Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last updated: January 2025

1. Policy Overview

LuckyBetFinder.com is committed to preventing money laundering and terrorist financing through our affiliate operations. While we do not directly handle customer funds, we recognize our responsibility to support the integrity of the UK gambling industry.

1.1 Our Role

As an affiliate marketing website, we:

  • Promote only UKGC-licensed operators with robust AML procedures
  • Maintain transparency in our business operations
  • Cooperate with law enforcement and regulatory authorities
  • Report suspicious activities when identified
  • Ensure our partners meet high compliance standards

2. Legal Framework

This policy aligns with UK legislation including:

  • Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
  • Proceeds of Crime Act 2002
  • Terrorism Act 2000
  • UK Gambling Commission's AML guidance
  • Financial Conduct Authority guidelines

3. Risk Assessment

3.1 Our Business Risk Profile

As an affiliate site, our money laundering risk is considered LOW because:

  • We don't handle customer funds or deposits
  • No direct gambling transactions occur on our site
  • We only receive legitimate affiliate commissions
  • All partner operators are UKGC-licensed
  • Our business model is transparent

3.2 Risk Factors We Monitor

  • Unusual patterns in referral traffic
  • Suspicious partner relationships
  • Irregular commission payments
  • Connections to unlicensed operators
  • Unusual geographic traffic patterns

4. Partner Due Diligence

4.1 Casino Partner Requirements

All featured casinos must demonstrate:

  • Valid UKGC license with good standing
  • Comprehensive AML policies and procedures
  • Robust KYC processes for customers
  • Regular AML training for staff
  • Appropriate technology systems for monitoring
  • Clear suspicious activity reporting procedures

4.2 Ongoing Monitoring

  • Regular license status checks
  • Review of regulatory actions or penalties
  • Assessment of AML policy updates
  • Monitoring of industry reputation
  • Annual compliance questionnaires

4.3 Partner Removal Criteria

We immediately remove partners who:

  • Lose their UKGC license
  • Receive serious AML-related penalties
  • Demonstrate poor compliance practices
  • Fail to maintain adequate KYC procedures
  • Show evidence of facilitating money laundering

5. Customer Due Diligence

5.1 Our Limited Role

While we don't conduct formal KYC on website visitors, we:

  • Verify age through mandatory age verification
  • Collect minimal personal data (email for newsletters only)
  • Monitor for suspicious website usage patterns
  • Maintain visitor logs for security purposes

5.2 Casino Partner KYC Standards

All featured casinos must implement:

  • Identity verification for all customers
  • Address verification procedures
  • Source of funds checks for high-value transactions
  • Enhanced due diligence for high-risk customers
  • Regular review of customer profiles
  • Compliance with sanctions and PEP screening

6. Suspicious Activity Monitoring

6.1 Red Flags We Monitor

  • Unusual traffic patterns from high-risk jurisdictions
  • Multiple accounts from same IP/device
  • Rapid, high-volume referrals to specific operators
  • Use of anonymizing technologies
  • Patterns suggesting coordinated activity
  • Connections to known criminal entities

6.2 Technology Systems

  • Automated monitoring of traffic patterns
  • IP address and device fingerprinting
  • Behavioral analysis systems
  • Integration with industry databases
  • Regular security and fraud assessments

7. Record Keeping

7.1 Records We Maintain

  • Partner due diligence documentation (5 years)
  • Commission payment records (5 years)
  • Suspicious activity reports (5 years)
  • Website visitor logs (90 days for security, 2 years for investigations)
  • Communication records with partners (3 years)
  • Training records (5 years)

7.2 Data Security

  • Encrypted storage of sensitive documents
  • Access controls and audit trails
  • Regular backups and disaster recovery
  • Secure disposal of expired records
  • Compliance with data protection regulations

8. Reporting Procedures

8.1 Suspicious Activity Reports (SARs)

We will file SARs with the National Crime Agency when we identify:

