AML Policy

1. General Conditions

The website www.lamabet.com (hereinafter referred to as the "Website") is owned and operated by 3-102-940953 SRL, a limited liability company duly incorporated and registered in accordance with the laws of Costa Rica, with company registration number 3102940953, and having its registered office located at San Pedro, Barrio Dent, Del Centro Cultural Costarricense Norteamericano, San José - Montes de Oca, Costa Rica (hereinafter referred to as the "Company", the "Operator", "We", "Us", or "Our").

The Website is duly licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros, under License No. ALSI-152406018-F12. The Company has successfully completed all necessary regulatory compliance procedures and holds the legal authorization to conduct gaming operations, including, but not limited to, games of chance and wagering activities via the Website.

www.lamabet1.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet2.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet3.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet4.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet5.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet6.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet7.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet8.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet9.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-play01.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-fun01.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-best.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-game.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-gold.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-play.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-win.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

www.lamabet-vip.com (hereinafter referred to as the "Website", "We", "Us", "Our", "Company", or "Operator") has passed all regulatory compliance checks and is legally authorized to conduct gaming operations involving all games of chance and wagering.

The operation of the Website is in line with the stringent regulatory standards, including comprehensive AML procedures, in line with applicable laws and regulations. To ensure Customers are adequately informed regarding the AML procedures, the Company has established a dedicated AML Policy (hereinafter referred to as the "AML Policy"), which is fully aligned with the Company's Policy for the Prevention and Combatting of Money Laundering and Terrorist Financing.

The AML Policy is an integral part of the Terms of Service, Responsible Gambling and Self-Exclusion Policy, Bonus Policy, Privacy Policy, Сookies Policy, KYC Policy, as well as any other policies, rules, guidelines, or codes of conduct that may be adopted, modified, or published by the Company on the Website from time to time. By registering a Customer Account on the Website, the Customer expressly acknowledges and agrees to be bound by all such documents, including any amendments or updates thereto, as may be revised and implemented from time to time.

Unless otherwise specified, capitalized terms used in this document shall have the same meaning ascribed to them in the General Terms.

These AML Policy/procedures encompass the following measures:

1.1 Money laundering and the financing of terrorism are some of the ever-growing threats for national and international economies throughout the world, forcing all vulnerable sectors to have measures in place for their prevention.

1.2 The Company is committed to have procedures in place for the prevention of the misuse of its Services provided to Customers for money laundering, terrorism financing, fraud and other criminal purposes.

1.3 This Policy is written based on the international standards set by the FATF and the applicable national legislation on AML inter alia:

• The European AMLD 1-6
• The Anjouan Money Laundering (Prevention) Act 008 of 2005.
• The Financial Action Task Force (FATF) Recommendations: International standards on combating money laundering and the financing of terrorism and proliferation (FATF 40 Recommendations). These are global standards followed by jurisdictions, including those operating with online gaming licenses.
• Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods.

1.4 Proper Identification of Customers, verification of the identity, monitoring of Customer activities and reporting of suspicious activities are part of the measures the Company has in place in an effort to mitigate industry related risks.

1.5 The Company is committed to the highest national and international AML and CFT standards when providing its Services and requires management and employees to follow these standards.

1.6 All employees in finding out indicators of Money Laundering such as (but not limited to):

• Unusual Betting Patterns
• Suspicious deposit and withdrawal patterns (size and frequency)
• Reliability of Card Data
• Customer verification issues and Identity Theft
• Account linkage/multiple accounting

1.7 In an effort to be compliant with the applicable rules, regulations and international standards, the Company has procedures in place to which it attains itself when providing Services to Account Holders. These procedures include:

• Know Your Customer;
• Monitoring of player activities;
• Risk management;
• Reporting of unusual transactions;
• Recordkeeping.

2. Know Your Customer Procedure

The Company has put in place Know-Your-Customer (KYC) programs as an essential element for service, risk management and control procedures.

Such programs include:

• Customer Registration/Acceptance;
• Customer Identification/Verification;
• On-going Monitoring of customers’ activity.

