Introduction and Scope
This Know-Your-Customer (“KYC”) and Anti-Money Laundering / Counter-Terrorist Financing (“AML/CTF”) Policy (the “Policy”) sets out the standards and procedures applied by 3-102-960253 SRL (the “Company”), operator of https://ludivion.com (the “Platform”), to verify the identity of its players and to prevent the use of the Platform for money laundering, terrorist financing or any other unlawful purpose.
The Company is licensed and regulated by Anjouan Licensing Services Inc. (operating as Anjouan Gaming), the competent licensing and supervisory authority acting on behalf of the Autonomous Island of Anjouan under the oversight of the Anjouan Offshore Financial Authority (AOFA), pursuant to the Computer Gaming Licensing Act 007 of 2005.
This Policy is aligned with, and gives effect to, the AML & CTF Code of Conduct for Anjouan Internet Gaming Operators, the Code of Conduct for Anjouan Internet Gaming Operators, the License Conditions and the FATF Recommendations on which they are based. It applies to all Ultimate Beneficial Owners (UBOs), shareholders, directors, officers, key personnel, employees, contractors, agents and third-party service providers of the Company involved in gaming, payments or player onboarding. The Company remains fully responsible for AML/CTF compliance, including where any function is outsourced.
Core AML/CTF Principles
- Risk-Based Approach — Controls are proportionate to the money-laundering and terrorist-financing risks identified.
- Transparency — Funds and player activity must be traceable.
- Accountability — Clear responsibility for AML/CTF compliance is established at all levels of the Company.
- Cooperation — The Company cooperates fully with Anjouan Licensing Services Inc. (operating as Anjouan Gaming), AOFA and other relevant authorities.
Risk Assessment
3.1 Risk Identification
The Company maintains a documented AML/CTF risk assessment that considers, at a minimum:
- Player risk profiles (geography, behaviour, funding sources);
- Products and services offered;
- Payment methods and delivery channels;
- Jurisdictions involved, including FATF-identified high-risk countries.
3.2 Risk Mitigation and Review
Based on identified risks, the Company implements proportionate controls, applies Enhanced Due Diligence (EDD) where required, and reviews and updates the risk assessment at least annually, or upon any material change to its business, products, payment channels, customer base or applicable regulation.
Customer Due Diligence (CDD) at Registration
In line with the AML & CTF Code of Conduct for Anjouan Internet Gaming Operators, the Company conducts Customer Due Diligence (“CDD”) at the point of player registration. The following information is collected and recorded as a minimum at sign-up:
- Full legal name;
- Valid email address;
- Date of birth;
- Residential address.
No Account will be activated unless all of the above information has been provided. The player must also confirm that they are at least 18 years of age and that they accept the Company’s Terms and Conditions and this Policy.
Information collected at registration is screened against international sanctions lists, politically-exposed-person (PEP) databases and adverse-media sources, on a risk-based basis.
Enhanced Due Diligence (EDD)
5.1 Mandatory Triggers
The Company may request identity verification (KYC/EDD) at any time at its sole discretion. As a general rule, full identity verification (KYC) is required prior to the first withdrawal of funds and/or once a player's aggregate deposits or transactions reach thresholds established by the Company in accordance with applicable anti-money laundering requirements and risk-based controls.
Without limiting the foregoing, the Company will in any event conduct Enhanced Due Diligence ("EDD") on a player whenever any of the following occurs:
- Upon the player's first withdrawal request, regardless of amount;
- When the player's aggregate lifetime deposits reach USD 10,000 (or equivalent in any other currency), in accordance with the Currency Transaction Reporting requirements of the AML & CTF Code of Conduct for Anjouan Internet Gaming Operators;
- Where any elevated risk indicator or suspicious activity is identified (for example, deposits or wagering patterns inconsistent with the player's declared profile, transactions involving high-risk jurisdictions, structuring or threshold avoidance, or PEP/sanctions matches).
5.2 EDD Documentation
As part of the EDD process the player will be required to submit, at a minimum:
- A copy of a valid government-issued photo identification document (e.g. passport, national ID card or driving licence — front and back where applicable);
- A selfie or other liveness/identity confirmation as may be requested by the Company where necessary to verify the player's identity, prevent fraud, or fulfil an elevated level of due diligence;
- A recent utility bill or equivalent document confirming the player’s residential address (issued within the last three months);
- Where required on a risk-based assessment, evidence of source of funds and/or source of wealth (for example, payslips, bank statements, tax documents, sale-of-asset documents or other documentary evidence).
5.3 KYC Review and Outcomes
Once the required documents have been uploaded, the player’s Account is placed on “Temporarily Approved” status and the Company’s KYC Team has up to 24 hours to review the submission and to email the player one of the following outcomes:
- Approval;
- Rejection;
- More information needed — status unchanged.
While the Account is on “Temporarily Approved” status, the player:
- May continue to use the Platform normally for gameplay; and
- May not deposit more than EUR 500 in aggregate; and
- May not complete any withdrawal.
