Aml

Introduction

Lalabet operates online gaming services and is subject to applicable anti‑money laundering and counter‑terrorist financing laws. This AML Policy sets out the framework for Lalabet to prevent the use of its platform for money laundering or the funding of terrorism. It applies to Lalabet, its employees, contractors, and any affiliated service providers, and governs all customer onboarding, payments, and account activity on Lalabet platforms.

Regulatory framework and risk‑based approach

Lalabet conducts business under the Curaçao regulatory regime and is subject to supervision by the competent financial authorities. The policy adopts a risk‑based approach consistent with international standards to identify, assess, and mitigate ML/FT risks across customers, products, channels, and geographies. Risk assessments are performed on onboarding and reviewed at regular intervals thereafter, including ongoing monitoring for risk changes. The Company classifies risk into at least the following categories: customer risk, product/offer risk, channel risk, and geographical risk.

Customer due diligence and verification

Onboarding to Lalabet requires identification and verification of the customer before establishing a business relationship. The Company shall collect and verify information to establish the customer’s identity, intended nature of the business relationship, and source of funds. Required documentation for individual customers includes:

  • Government‑issued, valid photographic identification; and
  • Proof of residential address (e.g., utility bill or equivalent issued within the last three months).

For corporate or other legal entity customers, the Company shall obtain documentation identifying the entity, its registered address, and the beneficial owners or controlling persons, together with information regarding the purpose and expected nature of the business relationship. Lalabet may request additional information or documentation to complete verification where necessary.

The Company shall assess the source of funds and, where appropriate, the source of wealth. The information and documents collected shall be retained in accordance with applicable record‑keeping requirements and data protection obligations.

Enhanced due diligence and high‑risk scenarios

Enhanced due diligence (EDD) is applied where risk indicators are identified, including, but not limited to, the following: politically exposed persons (PEPs) and their immediate family or known associates; customers located in or transacting from high‑risk or other monitored jurisdictions; complex or large‑volume transactions; unusual patterns of activity or structures that obscure ownership or beneficial control. In such cases Lalabet shall obtain additional information and documentation (for example, enhanced proof of identity, source of funds, and source of wealth) and seek senior management approval before continuing the relationship. Ongoing monitoring and transaction screening shall be intensified for high‑risk accounts, and EDD measures shall be reviewed and updated as necessary.

Ongoing monitoring and transaction monitoring

All customer activity is subject to ongoing monitoring to identify suspicious or unusual behavior. Triggers may include, but are not limited to:

  • Excessive or rapidly changing deposit activity;
  • Use of multiple payment methods or devices within a short period;
  • Geolocation or device inconsistencies with declared residence or identity;
  • Mismatch between customer information and transaction patterns;
  • Behavior that suggests masquerading or misrepresentation of ownership.

When suspicious activity is detected, Lalabet’s compliance function shall escalate the matter for investigation and take appropriate action, including potential freezing of funds pending further verification and, where required, reporting to the relevant authorities. Lalabet does not permit the use of anonymous payment methods; transactions must be attributable to the customer account holder.

Record‑keeping and data protection

All documents and data obtained in connection with verification activities, as well as related transaction data and supporting evidence, shall be stored securely and retained for the period required by applicable laws and regulatory guidance. Lalabet complies with data protection obligations, including applicable data privacy laws, and processes personal data in accordance with Lalabet’s Privacy Policy. Access to records is restricted to authorized personnel and regulatory authorities in accordance with the law.

Reporting and cooperation with authorities

Lalabet shall comply with all reporting requirements for suspicious activities or transactions. When there is reasonable ground to suspect money laundering, terrorist financing, or other illicit activity, Lalabet shall prepare and submit a suspicious activity report to the designated competent authority in accordance with statutory procedures. Lalabet may disclose information to such authorities as permitted or required by law and will not disclose confidential information beyond what is legally permissible in response to regulatory inquiries.

Governance, training, and oversight

The ultimate responsibility for Lalabet’s AML policy lies with the Company’s governance body. The Compliance program is implemented by a designated Compliance Officer who oversees AML/CFT controls, policies, and procedures. All staff receive AML/CFT training at onboarding and on a regular basis, with refresher sessions when regulatory changes occur. Training includes identification of suspicious activities, proper escalation paths, and data protection obligations.

Amendments and communications

Lalabet may modify or supplement this Policy from time to time to reflect changes in laws, regulations, or risk landscape. When updates occur, Lalabet shall communicate changes to affected customers in accordance with applicable regulatory and contractual requirements. Continued use of Lalabet services after notification constitutes acceptance of the revised Policy.

Definitions and scope

For the purposes of this Policy, the terms used herein shall have meanings consistent with applicable AML/CFT legislation and Lalabet’s Privacy Policy. The Policy covers all Lalabet platforms and services where customer accounts are opened, maintained, or used, including payments and ancillary activities related to gaming and betting operations.