This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of LolaJack Casino, operated at lola-jack.co ("LolaJack", "we", "us", "our"), to prevent money laundering, terrorist financing, and related financial crime. LolaJack holds an international gaming licence and operates in full compliance with the 5th Anti-Money Laundering (AML) Directive. All customers ("you", "your") who register and transact on lola-jack.co are subject to this Policy.
LolaJack is operated under an international gaming licence that requires adherence to the 5th AML Amendment and associated anti-financial-crime obligations. This Policy has been prepared in accordance with those requirements and reflects internationally recognised standards for customer due diligence, transaction monitoring, suspicious activity reporting, and record-keeping. Where applicable law is updated, this Policy will be revised accordingly and the most current version will always be published on lola-jack.co.
The principal legislative and regulatory purposes addressed by this Policy are:
This Policy applies to:
| Term | Meaning |
|---|---|
| AML | Anti-Money Laundering — the set of laws, regulations, and procedures designed to prevent the proceeds of crime from being disguised as legitimate income. |
| KYC | Know Your Customer — the process of verifying the identity and assessing the risk profile of a customer before and during the business relationship. |
| CDD | Customer Due Diligence — standard identity and source-of-funds checks applied to all customers. |
| EDD | Enhanced Due Diligence — additional, more stringent checks applied to higher-risk customers. |
| PEP | Politically Exposed Person — an individual who holds or has held a prominent public function, or is a close associate or family member of such a person. |
| SAR | Suspicious Activity Report — a formal internal or external report of activity that may indicate money laundering or terrorist financing. |
| MLRO | Money Laundering Reporting Officer — the designated officer responsible for overseeing AML compliance and receiving internal SARs. |
| Beneficial Owner | The natural person who ultimately owns or controls the customer account or on whose behalf a transaction is conducted. |
LolaJack adopts a risk-based approach (RBA) to AML and KYC compliance. This means the level of due diligence applied to each customer and each transaction is proportionate to the assessed risk of money laundering or terrorist financing. Factors considered when assessing risk include, but are not limited to:
Risk assessments are reviewed periodically and updated whenever new information is obtained about a customer or their transactions.
LolaJack will apply CDD measures at the following points:
Standard CDD requires the customer to provide sufficient documentation to allow LolaJack to:
Regardless of the method or currency used, LolaJack will require completion of full KYC verification before processing any withdrawal request. In addition, KYC may be triggered at earlier points based on cumulative transactional activity or risk indicators identified by our compliance team. No withdrawal — whether fiat or cryptocurrency — will be released until the customer's identity has been satisfactorily verified.
To satisfy the identity verification requirement, customers must submit clear, unaltered copies or photographs of valid documents. Acceptable documents include:
All documents must be in colour where possible, fully legible, and must show all four corners. Documents in languages other than English may require a certified translation at LolaJack's discretion.
Where a customer is assessed as higher risk, LolaJack will apply Enhanced Due Diligence measures in addition to standard CDD. EDD will be triggered in the following circumstances:
EDD measures may include one or more of the following:
Where EDD is required, the customer will be notified via the email address associated with their account or through the live chat function at lola-jack.co. The account may be temporarily restricted pending completion of EDD checks.
LolaJack may at any time request evidence of the source of funds used to deposit on lola-jack.co and, where appropriate, evidence of the broader source of the customer's wealth. This is distinct from identity verification and is a separate compliance obligation.
Source of funds documentation helps LolaJack establish that the money deposited on the platform has originated from a legitimate activity. Examples of acceptable source of funds evidence include:
For cryptocurrency deposits, LolaJack may use blockchain analytics tools to assess the origin of funds. Customers depositing via any of the twelve accepted cryptocurrencies (BTC, ETH, USDT, USDC, LTC, XRP, BNB, ADA, SOL, TRX, DOGE, BCH) should be aware that the traceability of on-chain transactions forms part of our compliance review process. Funds traced to high-risk sources, darknet markets, mixing services, or sanctioned addresses will result in account suspension and a report to the relevant authority.
KYC verification is not a one-time event. LolaJack conducts ongoing monitoring of all customer accounts throughout the business relationship. This includes:
Where ongoing monitoring reveals a change in the customer's risk profile, LolaJack will apply CDD or EDD measures as appropriate, which may include requesting updated documentation or placing a temporary restriction on the account.
Any employee or contractor of LolaJack who knows, suspects, or has reasonable grounds to suspect that a customer is engaged in money laundering, terrorist financing, or any associated criminal activity must report this immediately to the designated Money Laundering Reporting Officer (MLRO) via the internal reporting procedure. Failure to make such a report is itself a criminal offence under applicable law.
