Introduction

Lilbet maintains an anti-money laundering and countering the financing of terrorism (AML/CTF) program designed to prevent misuse of its platform for illicit financial activity. This policy sets the governance, controls, and operating procedures Lilbet applies to customers, transactions, and related communications in order to comply with applicable laws and international standards, including those promulgated by recognized financial intelligence authorities and regulators.

Scope and Regulatory Basis

This policy applies to all Lilbet customers and all payment streams processed through Lilbet. It governs onboarding, verification, ongoing monitoring, reporting, and cooperation with authorities consistent with the jurisdictional licensing and regulatory expectations applicable to Lilbet.

Customer Identification, Verification and Due Diligence

• Customer Identification: Lilbet collects and verifies essential information to establish identity, including full name, date of birth, nationality, residential address, and government-issued identification.
• Verification Thresholds: Identity verification is mandatory prior to processing any financial transaction exceeding USD 2,000 per incident, or prior to a payout, whichever occurs first.
• Documentation: Acceptable documents include a government-issued photo ID (passport, national ID, or driver’s license) and proof of address issued within the last three months. Where required, Lilbet may request documentation to corroborate payment methods.
• Enhanced Due Diligence (EDD): Applied to high‑risk customers, including Politically Exposed Persons (PEPs) and customers from high‑risk jurisdictions, involving assessment of source of funds and, where warranted, source of wealth, with approval by senior compliance personnel.

Sanctions, PEP Screening and Source of Funds

• Sanctions and PEP Screening: Lilbet conducts ongoing screening of customers against global sanctions lists and PEP databases on onboarding and at defined intervals thereafter.
• Source of Funds and Source of Wealth: Customers may be required to disclose the source of funds for provided funds and, when necessary, the source of wealth. Information is used solely for risk assessment, regulatory reporting, and ongoing due diligence.

Ongoing Monitoring and Reporting

Lilbet employs automated and manual monitoring of account activity and transactional behavior. Suspicious or unusual activity triggers internal reviews, escalation to appropriate compliance personnel, and, where required, reporting to the relevant authorities in accordance with legal obligations. Lilbet cooperates with regulatory inquiries and maintains a documentation trail of investigative steps taken.

Record Keeping and Data Retention

All relevant identification data, verification records, and transactional information are securely stored for a minimum of five (5) years and are accessible to authorities or regulators upon lawful request, in compliance with applicable data protection laws.

Training and Governance

Lilbet maintains ongoing AML/CTF training for staff, led by the designated Money Laundering Reporting Officer (MLRO) and senior compliance leadership. Training covers red-flag indicators, escalation procedures, roles and responsibilities, and the organization’s record-keeping requirements. Training is updated as laws and guidance evolve.

Third-Party Verification and Oversight

Lilbet may rely on authorized, regulator-compliant third‑party providers for identity or document verification under binding contracts and with audit trails. Delegation of verification activities does not relieve Lilbet of its regulatory obligations.

Risk-Based Approach and Customer Risk

Lilbet applies a risk-based framework to continuously assess exposure to ML/TF risk across three dimensions: customer risk (KYC tier, geographic origin, PEP status), product/service risk (online gaming environment), and transaction risk (amount, frequency, pattern). Higher‑risk customers are subject to enhanced scrutiny, extended document checks, and additional monitoring controls.

Client Obligations

• Provide complete and truthful KYC documentation and promptly update Lilbet of changes that affect risk assessment.
• Disclose the source of funds and, where necessary, the source of wealth as requested by Lilbet.
• Cooperate with verification requests and undergo re-verification when risk indicators or regulatory triggers necessitate action.
• Non-compliance may result in restrictions, suspension, or termination of access to Lilbet services.

Account Termination, Freezing and Restrictions

Lilbet reserves the right to suspend, restrict, or terminate a customer relationship and to freeze accounts where verification is incomplete, information provided is false or misleading, the customer appears on sanctions or PEP lists without adequate risk mitigation, or there is behavior suggesting potential ML/TF activity. Frozen funds may be retained or restricted in accordance with legal obligations and regulatory reporting requirements.

Confidentiality and No Tipping-Off

All suspicious activity reports and related investigations are handled confidentially in compliance with applicable law. Lilbet maintains confidentiality of internal reviews and communications with authorities and does not disclose investigations, reports, or freezes to customers unless legally required or permitted.

Policy Availability and Access

A condensed version of this AML/KYC Policy is accessible to users on the Lilbet platform. The full policy may be provided upon legitimate request by regulators, partners, or institutional stakeholders through the Compliance Department.

Contact and Further Information

Requests for information or copies of the policy may be submitted via the Lilbet platform through the Compliance channel. The Compliance Department coordinates responses and regulator inquiries in accordance with applicable laws and governance standards.