Where the KYC process is unsuccessful, the reason is documented and a support ticket is created in the system. The ticket number and an explanation are communicated to the player. Once all proper documents are in the Company’s possession, the Account is approved.
5.4 Restrictions Pending Completion of EDD
Where EDD has been triggered but is not yet complete, no withdrawal will be processed and the Company may restrict further financial activity on the Account, including new deposits, to the extent necessary to mitigate risk.
Document Verification Standards
Each document submitted during the KYC process is checked against the following criteria. The same set of restricted jurisdictions applies across the entire verification process and is harmonised with the Restricted-Use clause of our Terms and Conditions and the License Conditions issued by Anjouan Licensing Services Inc. (operating as Anjouan Gaming).
6.1 Proof of Identity
a. The document bears the holder’s signature (where required for the document type).
b. The country of issue/residence is not a restricted jurisdiction (see Section 7).
c. Full name matches the player’s registered name.
d. The document does not expire in the next 3 months.
e. The holder is at least 18 years of age.
6.2 Proof of Residence
a. The document is a bank statement or utility bill (or equivalent).
b. The country of residence is not a restricted jurisdiction (see Section 7).
c. Full name matches the player’s registered name and matches the name on the Proof of Identity.
d. Date of issue is within the last 3 months.
6.3 Selfie or Liveness Check (where requested)
Where the Company requests a selfie or liveness/identity confirmation as part of the KYC process:
a. The holder shown must be the same person as in the Proof of Identity.
b. Where a document-in-hand selfie is requested, the identification document held must be the same as the one provided as Proof of Identity (the photograph and document number must match).
Restricted Jurisdictions
Players who are resident in, or accessing the Platform from, any of the following jurisdictions will not be onboarded and any Account already opened will be closed in accordance with our Terms and Conditions:
- Australia and its territories;
- Austria;
- France and its territories;
- Germany;
- Netherlands and its territories, and countries that form the Kingdom of the Netherlands, including Bonaire, Sint Eustatius, Saba, Aruba, Curaçao and Sint Maarten;
- Spain;
- Union of the Comoros;
- United Kingdom of Great Britain and Northern Ireland;
- United States of America and its territories;
- All jurisdictions subject to international sanctions (including, without limitation, UN, EU, OFAC or other applicable sanctions regimes);
- All FATF-blacklisted countries; and
- Any other jurisdiction designated by the Anjouan Offshore Financial Authority (AOFA) or Anjouan Licensing Services Inc. (operating as Anjouan Gaming) as a prohibited territory.
Effective GEO-IP blocking is implemented at the Platform level to enforce these restrictions. The Company also takes reasonable steps — including obtaining legal opinions where necessary — to understand where interactive gaming is prohibited, and uses best endeavours to prevent participation in those jurisdictions.
Additional AML/CTF Measures
8.1 If a player has not passed full KYC (CDD/EDD as applicable) where triggered, they cannot make additional deposits or withdrawals.
8.2 For verified players, the Company applies the following additional controls:
- Deposit and transaction limits may vary depending on the player's account verification level, payment method, jurisdiction, risk profile, and the Company's internal AML and risk controls. The applicable limits are communicated to the player via the Account interface or upon request to Customer Support;
- Prior to any withdrawal there is a detailed algorithmic and manual check on the activity and balance of the player to verify that the amount withdrawn is the result of proper play activity on the Platform; and
- Withdrawals are paid back to the original payment method used for the deposit, save in exceptional cases approved on a risk basis.
8.3 Under no circumstances may a player transfer funds directly to another player.
8.4 The Company does not accept anonymous deposits and does not accept third-party deposits. All deposits must come from a payment method in the player’s own name.
Ongoing Transaction Monitoring
The Company operates ongoing automated and manual transaction monitoring designed to detect, among other things:
- Structuring or threshold avoidance;
- Rapid movement of funds (e.g. deposits immediately followed by withdrawal with little or no play);
- Unusual betting patterns or play behaviour inconsistent with the player’s profile;
- Activity involving high-risk jurisdictions or high-risk payment methods;
- Use of multiple accounts, identities or payment instruments by the same person.
Alerts generated by monitoring tools are reviewed by the Compliance Function and escalated for further investigation, additional EDD, restriction of the Account, or reporting, as appropriate.
Suspicious Activity and Transaction Reporting
10.1 Suspicious Activity Reports (SARs)
Where the Company knows, suspects or has reasonable grounds to suspect that funds or transactions are connected with money laundering, terrorist financing or other criminal activity, it will file a Suspicious Activity Report (SAR) with Anjouan Licensing Services Inc. (operating as Anjouan Gaming) within 24 hours of detection, together with full supporting documentation. The Company will also report to such other competent authorities as may be required by applicable law.
10.2 Currency Transaction Reports (CTRs)
All transactions, or linked transactions, exceeding USD 10,000 (or equivalent in any other currency) will be reported in accordance with the AML & CTF Code of Conduct, whether or not they are suspicious.