The MLRO will evaluate each internal report and determine whether it is necessary to submit a Suspicious Activity Report (SAR) to the appropriate financial intelligence unit or regulatory authority. The MLRO has authority to take immediate steps to restrict or suspend an account pending investigation, and to freeze funds where there is a reasonable suspicion of criminal activity.
LolaJack is legally prohibited from informing a customer or any third party that a SAR has been filed or that an investigation is under way ("tipping off"). Customers whose accounts are restricted during a compliance review will be informed only that their account has been placed under review pending additional verification, without disclosure of the specific nature of the investigation.
The following are examples of behaviour that may trigger an internal review or SAR. This list is illustrative and not exhaustive:
LolaJack screens all customers and transactions against applicable international sanctions lists, including but not limited to those published by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and the UK Office of Financial Sanctions Implementation (OFSI). Screening is conducted at registration, at key transactional events, and on an ongoing basis as lists are updated.
Where a customer or transaction matches or closely resembles a sanctioned entity, LolaJack will immediately freeze the account, decline the transaction, and escalate the matter to the MLRO for determination and, where required, reporting to the relevant authority. LolaJack will not conduct business with any individual, entity, or jurisdiction subject to applicable sanctions.
LolaJack operates a zero-tolerance approach to providing services to individuals who are PEPs without first completing thorough Enhanced Due Diligence. A PEP is defined as an individual who holds or has held within the last twelve months a prominent public function, including but not limited to heads of state, senior politicians, senior government officials, senior judicial or military officials, senior executives of state-owned enterprises, and senior officials of political parties, together with their immediate family members and known close associates.
Where a customer is identified as a PEP:
LolaJack reserves the right to restrict, suspend, or permanently close any customer account where:
Where an account is closed under this Policy, any balance held may be withheld pending investigation and, where legally required, reported to or surrendered to the relevant authority. LolaJack will not be liable for losses arising from account restriction or closure carried out in good faith pursuant to its compliance obligations.
LolaJack maintains comprehensive records of all customer due diligence documentation, transactional data, and compliance decisions. Records are retained for a minimum of five years from the date of the last transaction or the end of the business relationship, whichever is the later, in accordance with the requirements of the 5th AML Amendment. Records are stored securely and are accessible to the MLRO and, where legally required, to relevant regulatory and law enforcement authorities.
Records retained include, but are not limited to:
Personal data collected for the purposes of AML and KYC compliance will be processed in accordance with LolaJack's Privacy Policy, which is published on lola-jack.co. Customers should be aware that LolaJack is legally required to collect and process certain personal data to fulfil its compliance obligations, and this processing takes place on the basis of legal obligation as well as legitimate interest in preventing financial crime. Customers may not object to processing carried out exclusively for AML or KYC compliance purposes.
Data will not be shared with third parties except where required by law, by a regulatory authority, by a court order, or where necessary to carry out verification through approved third-party identity and sanctions screening providers. All third-party providers engaged for this purpose are contractually bound to process data only for the specified compliance purpose and to maintain appropriate security standards.
LolaJack recognises that responsible gambling controls and AML monitoring are complementary obligations. Unusual transactional patterns may indicate not only potential financial crime but also potential problem gambling behaviour. Where our monitoring identifies either concern, appropriate action will be taken under both this Policy and our Responsible Gambling Policy.
Customers who wish to apply deposit limits, cooling-off periods, self-exclusion, or other responsible gambling tools are encouraged to contact our support team at any time via the 24/7 live chat on lola-jack.co or by emailing [email protected]. These controls do not affect LolaJack's right and obligation to conduct AML and KYC checks independently of any responsible gambling measures in place.
LolaJack ensures that all staff involved in customer onboarding, payments processing, customer support, and compliance functions receive appropriate and up-to-date AML and KYC training. Training covers:
Training is reviewed and updated at least annually and whenever there is a material change in applicable legislation or the risk environment.
This Policy is reviewed at least annually by LolaJack's MLRO and senior management, and updated as required to reflect changes in applicable law, regulatory guidance, or the operational risk environment. The current version of this Policy is always available on lola-jack.co. Customers are advised to review this page periodically. Continued use of lola-jack.co following any update to this Policy constitutes acceptance of the revised terms.
Questions or concerns relating to this Policy, or requests to understand how LolaJack's AML and KYC procedures affect your account, may be directed to our compliance and support team:
Please note that LolaJack cannot discuss the specifics of any ongoing compliance investigation, SAR, or account restriction imposed for AML or KYC reasons beyond confirming that a review is in progress.
