been received and reviewed. Customers who do not complete verification within a reasonable timeframe may have their accounts suspended or closed.

4.2 Standard Identity Documents

To verify your identity, we will ask you to provide clear, unobstructed copies of the following:

• Proof of Identity (POI): A valid government-issued photo ID such as a passport, national identity card, or driving licence. The document must be current, clearly legible, and must show your full name, date of birth, and photograph.
• Proof of Address (POA): A utility bill, bank statement, or official government correspondence issued within the last three months. The document must display your full name and residential address as registered on your Lalabet Casino account.
• Proof of Payment Method: Verification of the payment instrument used to deposit funds. For cards, this typically means a photograph of the card showing only the last four digits and your name. For e-wallets such as Skrill or Neteller, a screenshot confirming account ownership may be requested. For cryptocurrency wallets, we may request confirmation of the sending address.

All documents must be submitted in a format that clearly shows all four corners of the document, with no editing or digital alteration. Documents that appear to have been modified in any way will be rejected, and the account may be flagged for further review.

4.3 Source of Funds and Source of Wealth

Lalabet Casino may request evidence of your source of funds and, in higher-risk cases, your source of wealth. This is not a reflection of any personal suspicion; it is a regulatory requirement for all licensed gambling operators. Documents that may be requested include:

• Recent payslips or an employment contract confirming salary;
• Bank statements covering a period sufficient to demonstrate the origin of deposited funds;
• Company accounts or business financial statements for self-employed customers;
• Dividend statements, investment portfolio documentation, or sale-of-asset records;
• Inheritance or gift documentation where applicable.

Failure to provide satisfactory source-of-funds evidence will result in a withdrawal hold and, where we are unable to satisfy ourselves as to the legitimacy of the funds, account closure and the filing of a Suspicious Activity Report ("SAR") where required by law.

5. Ongoing Monitoring

KYC is not a one-time event. Lalabet Casino continuously monitors customer accounts and transactions throughout the customer relationship. Our ongoing monitoring programme includes:

• Automated transaction monitoring that flags deposits or withdrawals inconsistent with a customer's established profile;
• Review of cumulative deposit and withdrawal totals against stated income and source of funds;
• Monitoring for structuring behaviour — for example, making multiple deposits just below internal thresholds in a manner designed to avoid scrutiny;
• Re-screening of customers against updated PEP and sanctions lists on a periodic basis;
• Periodic review of customer files to ensure that identity documents remain current and that account activity remains consistent with the information held on file;
• Review of withdrawal requests across all payment methods, including Bitcoin, Ethereum, Litecoin, Skrill, Neteller, Visa/Mastercard, and bank transfer, to ensure that funds are returned to the same source wherever possible.

6. Enhanced Due Diligence (EDD)

Where a customer, a transaction, or a business relationship is assessed as higher risk, Lalabet Casino will apply Enhanced Due Diligence measures. EDD goes beyond standard CDD and may include any or all of the following:

• Requesting additional identity documentation or certified copies of documents;
• Requiring detailed source-of-funds and source-of-wealth evidence before any withdrawal is processed;
• Conducting independent verification of information provided by the customer;
• Applying enhanced transaction monitoring with lower alert thresholds;
• Requiring senior management approval before accepting or continuing a business relationship;
• Increasing the frequency of file reviews;
• Restricting deposit limits, withdrawal limits, or access to specific products pending the outcome of the review.

EDD is automatically applied to customers identified as Politically Exposed Persons, customers resident in higher-risk jurisdictions as identified in our internal risk assessment, and any customer whose account activity raises a concern that cannot be addressed through standard CDD.

7. Politically Exposed Persons (PEPs) and Sanctions Screening

A Politically Exposed Person is an individual who holds or has held a prominent public function, including heads of state, senior politicians, senior government officials, judicial officers, senior military officers, and senior executives of state-owned enterprises, as well as their close family members and known associates.

Lalabet Casino screens all customers against PEP databases and international sanctions lists at the point of registration and on an ongoing basis. Where a customer is identified as a PEP or as a match against a sanctions list:

• The account will be placed under immediate enhanced review;
• Senior management approval is required before the account may remain active;
• EDD measures as described in Section 6 will be applied in full;
• Where a customer is subject to applicable sanctions, the account will be suspended and the matter referred to the appropriate authorities without delay.

We use recognised third-party screening providers to ensure that our PEP and sanctions data is current and comprehensive.

8. Suspicious Activity — Identification and Reporting

All staff involved in the operation of lalabet.io are trained to identify indicators of suspicious activity. Indicators that may trigger an internal review include, but are not limited to:

• Deposits immediately followed by withdrawal requests with little or no gameplay, regardless of payment method;
• Use of multiple different payment methods — including combinations of Visa/Mastercard, Skrill, Neteller, and cryptocurrency wallets — across a short period, particularly where the pattern does not reflect normal player behaviour;
• Requests to withdraw to a different payment method or cryptocurrency wallet than was used to deposit;
• Sudden and unexplained changes in deposit or wagering volume;
• Customers who appear disinterested in the outcome of their gameplay and focus primarily on satisfying turnover requirements before withdrawing;
• Use of cryptocurrency to obscure the origin of funds;
• Account activity that is inconsistent with the customer's stated occupation or financial profile;
• Any information from third parties, including payment processors, that raises a concern about the source of funds or the identity of the customer.

Where suspicious activity is identified, a Suspicious Activity Report will be prepared and submitted to the appropriate financial intelligence unit in accordance with applicable law. Lalabet Casino strictly observes the legal prohibition on "tipping off" — neither employees nor the operator will disclose to a customer or any third party that a SAR has been filed or that an investigation is under way.

