Lussurio Anti-Money Laundering Policy

This policy explains the measures used by lussurio-ca.org to prevent money laundering, payment fraud, identity misuse and other forms of financial crime. It also outlines how customer verification, transaction monitoring, staff training and internal reporting are handled.

1. AML experience and internal responsibility

1.1. Lussurio has established procedures for protecting online gaming services from criminal misuse. These procedures include anti-fraud controls, transaction reviews, customer verification and regular staff training.

1.2. Training covers relevant proceeds-of-crime requirements and the warning signs commonly associated with money laundering in online gambling, including transactions completed without face-to-face contact.

1.3. Company management is responsible for maintaining appropriate anti-money laundering controls and ensuring that employees understand their duties.

2. Financial crime risks in online gaming

2.1. Online gaming platforms may be targeted by individuals attempting to move or disguise unlawfully obtained funds. The speed of transactions and the availability of several payment methods can increase this risk.

2.2. Lussurio therefore applies financial crime controls throughout account registration, deposits, gameplay, withdrawals and account reviews.

3. Staff awareness and reporting

3.1. Employees receive training to recognise activity that may require further review. Relevant indicators include:

• unusual or inconsistent betting behaviour;
• unexpected deposit or withdrawal amounts;
• frequent transactions without a clear gaming purpose;
• unreliable or conflicting payment information;
• identity verification problems;
• suspected identity theft;
• linked accounts or multiple accounts controlled by the same person.

3.2. Suspected money laundering must be reported internally to the Money Laundering Reporting Officer, also referred to as the MLRO.

3.3. Employees must not inform a customer that a report, review or investigation is taking place. Further action is handled through the appropriate internal procedures.

3.4. The MLRO is responsible for reviewing reports, maintaining the required records and submitting suspicious activity information to the relevant authority where necessary.

4. Customer identification and verification

4.1. Lussurio follows a Know Your Customer process to confirm the identity of account holders and reduce the risk of fraud, money laundering and account misuse.

4.2. Online verification tools may be used during registration, deposits, withdrawals or later account reviews.

4.3. Where electronic checks are not sufficient, the Company may request additional information or documents, including:

• proof of identity;
• proof of residential address;
• payment method ownership information;
• evidence explaining the source of funds;
• other documents reasonably required to complete verification.

4.4. Account services or payments may be restricted until the requested verification has been completed.

5. Withdrawal controls

5.1. Withdrawal activity is reviewed against transaction limits and risk indicators.

5.2. Card withdrawals and bank transfers above USD 3,000 in a single transaction require additional checks and management approval before processing.

5.3. A Player may submit no more than three withdrawal requests per day.

5.4. The standard combined daily withdrawal limit under this policy is USD 9,000.

5.5. Enhanced Due Diligence may be required where withdrawals exceed:

• USD 3,000 during a single 24-hour period; or
• USD 9,000 during a 90-day period.

5.6. Enhanced Due Diligence may involve additional proof of identity, address, payment ownership or source of funds.

6. Cash transactions

6.1. Lussurio does not operate with physical cash. Deposits and withdrawals are processed through supported electronic payment methods.

6.2. Removing cash handling reduces risks associated with counterfeit currency and unrecorded transactions.

7. Transaction monitoring

7.1. Account systems record deposits, withdrawals, wagers and other relevant transaction activity.

7.2. Account histories are reviewed regularly for indicators connected with fraud, money laundering and responsible gambling concerns.

7.3. Unusual betting or winning patterns may be compared with support or telephone records to identify possible collusion, internal misconduct or other improper activity.

7.4. Reviews may consider transaction size, frequency, payment methods, wagering behaviour, account links and inconsistencies in customer information.

8. High-risk and politically exposed customers

8.1. The Company maintains records of customers identified as high risk or politically exposed.

8.2. These accounts are subject to more detailed checks and may be reviewed more frequently.

8.3. Additional monitoring may also apply to customers connected with higher-risk jurisdictions, unusual sources of funds or complex transaction patterns.

9. Staff conduct and internal investigations

9.1. Suspected misconduct by an employee is reviewed under the Company’s internal investigation and disciplinary procedures.

9.2. Where transaction fraud, collusion or another serious breach is suspected, temporary suspension may be used while the matter is investigated.

9.3. Any disciplinary action is carried out in accordance with employment requirements and the employee’s contractual obligations.

10. Security and operational monitoring

10.1. Lussurio applies monitoring procedures to systems, equipment, employees, communications and transactions.

10.2. These controls are intended to protect customer information, maintain accurate records and identify suspicious activity.

Call recording

10.3. Telephone calls may be recorded where permitted. Call recordings may be used for:

• staff training;
• confirming transaction or wagering instructions;
• reviewing the timing and placement of activity;
• protecting customers and the Lussurio brand;
• detecting possible collusion between customers and employees.

11. Information and system protection

11.1. Lussurio applies encryption and access controls to protect information handled through a remote, non-face-to-face service.

11.2. Access to shared systems and stored information is limited to authorised personnel and may be protected by passwords or other security measures.

11.3. Data storage and backup procedures are used to reduce the risk of information loss and prevent access by unauthorised parties.

11.4. Information is encrypted where reasonably possible and appropriate for the system or data involved.

12. Fraud, match manipulation and suspicious events

12.1. The Company’s account rules prohibit fraud, cheating, use of inside information, manipulation of events and activity connected with match-fixing.

12.2. Where suspicious conduct is identified, Lussurio may:

• review the affected account and transactions;
• request further verification;
• restrict account access or payments;
• preserve relevant records;
• cooperate with regulators, payment providers or sporting authorities;
• report suspected criminal activity where required.

12.3. Customers will not be informed where doing so could interfere with a criminal, regulatory or internal investigation.

13. Checks on business partners

13.1. Lussurio carries out due diligence before entering into certain commercial relationships.

13.2. A review may include:

• ownership and management structure;
• company registration information;
• registered and operating addresses;
• relevant contact details;
• the nature of the proposed business relationship.

13.3. Non-disclosure agreements may be used where appropriate. Records of completed checks are retained in accordance with internal procedures and applicable legal requirements.

14. Player responsibilities

14.1. Players must provide genuine, accurate and current information during registration and verification.

14.2. Accounts and payment methods must not be used on behalf of another person or for the movement of funds without a genuine gambling purpose.

14.3. A Player may be asked to explain unusual account activity or provide documents confirming the lawful source and ownership of funds.

14.4. Failure to complete required checks may result in transaction delays, account restrictions or closure in accordance with the Website Terms and Conditions.