2.3. All Company Customers will acknowledge, undertake and agree to the following terms regarding their use of the Website, entering into trading activities with Website as a Company Customer (hereinafter referred to as the - “Customer”):

2.3.1 The Customer will comply with all relevant statutes pertaining to money laundering and proceeds from criminal activities;

2.3.2 The Company will operate under certain obligations known as “know-your-customer” obligations which grant Company the right to implement anti money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity;

2.3.3 The Customer agrees to lend full cooperation to the Company with respect to anti money laundering efforts. This involves providing information that Company requests regarding Customer Account, Website usage etc. to help Company perform its duties as dictated by applicable laws, regardless of jurisdiction;

2.3.4 The Company reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices;

2.3.5 The Company reserves the right to suspend or terminate any trading activity if there is reason to believe that services are used for activities that are deemed unlawful or fraudulent;

2.3.6 The Company has the right to use the Customer information for the investigation and/or prevention of fraudulent or otherwise illegal activities;

2.3.7 The Company has the right to share Customer information with:

• Investigative agencies or any authorized officers who are helping Company to comply with applicable law, including anti-money laundering laws and Know-Your-Customer obligations;
• Organizations that help Company provide the services it offers to its Customers;
• Government, law enforcement agencies and courts;
• Regulatory bodies and financial institutions.

More information about Know Your Customer procedure You can find in our KYC Policy.

3. Monitoring of Player Activities

3.1 Company is obliged not only to establish the identity of its Сustomers, but also to monitor account activity to determine those transactions that do not conform with the normal or expected transactions for that Customer or type of account. The Company have implemented a range of measures and procedures to ensure security and safety in these areas.

3.2 The Company is using the following measures to monitor activities of the Customers:

3.2.1 Prevention of multiple accounts

The system maintained for the monitoring of the activities comprises an IP address control uncovering any attempt to register Duplicate Accounts. Whenever a Customer requests for a withdrawal of funds from his/ her account, the system will check the presence of Duplicate Accounts and further checks whether the Customer has used a false proxy server. At the presence of Duplicate Accounts, all the accounts will be closed, and the Customer will be denied the opening of a new account.

3.2.2 Unusual activities

If the Customer has unusual deposits and gets flagged by the system, the department manager will contact the Customer to get an explanation of the abnormal use. In case no satisfactory answer or information is provided, the manager will suspend the Customer Account until necessary papers and explanations are in place. If the Customer has not provided satisfying information within 30 days, the Customer Account will be closed. The manager may proceed with the reporting of the unusual/suspicious transaction to the relevant authority.

3.2.3 Withdrawal or Pay out of funds

The Company will not Deposit withdrawn funds to another source from which it was originated unless sufficient information or documentation is provided substantiating the request.

The pay out of prizes or winnings will only be deposited on the bank account of the Customer. Transfers or Pay outs to a third-party account will not be affected unless sufficiently substantiated and to the discretion of the Company.

4. Risk Management

4.1 Prior to conducting any transaction, the Company conducts checks to ensure that the identity of the Customer does not match with any person with known criminal background, banned entities, or terrorists.

4.2 The relevant data shall be obtained from the client prior to conducting the respective transaction.

4.3 The process of risk assessment of the Customer may encompass the assessment of the Customer’s background, country of origin, source of funds and volume of transactions.

4.4 The Company may carry out enhanced due diligence with regard to Customer’s, which can be considered as high-risk based on the findings of the Company.

4.5 The Company may carry out enhanced due diligence with regard to funds the origin of which are unclear or for the transactions of higher value and frequency.

4.6 The Company shall be entitled, at its sole and absolute discretion, to conduct Customer Due Diligence (“CDD”) measures upon the occurrence of one or more of the following circumstances, including but not limited to:

• Upon the submission of an application for the creation of a Customer Account;
• Where suspicions arise regarding the authenticity or accuracy of any information or documentation provided during the onboarding process;
• Where there are reasonable grounds to suspect that the Customer may be engaged in money laundering or terrorist financing activities, or where the nature of the Customer’s profile or activity gives rise to such suspicion;
• Where any unauthorized modifications or discrepancies are detected within the Customer’s profile;
• Where a transaction or a series of linked transactions amounts to more than EUR 2,000 or its equivalent in other currencies, in which case CDD measures shall be applied automatically;

The Company reserves the right to impose restrictions on deposits originating from jurisdictions classified as high-risk

Customer Due Diligence procedures shall be triggered when the Customer’s aggregate transaction turnover equals or exceeds USD 10,000, or its equivalent in other currencies, regardless of whether such deposits or withdrawals are executed as a single transaction or through multiple linked operations.

