This Anti-Money Laundering and Know Your Customer Policy ("Policy") applies to all players who register, deposit, play, or withdraw at luckygem, operated by Virtual Connect Sociedad de Responsabilidad Limitada and accessible at luckygeem.nl. luckygem is committed to preventing its platform from being used for money laundering, terrorist financing, or any other form of financial crime. This Policy sets out the obligations of luckygem and of its players, and explains how identity verification, transaction monitoring, and suspicious-activity reporting are handled.

1. Legal Framework and Scope

luckygem operates under a Costa Rica licence granted to Virtual Connect Sociedad de Responsabilidad Limitada. Although Costa Rica-licensed operators are not subject to EU directives as a matter of domestic law, luckygem voluntarily aligns its compliance programme with internationally recognised standards, including the Financial Action Task Force (FATF) Recommendations, in order to maintain the integrity of its platform and protect its players.

This Policy applies to:

• all natural persons who register an account at luckygeem.nl;
• all deposits, wagers, and withdrawals processed through the platform;
• all payment methods accepted by luckygem, including ING, Rabobank, ABN AMRO, SNS, ASN Bank, and N26; and
• all staff, contractors, and third-party service providers who act on behalf of luckygem.

2. Definitions

• AML — Anti-Money Laundering: the set of laws, regulations, and procedures designed to prevent the proceeds of crime from being disguised as legitimate funds.
• KYC — Know Your Customer: the process by which luckygem verifies the identity, address, and source of funds of its players.
• Money Laundering — the process of making illegally obtained funds appear to originate from a legitimate source, typically through placement, layering, and integration.
• Terrorist Financing — the provision or collection of funds intended to be used, in whole or in part, for terrorist acts or by terrorist organisations.
• Suspicious Activity — any transaction, pattern of behaviour, or account activity that raises a reasonable suspicion of money laundering, fraud, or terrorist financing.
• PEP — Politically Exposed Person: an individual who holds or has held a prominent public function, or is a close associate or family member of such a person.
• Source of Funds (SOF) — the origin of the money used by a player to fund their account.
• Source of Wealth (SOW) — the origin of the total wealth of a player, independent of any single transaction.

3. Risk-Based Approach

luckygem adopts a risk-based approach to AML and KYC compliance. This means that the level of due diligence applied to any given player is proportionate to the assessed risk that player presents. Risk factors considered include, but are not limited to:

• the player's country of residence or nationality;
• the frequency and volume of deposits and withdrawals;
• the payment methods used;
• the player's VIP tier and associated withdrawal limits;
• whether the player has been identified as a PEP or is subject to international sanctions; and
• any unusual or inconsistent patterns of play relative to declared income or wealth.

Players assessed as lower risk may complete a streamlined verification process. Players assessed as higher risk — including those reaching elevated VIP tiers with access to higher or unlimited daily withdrawal limits — will be subject to Enhanced Due Diligence (EDD) as described in Section 6 below.

4. Customer Due Diligence — Standard KYC

4.1 When Verification Is Required

luckygem will request KYC documentation before, during, or after any of the following events:

• first withdrawal request, regardless of amount;
• cumulative deposits or withdrawals that reach internal thresholds set by luckygem's compliance team;
• any transaction that triggers a risk flag in luckygem's monitoring systems;
• prior to processing any withdrawal that exceeds the standard daily limit of €1,000;
• upon progression to VIP tiers that carry higher withdrawal limits; and
• at any time luckygem reasonably considers verification necessary to fulfil its AML obligations.

4.2 Documents Required — Proof of Identity

Players must provide one of the following unexpired, government-issued documents showing their full legal name and date of birth:

• national identity card (both sides);
• passport (photo page);
• driver's licence (both sides).

4.3 Documents Required — Proof of Address

Players must provide one of the following documents issued within the last three months, showing their full name and residential address:

• bank statement;
• utility bill (gas, electricity, water, or fixed-line telephone);
• official government correspondence; or
• municipal registration document.

PO Box addresses are not accepted as proof of residential address.

