AML Policy

This policy applies to all players, employees, directors and business partners of Rolluck. Every player must comply with this policy as a condition of using our services.

We have appointed a Money Laundering Reporting Officer (MLRO) who is responsible for our AML programme, monitoring and reporting. The MLRO can be contacted at legal@rolluck.biz.

Our AML programme is based on a documented business-wide risk assessment, is approved by senior management and is reviewed at least once a year.

We take a risk-based approach and apply simplified (SDD), standard (CDD) or enhanced (EDD) due diligence depending on the risk, transaction and customer type.

Full KYC is compulsory when a player's aggregate lifetime deposits or withdrawals exceed EUR 2,000 (or currency equivalent), when a withdrawal of any amount is requested at our discretion, or when a transaction is deemed suspicious. Players must then provide:

• a valid government-issued photo ID (passport, driver's licence or national ID card);
• a selfie holding that ID document;
• a utility bill or bank statement issued within the last 3 months as proof of residence.

Full document requirements are set out in our KYC Policy.

We apply enhanced due diligence to higher-risk players, including Politically Exposed Persons (PEPs), players linked to high-risk jurisdictions and players with unusual activity or high volumes. This may include:

• evidence of source of funds and source of wealth, such as payslips, tax returns, business accounts or exchange statements;
• senior management approval before the relationship continues;
• more frequent reviews and ongoing monitoring.

All players are screened against international sanctions lists (including UN, EU, UK and OFAC lists), PEP databases and adverse media, both at registration and on an ongoing basis. We do not provide services to sanctioned persons or to residents of sanctioned jurisdictions.

Because we accept cryptocurrency, we apply additional controls:

• blockchain analytics to screen deposit and withdrawal addresses for links to illicit activity, mixers, darknet markets or sanctioned entities;
• withdrawals are made only to wallets owned by the verified player;
• compliance with the FATF Travel Rule where applicable;
• funds must be wagered before they can be withdrawn, to prevent the platform being used to move value.

We monitor deposits, gameplay and withdrawals for unusual patterns, such as large or rapid deposits followed by withdrawals with minimal play, structuring of transactions, collusion between accounts or activity inconsistent with a player's profile.

Where we know or suspect that funds are linked to criminal activity, we will report this to the relevant Financial Intelligence Unit as required by law. We are legally prohibited from informing the player concerned ("tipping off").

We may freeze funds, suspend accounts or refuse transactions while a matter is investigated.

We keep customer due diligence records, transaction records and internal reports for at least five years after the end of the business relationship, or longer where required by law.

All relevant employees receive AML training when they join and at least once a year, covering how to recognise and report suspicious activity.

We may refuse to open an account, suspend or close an account, or withhold funds where a player fails to provide requested information, provides false information, or where we suspect money laundering, terrorist financing, fraud or any other breach of this policy.