9. Record Keeping

Lalabet Casino retains the following records for a minimum of five years from the date of the transaction or the end of the customer relationship, whichever is later:

• All identity and verification documents collected during the KYC process;
• All transactional records, including deposits, withdrawals, bonuses and adjustments across all payment methods;
• Account activity logs, including login history and session data;
• All correspondence with customers relating to KYC and compliance matters;
• Internal investigation records, SAR filings and any responses received from authorities;
• Staff training records relating to AML and KYC compliance.

Records are stored securely and accessed only by authorised personnel. We comply with applicable data protection legislation in the handling of all personal data. For further information on how your personal data is processed, please refer to our Privacy Policy on lalabet.io.

10. Payments, Currencies and AML Controls

Lalabet Casino accepts deposits and processes withdrawals across a range of payment methods, each of which is subject to the controls set out in this Policy. The following table summarises the methods available and the applicable limits:

As a general rule, Lalabet Casino operates a return-to-source principle: withdrawals will be directed back to the same payment method used for the corresponding deposit, to the extent technically possible. This principle is a core AML control that prevents funds from being cycled through multiple instruments. Where a return-to-source withdrawal is not possible, additional verification will be required before an alternative method is approved.

Deposits and withdrawals made in cryptocurrency require particular attention because of the pseudonymous nature of blockchain transactions. We reserve the right to request wallet ownership confirmation, blockchain analytics information, and enhanced source-of-funds documentation for any cryptocurrency transaction, regardless of value. Third-party cryptocurrency deposits — that is, funds sent from a wallet that does not belong to the registered customer — are strictly prohibited and will be returned where technically possible or held pending investigation.

Third-party payments by any method are not permitted. All deposits must originate from a payment account held in the name of the registered Lalabet Casino customer. Similarly, all withdrawals will be made only to accounts or wallets confirmed to be in the customer's own name. Any attempt to use a third-party payment method may result in account suspension and a SAR filing.

11. Bonus Abuse and Financial Crime

The abuse of promotional offers — including the ten-deposit welcome package worth up to €10,000 and all ongoing promotions such as reload bonuses, free spins, cashback offers and sportsbook boosts — can in some circumstances constitute a form of fraud that intersects with money laundering risk. Lalabet Casino monitors bonus uptake and wagering behaviour to identify patterns consistent with bonus abuse, including:

• Systematic exploitation of bonuses without genuine recreational intent;
• Using bonus funds as a mechanism to cleanse funds through rapid wagering and withdrawal;
• Operating multiple accounts to claim bonuses more than once;
• Coordinated play across accounts to manufacture the appearance of legitimate wagering.

Where bonus abuse is detected alongside AML concerns, the matter will be escalated and may result in forfeiture of bonus funds, account closure, and, where appropriate, a referral to the relevant authorities.

12. Responsible Gambling and Vulnerability Considerations

Lalabet Casino recognises that problem gambling and financial vulnerability can intersect with AML risk. A customer experiencing financial difficulty may exhibit transaction patterns that, in a different context, could appear suspicious — for example, depositing unusually large sums shortly before significant withdrawals, or rapidly escalating deposit frequency. Our compliance team is trained to consider customer vulnerability alongside AML indicators, and to refer cases involving potential harm to our responsible gambling team where appropriate.

Customers who wish to set deposit limits, take a cooling-off period, or self-exclude can contact our support team via 24/7 live chat or email through lalabet.io. Responsible gambling tools do not replace or limit our AML obligations; both frameworks operate in parallel and are applied independently.

13. Staff Training

All employees and contractors with access to customer accounts, financial data or compliance functions receive AML and KYC training at the point of onboarding and on a regular basis thereafter. Training covers:

• The legal and regulatory framework applicable to Lalabet Casino under its Curaçao eGaming licence;
• How to identify suspicious activity indicators in the context of casino and sportsbook operations;
• The internal escalation procedure for raising AML concerns;
• Confidentiality obligations, including the prohibition on tipping off;
• Record-keeping requirements;
• Updates to regulatory guidance and typologies relevant to online gambling.

Training records are maintained and made available to regulators upon request.

14. Compliance Officer

Lalabet Casino has appointed a designated Money Laundering Reporting Officer ("MLRO") who is responsible for overseeing the implementation of this Policy, reviewing and filing SARs, liaising with regulatory and law enforcement authorities, and ensuring that the training programme remains fit for purpose. The MLRO has sufficient seniority, independence and access to resources to carry out these functions effectively. Staff wishing to make an internal disclosure of suspicious activity should do so to the MLRO through the internal escalation procedure.

15. Non-Cooperation and Account Closure

Where a customer fails or refuses to provide the information or documentation requested under this Policy within a reasonable timeframe, Lalabet Casino will:

• Suspend the customer's ability to withdraw funds pending the completion of verification;
• Where appropriate, suspend the ability to deposit or play;
• Close the account if satisfactory documentation is not received within the timeframe communicated to the customer;
• Retain any funds on the account in accordance with legal obligations pending resolution or regulatory guidance;
• File a SAR where the circumstances warrant, without informing the customer that this has been done.

We understand that verification requests can feel intrusive. They are not optional. They are a legal requirement that protects both our customers and the integrity of the platform.

16. Policy Review

This Policy is reviewed at least annually by the MLRO and senior management, and more frequently where required by changes in legislation, regulatory guidance, our licence conditions, or the risk environment in which Lalabet Casino operates. The current version of this Policy is published on lalabet.io and supersedes all previous versions.

17. Contact

If you have any questions about this Policy or about the verification process, please contact the Lalabet Casino compliance and support team through the 24/7 live chat facility available on lalabet.io, or by email as listed in the support section of the website. We aim to respond to all compliance-related enquiries promptly and to handle your personal data with the utmost care throughout the process.