  • Suspected money laundering activities
  • Terrorist financing indicators
  • Serious organized crime connections
  • Unusual financial flows through our business

8.2 Reporting Process

  1. Immediate escalation to Money Laundering Reporting Officer (MLRO)
  2. Investigation and documentation of concerns
  3. Filing of SAR with NCA within required timeframes
  4. Cooperation with any subsequent investigation
  5. Internal review and process improvement

8.3 Information Sharing

We cooperate with:

  • National Crime Agency (NCA)
  • UK Gambling Commission
  • Police forces and law enforcement
  • Financial Intelligence Units
  • Industry information sharing initiatives

9. Training and Awareness

9.1 Staff Training

All team members receive training on:

  • AML/CTF legal requirements
  • Money laundering typologies in gambling
  • Suspicious activity identification
  • Reporting procedures and obligations
  • Record keeping requirements
  • Customer due diligence principles

9.2 Training Schedule

  • Initial training for all new staff
  • Annual refresher training
  • Additional training when regulations change
  • Specialized training for senior staff and MLRO
  • Industry conference participation

10. Governance and Oversight

10.1 Money Laundering Reporting Officer (MLRO)

Our MLRO is responsible for:

  • Overall AML compliance program oversight
  • Suspicious activity investigation and reporting
  • Staff training coordination
  • Regular risk assessment updates
  • Liaison with law enforcement and regulators
  • Annual compliance reporting to management

10.2 Senior Management

  • Ultimate responsibility for AML compliance
  • Quarterly review of AML policies and procedures
  • Resource allocation for compliance activities
  • Board-level oversight and reporting
  • Cultural commitment to compliance

11. Technology and Systems

11.1 Monitoring Technology

  • Real-time traffic analysis systems
  • Fraud detection algorithms
  • IP and device intelligence platforms
  • Pattern recognition software
  • Integration with sanctions screening databases

11.2 System Security

  • End-to-end encryption for sensitive data
  • Multi-factor authentication systems
  • Regular penetration testing
  • Incident response procedures
  • Secure development practices

12. International Cooperation

12.1 Information Sharing

We support international AML efforts through:

  • Cooperation with foreign financial intelligence units
  • Participation in industry initiatives
  • Sharing of best practices and threat intelligence
  • Compliance with international sanctions

12.2 Cross-Border Considerations

  • Enhanced monitoring of international traffic
  • Compliance with multiple jurisdictional requirements
  • Partnership with international compliance services
  • Regular assessment of emerging international risks

13. Sanctions and Embargo Compliance

13.1 Sanctions Screening

  • Real-time screening against UK, UN, EU, and US sanctions lists
  • Regular updates to sanctions databases
  • Enhanced due diligence for high-risk jurisdictions
  • Prohibition on business with sanctioned entities

13.2 Geographic Restrictions

  • Blocking of traffic from embargoed countries
  • Enhanced monitoring of high-risk jurisdictions
  • Regular review of geographic risk assessments
  • Compliance with UK trade restrictions

14. Independent Testing and Review

14.1 Internal Audit

  • Annual AML compliance audits
  • Testing of policies and procedures
  • Review of training effectiveness
  • Assessment of technology systems
  • Recommendations for improvement

14.2 External Review

  • Independent compliance assessments
  • Regulatory examinations when required
  • Third-party security audits
  • Industry peer reviews

15. Policy Updates and Communication

15.1 Regular Review

This policy is reviewed:

  • Annually as part of risk assessment
  • When regulations or guidance change
  • Following significant business changes
  • After suspicious activity incidents
  • Based on audit recommendations

15.2 Communication

  • Policy updates communicated to all staff
  • Public policy available on website
  • Regular awareness campaigns
  • Integration with partner communications

16. Contact Information

For AML/KYC related inquiries:

Confidential Reporting: If you need to report suspicious activity confidentially, contact our MLRO directly or use the secure reporting portal on our website.

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