This Anti-Money Laundering and Know Your Customer Policy (the "Policy") explains how Lucky Boom (run at dennisebben.nl by MAIREKE LIMITADA, a Costa Rican company licensed by the Anjouan Offshore Financial Authority) prevents money laundering, terrorist financing and similar crime. It applies to every player, transaction and account at dennisebben.nl. By registering and using our services you confirm that you have read, understood and accepted it.

1. Why this Policy exists

Lucky Boom holds a licence from the Anjouan Offshore Financial Authority. Under international AML/CFT (Counter Financing of Terrorism) standards and our licence conditions, we must use proportionate controls to detect, prevent and report activity that could be money laundering or terrorist financing.

The Policy is meant to:

• Set out what Lucky Boom and its players must do about identity checks and source-of-funds checks;
• Say when, how and why we collect, verify and keep personal and financial documents;
• Explain how we monitor transactions over time;
• State what happens if the rules are not followed, including limits on or closure of an account;
• Describe how we report suspicious activity.

It applies to all employees, contractors and third-party providers working for Lucky Boom, and to all registered players at dennisebben.nl.

2. Key terms

• AML — Anti-Money Laundering: laws and procedures that stop criminals from disguising illegally obtained money as legitimate income.
• CFT — Counter Financing of Terrorism: measures that stop money from backing terrorist activity.
• KYC — Know Your Customer: how we confirm a player's identity, address and, where needed, the source of their funds or wealth.
• CDD — Customer Due Diligence: the standard checks for every player.
• EDD — Enhanced Due Diligence: extra, deeper checks for higher-risk players or transactions.
• PEP — Politically Exposed Person: someone with a prominent public role, now or before, including close associates and family.
• SAR — Suspicious Activity Report: a formal report, internal or external, when we suspect money laundering or terrorist financing.
• MLRO — Money Laundering Reporting Officer: the person at Lucky Boom who receives and assesses internal SARs and makes external disclosures when needed.

3. How we judge risk

We use a risk-based approach: each player and each transaction gets a risk level, and our checks match that level. Not everyone is looked at equally closely, but everyone goes through at least standard CDD before a withdrawal is approved.

Our assessment looks at things like:

• Where the player lives or which nationality they hold;
• Which payment methods and currencies they use;
• How often and how much they deposit and withdraw compared with their stated income;
• How they play;
• Whether they are a PEP or on a sanctions list;
• Earlier suspicious activity or flagged transactions;
• The source of funds they declare.

If risk signs are high we apply EDD and may ask for more documents before paying out or continuing service.

4. Standard KYC (CDD)

4.1 When we ask for KYC

We can ask for identity documents at any time after registration, and we always need full KYC before approving a withdrawal. Please verify early so you are not waiting later. KYC can also start because of:

• Total deposits reaching an internal risk threshold;
• A withdrawal request of any size;
• A transaction pattern that does not match earlier activity;
• A PEP identification or a sanctions-database match;
• Any sign of suspected money laundering or fraud.

4.2 Standard documents

For standard CDD we need from every player:

• Proof of Identity (POI) — a clear, full-colour copy of a valid government-issued photo ID: national identity card, passport or driving licence. It must not be expired, must show your full legal name, date of birth and photo, and all four corners must be readable.
• Proof of Address (POA) — a document from the last three months that confirms where you live: a utility bill (gas, electricity, water or landline), a bank statement, a government letter or a council tax statement, showing your full name and current address.
• Proof of Banking Option (POPM) — proof that the payment method is yours. For bank cards, a photo or screenshot with the card number (middle eight digits covered), your name and the expiry date; for e-wallets or bank transfers, a screenshot of the account with your name and account details usually does it.

4.3 Selfie and liveness check

Sometimes we ask for a selfie with your ID, or a liveness check in our verification system, to confirm that the person sending the documents is the person on the ID and the registered account holder.

4.4 How to send documents

Upload KYC documents in your account profile or email them to support@dennisebben.nl. Our 24/7 live chat can guide you through it live. Documents must be readable, unaltered and complete; we may reject any that look manipulated, cropped or tampered with.

4.5 Result and timing

We process standard KYC quickly. With complete, satisfactory documents, verification normally fits our published payout approval window of two business days. If we need more, we contact you directly. While a review is open, withdrawals wait until KYC is completed.

5. Enhanced checks (EDD)

If a player or transaction looks higher-risk we apply EDD. It is not a punishment but a legal and regulatory duty. On top of CDD it may need one or more of:

5.1 Source of funds (SOF)

We may ask you to show where the money you gamble with came from. Examples of acceptable evidence:

• Recent payslips or an employment contract showing your salary;
• Bank statements with regular salary payments or the receipt of the money used;
• A letter from an accountant or employer confirming your income;
• Papers for an inheritance, a property sale or investment dividends;
• Business accounts or tax returns if you are self-employed.

5.2 Source of wealth (SOW)

With very high volumes, or when a player's total wealth needs a closer look, we may ask for Source of Wealth documents. This is wider than SOF: it covers how the player built up their assets, not only where the deposit came from.

5.3 PEP and sanctions screening

We screen all players against PEP lists and international sanctions databases when they register and continuously afterwards. A PEP or sanctions match triggers EDD automatically. Lucky Boom may refuse to open, or may close, the account of anyone on a sanctions list or whose risk as a PEP is unacceptable.

5.4 Watching high-value players

Players who use the High Roller Bonus (deposits of €500 or more), or who come close to the weekly withdrawal cap of €20,000 or the monthly cap of €50,000 for non-jackpot wins, get closer transaction monitoring. For jackpot wins, which sit outside the monthly cap, we may ask for more source-of-funds proof before paying the full amount.