10.3 Tipping-Off
Employees are strictly prohibited from disclosing, directly or indirectly, to the player concerned or to any third party that a SAR has been or is being made, or that an investigation is being or may be carried out.
Record Keeping
The Company retains AML-related records for a minimum of five (5) years from the end of the customer relationship or from the date of the relevant transaction, whichever is later. The records retained include:
- CDD and EDD documentation (identification documents, proof of address, source-of-funds evidence and the underlying verification results);
- Transaction records (deposits, wagers, withdrawals);
- SARs, CTRs and internal reports;
- Audit and compliance records, including training logs and risk assessments.
Records are stored securely (with appropriate encryption and access controls) and are made readily available to Anjouan Licensing Services Inc. (operating as Anjouan Gaming) and other authorised regulators upon request.
Internal Controls and Governance
12.1 AML/CTF Policies and Procedures
The Company maintains written AML/CTF policies and procedures covering risk assessment, CDD and EDD, ongoing monitoring and reporting, record keeping and staff training. These documents are reviewed and updated at least annually and following any material regulatory or operational change.
12.2 Compliance Officer / MLRO
The Company has appointed a suitably qualified Compliance Officer who also acts as Money Laundering Reporting Officer (MLRO). The Compliance Officer is responsible for:
- Overall AML/CTF oversight and the implementation of this Policy;
- Liaison with Anjouan Licensing Services Inc. (operating as Anjouan Gaming), AOFA and other competent authorities;
- Timely review, filing and escalation of SARs and other regulatory reports;
- Periodic reporting to senior management and the Board on the effectiveness of the AML/CTF programme.
In addition to the Compliance Officer, the Company has designated a Key Person reporting to AOFA on gaming compliance matters in accordance with the License Conditions.
12.3 Staff Training
All relevant staff receive AML/CTF and KYC training:
- Upon onboarding;
- At least annually thereafter;
- Following any material regulatory or policy change.
Training covers, at a minimum, the legal and regulatory framework, the Company’s policies and procedures, recognition of red flags, the EDD process, SAR reporting obligations and the prohibition on tipping-off. Training is documented and records are retained in line with Section 11.
Data Protection and Cybersecurity
All personal data collected through the KYC and AML/CTF process is processed lawfully, fairly and transparently, and used solely for the purposes set out in this Policy and the Company’s Privacy Notice. The Company implements appropriate technical and organisational safeguards, including encryption of sensitive data at rest and in transit, role-based access controls and SSL/HTTPS transmission of any document upload.
Cybersecurity incidents that may affect the integrity or confidentiality of player data, or the security of the Platform, are reported to Anjouan Licensing Services Inc. (operating as Anjouan Gaming) within 24 hours of detection.
Independent Audit and Regulatory Inspection
The Company’s AML/CTF programme is subject to an annual independent audit assessing policy effectiveness, regulatory compliance, internal controls and the adequacy of staff training. Material findings are reported to senior management together with a remediation plan.
Anjouan Licensing Services Inc. (operating as Anjouan Gaming) reserves the right to conduct inspections and audits at any time. The Company will cooperate fully with any such inspection or audit and will produce records, systems and staff for review as required.
Reporting of Material Changes and Incidents
In accordance with the License Conditions and the Code of Conduct for Anjouan Internet Gaming Operators, the Company will:
- Notify Anjouan Licensing Services Inc. (operating as Anjouan Gaming) of any change in beneficial ownership of 10% or more within 10 business days, and of any material change to ownership, control, business structure or operations within 7 calendar days;
- Notify the licensor if any gaming or gambling licence held by the Company or any associated person is suspended or terminated in any jurisdiction;
- Report serious incidents or problems affecting operations or the reputation of the Autonomous Island of Anjouan within 3 working days;
- Report material changes to information previously provided during the licence application or thereafter, where relevant to suspension or revocation considerations.
Continuous Improvement
The Company monitors regulatory developments and industry best practice, and may adopt approved technological solutions (including AI-based monitoring, document verification and behavioural analytics) to strengthen its AML/CTF programme, subject to regulatory approval where required.
Enforcement
Non-compliance by any employee, contractor, agent or third-party service provider with this Policy is treated as a serious matter and may result in disciplinary action, termination of engagement and, where appropriate, referral to law-enforcement authorities. Non-compliance with the regulatory framework that underpins this Policy may also result in financial penalties, suspension or revocation of the Company’s gaming licence by Anjouan Licensing Services Inc. (operating as Anjouan Gaming).
Acknowledgement
This Policy is formally acknowledged and adopted by 3-102-960253 SRL as a condition of its licensure under the Computer Gaming Licensing Act 007 of 2005 and the License Conditions issued by Anjouan Licensing Services Inc. (operating as Anjouan Gaming). Any question regarding this Policy should be directed to the Company’s Compliance Officer.