For the purposes of this Clause, the wagering of a stake, the deposit of funds, or the withdrawal of winnings shall each constitute a “transaction”.

Periodic reviews of existing records and ongoing monitoring of the transactional patterns of regular players shall form an integral part of the CDD process.

The Company reserves the exclusive right, at its sole and absolute discretion, to conduct CDD measures with respect to any individual Customer or transaction, regardless of whether any of the triggering events or prescribed thresholds set out herein have been met.

Such right shall vest in, and remain exercisable by, the Company throughout the entire duration of the business relationship with the Customer and may be invoked at any time the Company deems necessary for the purposes of regulatory compliance, risk management, or verification of Customer identity and transactional integrity.

In circumstances where mandatory Customer Due Diligence (CDD) measures cannot be successfully completed—including, but not limited to, the Company awaiting documents or clarification from the Customer—the Customer Account shall be temporarily suspended and locked.

During this suspension period, all gaming and transactional functionalities will be disabled until the required documentation and checks are completed to our satisfaction.

The Company reserves the right to terminate the business relationship and close the Customer Account if the required CDD measures are not successfully completed within a reasonable timeframe, or if the documentation provided is deemed insufficient or fraudulent. Termination in such cases shall be due to non-compliance with applicable Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) legislative requirements.

If the Company terminates the account due to unresolved non-compliance, all funds legally owed to the Customer shall be refunded through the original payment channel.

4.7 Enhanced Due Diligence (EDD) shall be conducted in circumstances where an elevated risk of money laundering or terrorist financing is identified, in accordance with the Company’s internal risk assessment framework and applicable legal and regulatory requirements.

EDD procedures may be initiated, including but not limited to, the following scenarios:

• When the Customer is identified as a Politically Exposed Person (PEP) or has a close association with a PEP;
• When transactions involve jurisdictions classified as high-risk third countries by credible sources or competent authorities;
• When discrepancies or inconsistencies arise in the information provided by the Customer during onboarding or transactional activities;
• When the Customer’s behavior or transaction patterns deviate from the expected profile;
• When the business relationship is conducted via atypical or non-face-to-face channels.

The Company reserves the exclusive right, at its sole discretion, to apply EDD measures to any individual Customer or transaction, regardless of whether established thresholds or risk indicators have been formally met. Furthermore, the Company may impose restrictions on deposits, withdrawals, or other transactional activities originating from or connected to jurisdictions deemed high-risk.

Where EDD is applied, the Customer may be required to submit additional documentation, including but not limited to a written declaration and supporting evidence verifying the lawful Source of Funds (SOF) and/or Source of Wealth (SOW). Failure to comply with such requests may result in the suspension or termination of the business relationship, at the sole discretion of the Company.

5. Reporting Of Unusual Transactions

5.1 Any suspicious transactions or circumstances for which the transaction monitoring department has not received sufficient explanation may give rise to a report to the appropriate authority of Anjouan, Union of Comoros. The Company will hold a list of all instances in which it did not consider it necessary to report to the relevant authority. The decision not to report will need to be sufficiently justified.

6. Recordkeeping

6.1 The Company will retain the following records for five years after the end of the Customer relationship:

• Copies of, or references to, the evidence obtained of a Customer’s identity;
• Details of customer trading activities for five years from the date of the relevant transaction;
• Records of all AML/CTF training delivered;
• Details of actions taken in respect of internal and external suspicion reports;
• Details of information considered by the Compliance Department in respect of an internal report where no external report is made.

6.2 The Company will ensure that the above requirements are adhered to, and that the documents are able to be produced on request.

7. Contact Us

7.1 If You have any questions about Our AML Policy, please contact Us by email: support@lamabet.com

7.2 If You have any complaints about Our AML Policy or about the checks done on Your Account and Your Person, please contact Us by email: support@lamabet.com

7.1 If You have any questions about Our AML Policy, please contact Us by email: support@lamabet10.com

7.2 If You have any complaints about Our AML Policy or about the checks done on Your Account and Your Person, please contact Us by email: support@lamabet10.com