4.4 Documents Required — Proof of Payment Method

Where a player has deposited via a bank account at ING, Rabobank, ABN AMRO, SNS, ASN Bank, N26, or any other accepted institution, luckygem may request:

• a bank statement confirming account ownership and the IBAN used; or
• a screenshot of the banking application clearly showing the account holder's name and IBAN.

luckygem applies a strict same-method withdrawal policy: funds will be returned to the same account or payment instrument used to make the original deposit, subject to successful KYC verification.

4.5 Selfie / Liveness Check

luckygem may require a player to submit a selfie holding their identity document, or to complete an automated liveness check, in order to confirm that the document holder and the account holder are the same person.

4.6 Submission and Processing

Documents must be submitted through the secure verification interface available in the player's account area, or as directed by the luckygem support team via live chat or at [email protected]. luckygem endeavours to review and respond to standard KYC submissions within two banking days. Withdrawals remain pending until verification is complete; luckygem's standard payout speed of within two banking days applies from the point at which verification is successfully concluded.

5. Age Verification

luckygem strictly prohibits the registration or participation of persons under the age of 18. Age verification is a mandatory component of the KYC process. Where luckygem has reasonable grounds to suspect that a player may be under 18, the account will be suspended and all gameplay and withdrawal functionality frozen pending production of satisfactory proof of age. If a player is confirmed to be under 18, the account will be permanently closed, any deposits returned, and all winnings forfeited in accordance with applicable policies.

6. Enhanced Due Diligence

Enhanced Due Diligence (EDD) will be applied in the following circumstances:

• the player is identified as a Politically Exposed Person (PEP), or is a close family member or known associate of a PEP;
• the player's transactions are inconsistent with their stated occupation, income, or profile;
• the player reaches VIP tiers associated with unlimited daily withdrawal limits;
• the player makes a large or unusual single withdrawal, particularly one that approaches or exceeds the standard monthly limit of €10,000;
• the player's account shows patterns consistent with structuring, layering, or integration of funds; or
• any other factor that elevates the player's assessed risk profile.

EDD measures may include, but are not limited to, one or more of the following:

• Source of Funds (SOF) declaration — written confirmation and documentary evidence of the specific funds used to make deposits (e.g., wage slips, bank statements, sale agreements);
• Source of Wealth (SOW) declaration — documentary evidence of the overall financial standing of the player (e.g., employment contracts, tax returns, company accounts, inheritance documentation);
• Enhanced identity documentation — additional or certified copies of identity documents;
• Third-party database checks — screening against PEP lists, international sanctions lists, and adverse-media databases; and
• Senior compliance review — escalation to luckygem's senior compliance officer for manual assessment.

A player who is unable or unwilling to satisfy EDD requirements within the timeframe specified by luckygem's compliance team may have their withdrawal withheld, their account restricted, or their account permanently closed, as appropriate.

7. Ongoing Monitoring

KYC is not a one-time exercise. luckygem monitors player accounts on an ongoing basis throughout the customer relationship. Ongoing monitoring includes:

• automated transaction monitoring to detect unusual deposit or withdrawal patterns, including sudden spikes in activity relative to a player's established profile;
• review of deposit and withdrawal methods to identify any attempt to use multiple payment instruments in a manner inconsistent with normal behaviour;
• periodic re-verification of player identity and source of funds, particularly for players in higher VIP tiers;
• screening of player data against updated PEP and sanctions lists; and
• review of gameplay patterns for signs of activity inconsistent with genuine recreational play.

Where ongoing monitoring identifies a concern, luckygem reserves the right to request further documentation, restrict the account, or report the activity in accordance with Section 9 of this Policy.

8. Indicators of Suspicious Activity

luckygem's compliance and support teams are trained to recognise indicators of potential money laundering or fraud. Examples of red flags include, but are not limited to:

• a player depositing large sums immediately after registration without significant gameplay;
• deposits made via multiple different bank accounts or payment instruments;
• a player requesting withdrawal of funds shortly after deposit with little or no wagering activity;
• patterns of wagering that appear designed to clear bonus requirements mechanically rather than for genuine entertainment;
• inconsistency between stated occupation or income and the volume of funds transacted;
• a player expressing unusual concern about the KYC process or actively seeking to avoid verification;
• multiple accounts linked to the same device, IP address, bank account, or payment method; and
• use of third-party payment accounts not registered in the player's own name.

