AML Policy

Table of Content

Purpose of the AML Policy

Our primary aim is to provide top-tier security for all Lucky Pays users and clients. To this end, we employ a three-tier verification process to authenticate customer identities, ensuring the accuracy of registered information and confirming that payment methods belong to the account holder. This framework is designed to prevent money laundering effectively. Security protocols are adjusted based on factors such as customer nationality, payment methods, and withdrawal preferences.

Lucky Pays takes practical steps to manage and reduce money laundering risks, committing adequate resources to this effort.

We adhere to rigorous AML standards aligned with EU regulations and compliance obligations. Both management and staff are obligated to uphold these measures to block the exploitation of our platform for illicit financial activities.

The AML framework at Lucky Pays aligns with:

EU Directive 2015/849 on preventing the financial system’s use for money laundering.
EU Regulation 2015/847 regarding details accompanying fund transfers.
EU sanctions and restrictive measures targeting specific individuals, goods, and dual-use technologies.
Belgian Law of 18 September 2017 on countering money laundering and restricting cash transactions.

What Constitutes Money Laundering

Money laundering includes:

Transforming or moving assets, particularly funds, with awareness of their criminal origins, to mask their illicit source or shield individuals from legal repercussions.
Hiding or altering the true characteristics, origin, location, or ownership of assets derived from crime.
Obtaining, holding, or utilizing assets known to stem from criminal acts.
Engaging in, attempting, or supporting any of the aforementioned activities.

Such actions are classified as money laundering regardless of whether the underlying crimes occurred within another EU country or outside the EU.

AML Structure at Lucky Pays

Per AML regulations, oversight of money laundering prevention is assigned to SIMBA N.V.’s top management. An Anti-Money Laundering Compliance Officer (AMLCO) is also appointed to implement and monitor AML policies, reporting directly to senior leadership.

AML Policy Updates and Execution

Significant revisions to the AML policy require approval from SIMBA N.V.’s general management and the AMLCO.

Three-Tier Verification Process

Tier One Verification

All users must complete Tier One Verification to access withdrawals. This involves submitting a form with personal details: full name, birth date, gender, country of residence, and complete address. Requirements may differ based on payment type, transaction size, or user nationality.

Tier Two Verification

Deposits exceeding €2,000 or any withdrawal trigger Tier Two Verification. Users must provide a photo of a valid ID (e.g., passport or driver’s license) alongside a handwritten note displaying a six-digit random code. An automated check confirms the data’s consistency, and if it fails, proof of residence (e.g., a utility bill) may be requested.

Tier Three Verification

Transactions exceeding $5,000 in deposits or withdrawals, or transfers over $3,000 to another user, require Tier Three Verification. Users must submit evidence of their wealth’s source, such as employment records or inheritance documentation.

Know Your Customer (KYC) and Identification

Verifying customer identities at the outset of a business relationship is essential for AML and KYC compliance. This entails:

Providing a photo of an ID (e.g., passport or license) with a handwritten six-digit code, plus a separate facial photo.
Ensuring all ID details are legible (except sensitive data like ID numbers, which may be obscured).
Allowing staff to perform extra checks when warranted.

Address Confirmation

Address verification relies on dual electronic checks across separate databases. If these checks fail, users must submit a recent utility bill or official government document proving residency.

Source of Funds Verification

Deposits above €5,000 require proof of funds’ origins, such as business ownership, salary, or investments. If legitimacy cannot be established, further documentation may be sought. Large, unexplained deposits may lead to account suspension, with users prompted to complete verification. Bank or credit card details may also be requested for added scrutiny.

Initial Step One Document

Users access a form through the settings page to input their full name, nationality, gender, and birth date. This data is securely stored, with staff conducting additional reviews as needed.

Risk Management Approach

Lucky Pays classifies countries into three risk levels:

Low Risk (Region One): Standard three-tier verification applies.
Medium Risk (Region Two): Lower thresholds apply—Tier Two at $1,000 for deposits/withdrawals or $500 for transfers; Tier Three at $2,500 for deposits/withdrawals or $1,000 for transfers.
High Risk (Region Three): Users from these areas are prohibited, with the list updated regularly.

Enhanced Safeguards

An AI system, monitored by the AMLCO, flags unusual activity for staff review. Employees manually assess risks, watching for patterns like rapid deposit-withdrawal cycles or inconsistent payment methods. Withdrawals must match the deposit method to curb laundering risks.

Comprehensive Risk Evaluation

Lucky Pays conducts an annual “Enterprise-Wide Risk Assessment” (EWRA) to pinpoint and address operational risks, including those tied to online services. This informs our AML strategy and is refreshed yearly.

Continuous Transaction Oversight

Ongoing monitoring detects irregular or suspicious activities through:

Initial Control: Collaboration with reputable payment providers enforcing KYC standards.
Secondary Control: Staff and automated systems track customer behavior, flagging anomalies.
Tertiary Control: Manual reviews target high-risk or questionable accounts.

Suspicious Transaction Reporting

Employees are trained to identify and escalate suspicious transactions. The AML team evaluates these and determines whether to:

Notify the Financial Intelligence Unit (FIU) per legal mandates.
End the customer relationship.

Operational Procedures

AML and KYC guidelines are detailed in procedures accessible via Lucky Pays’ intranet.

Data Retention

Identification records are kept for a minimum of ten years post-relationship.
Transaction records are retained for at least ten years after execution or relationship closure.
All data is stored securely online and offline.