6. Monitoring over time

KYC does not end after one check. We monitor every account for as long as you play with us, including by:

• Reviewing deposits and withdrawals, live and afterwards, against your stated profile;
• Comparing deposit and withdrawal patterns with the published limits (minimum deposit €20, minimum withdrawal €40, weekly cap €20,000, monthly cap €50,000);
• Spotting unusual betting, such as large quick deposits followed at once by withdrawal requests with hardly any play;
• Detecting structuring, for example splitting deposits to stay under internal thresholds;
• Re-verifying identity and address from time to time, especially after account details change or after a quiet spell followed by high-value activity;
• Cross-checking VIP status claims: players who ask us to match a VIP status with screenshots from another operator may get extra scrutiny.

If monitoring shows activity that does not fit your profile or looks suspicious, the account goes to internal review and withdrawals or play may be paused until we have investigated.

7. Suspicious activity and reporting

7.1 Internal reports

Anyone on the compliance or operations team who spots or suspects money laundering, terrorist financing or related crime must report it at once to the MLRO under the internal SAR procedure. The MLRO assesses it, decides whether suspicion is justified and whether to make an external disclosure.

7.2 External disclosure

If the MLRO finds reasonable grounds for suspicion, a report goes to the appropriate financial intelligence unit or regulator, as our Anjouan licence and international standards require, without telling the player (the "tipping-off" rule).

7.3 No tipping off

Tipping off is strictly forbidden. No employee, contractor or representative may tell a player or anyone else that a SAR or an AML investigation exists. A breach is a serious disciplinary matter and may be a crime.

7.4 Red flags

Examples of activity that can lead to an internal review or a SAR (illustrative, not complete):

• Repeated minimum deposits (€20) in quick succession to build a larger total without a single large deposit being reviewed;
• Deposits through several payment methods or cards with no clear link to the player's verified account;
• A withdrawal request of €40 or more straight after a deposit, with almost no real play in between;
• A mismatch between declared occupation or income and deposit or wagering volumes;
• A player who cannot or will not provide satisfactory KYC documents in reasonable time;
• Trying to exploit bonus terms, free spins or rakeback credits in a way that does not fit genuine recreational play;
• Third-party deposits, where the money seems to come from a payment method that is not the registered player's;
• Activity that looks like chip dumping or collusion in live casino or sports betting;
• Requests to transfer an account balance to someone else.

8. Payments by others

We do not accept deposits from, or pay out to, payment methods that do not belong to the registered account holder. Deposits must come from a method in the account holder's name, and withdrawals go back to the same method wherever possible.

If the account holder's name and the payment method do not match, we ask for Proof of Banking Option documents before processing. Continued use of third-party payment methods, or an unsatisfactory explanation, can lead to suspension and escalation to the MLRO.

9. Keeping records

We keep KYC documents, transaction records, account activity logs and SAR-related records for at least five years from the last transaction on an account, or longer if our licence or the law requires. They are stored securely and the MLRO and compliance team can access them for audit and reporting.

KYC documents and personal data are handled under our Privacy Policy. We collect only what is necessary, keep it only as long as needed and use it only for compliance, fraud prevention and providing our services.

10. What we ask of players

By registering an account at dennisebben.nl you confirm and promise that:

• You are at least 18 years old;
• You are the only registered user of your account and will not let anyone else use it for you;
• All money you deposit at Lucky Boom comes from lawful sources and is not the proceeds of crime;
• You will not use the site to launder money, to help finance terrorism or for any other illegal activity;
• Everything you tell us and every document you send at registration or during KYC is accurate, complete and up to date;
• You will tell us promptly if a registered detail changes, such as your name, address or payment methods;
• You understand that if you do not cooperate with KYC requests, your account may be restricted or closed and withdrawals held back pending regulatory review.

11. If the rules are not followed

If a player does not provide satisfactory KYC documents within reasonable time, or we decide that an account carries an unacceptable AML or fraud risk, Lucky Boom may take any or all of these steps:

• Pause deposits and withdrawals until verification is done;
• Void bonus funds or rakeback credits on the account;
• Close the account for good;
• Hold the balance until regulators advise or we find that the money is lawful;
• Report the matter to the financial intelligence authority or law enforcement, as our licence requires.

We act in good faith and, where we can, give you a chance to fix a documentation problem before any irreversible step. If the law requires immediate action, for example with a confirmed sanctions match, we may act at once and without notice.

12. Responsible gambling and AML together

Our AML and responsible gambling work run side by side. If monitoring shows behaviour that might point to problem gambling (more frequent deposits, big deposits followed by distressed withdrawal requests, or patterns suggesting someone is playing beyond their means), we share it with our responsible gambling team. Likewise, responsible gambling signals can start an AML review, for instance when a player says they cannot afford losses but makes high-value deposits.

If you want to set limits, take a break or find help with gambling problems, our 24/7 support team is available by live chat or at support@dennisebben.nl at any time.

13. Staff training

Every Lucky Boom employee and contractor who handles player accounts, transactions or compliance gets AML and KYC training for their role: spotting suspicious activity, internal reporting, the tipping-off ban and this Policy. Training is given at the start and refreshed regularly when guidance or procedures change.

14. Reviewing this Policy

Our compliance function reviews this Policy at least once a year, and more often if licence conditions, the law or our risks change. The current version is published at dennisebben.nl and replaces all earlier ones. Please look at this page now and then.

15. Contact

Questions about this Policy, our KYC steps or a verification request you received? Contact us:

We want Lucky Boom to be safe, fair and legally compliant. This Policy reflects that, and we thank our players for helping us keep it that way.