9. Reporting and Record Keeping

9.1 Internal Reporting

Any member of luckygem staff or any third-party service provider who identifies or suspects suspicious activity must report it immediately to luckygem's designated compliance officer. Internal reports are treated as strictly confidential. No player will be tipped off that a report has been filed or that their account is under review.

9.2 External Reporting

Where luckygem's compliance officer determines that a suspicious activity report is warranted, a report will be made to the relevant financial intelligence or law enforcement authority in accordance with applicable law. luckygem will co-operate fully with any investigation conducted by regulatory or law enforcement bodies.

9.3 Record Keeping

luckygem retains all KYC documents, transaction records, and compliance-related communications for a minimum of five years from the date of the relevant transaction or the closure of the player account, whichever is the later. Records are stored securely and in accordance with luckygem's Privacy Policy.

10. Prohibited Activities

The following activities are strictly prohibited on luckygeem.nl and will result in immediate account suspension, forfeiture of funds where legally permitted, and referral to the relevant authorities:

• depositing funds derived from criminal activity;
• using luckygem's platform to launder money or finance terrorism;
• providing false, misleading, or fraudulent KYC documentation;
• operating an account on behalf of a third party;
• using a payment method not registered in the player's own name; and
• creating multiple accounts for the purpose of circumventing verification or withdrawal limits.

11. Player Obligations

By registering at luckygeem.nl, each player agrees to:

• provide accurate, truthful, and up-to-date personal information at registration and throughout the account lifecycle;
• promptly supply any KYC documentation requested by luckygem's compliance team;
• notify luckygem of any material change to their personal details, including name, address, or primary payment method;
• ensure that all funds deposited originate from legitimate sources and are owned by the account holder; and
• co-operate fully with any verification or investigation process initiated by luckygem.

12. Deposits, Withdrawals, and Transaction Limits

luckygem operates the following standard transaction limits, which are relevant to the risk assessment process applied under this Policy:

Players seeking access to VIP-tier unlimited withdrawal limits will be subject to mandatory Enhanced Due Diligence before such limits are approved. luckygem reserves the right to apply additional transaction monitoring to any account operating at or near its maximum withdrawal limits.

All accepted payment methods — including ING, Rabobank, ABN AMRO, SNS, ASN Bank, and N26 — are subject to the same KYC and monitoring requirements. luckygem does not accept cash payments or anonymous payment instruments.

13. Responsible Gambling and AML

luckygem recognises that problem gambling and financial crime are related concerns, and that both can cause significant harm. Unusual patterns of play, such as depositing far beyond what might be expected of recreational play or making rapid consecutive deposits, may trigger both a responsible gambling review and an AML review simultaneously. Players who are identified through luckygem's responsible gambling programme as exhibiting signs of disordered gambling may also be subject to enhanced transaction monitoring.

Players who wish to manage their own spending are encouraged to make use of the responsible gaming tools available on luckygeem.nl. For support with problem gambling, independent help is available from organisations including Verslavingszorg Noord Nederland (VNN) and the national helpline Agog.

14. Staff Training and Internal Controls

luckygem ensures that all relevant staff receive appropriate and up-to-date training in AML and KYC obligations, including how to identify suspicious activity, how to handle KYC documentation securely, and how to escalate concerns to the compliance officer. Internal controls are reviewed periodically to ensure that they remain effective and proportionate to the risks faced by the platform.

15. Amendments to This Policy

luckygem reserves the right to amend, update, or replace this Policy at any time. Where material changes are made, luckygem will endeavour to notify players through the platform or by email. Continued use of luckygeem.nl following the publication of an updated Policy constitutes acceptance of its terms. Players are encouraged to review this page periodically.

16. Contact

Questions or concerns relating to this Policy, or requests to submit KYC documentation, may be directed to luckygem's compliance and support team through the following channels:

• Email: [email protected]
• Live Chat: available 24 hours a day, 7 days a week, via luckygeem.nl

luckygem is operated by Virtual Connect Sociedad de Responsabilidad Limitada. This Policy was last reviewed and updated in 2026.