AML Policy

Lootbox, owned and operated by LOOTBOX LTD (HE 466358), with its registered office at 81 Griva Digeni, MARINOS COURT, 3rd Floor, Flat 301, 6043, Larnaca, Cyprus, is unwaveringly committed to upholding the highest standards of integrity in its operations. In accordance with international best practices and applicable legal frameworks, Lootbox adheres to a robust Anti-Money Laundering (AML) regime to prevent its platform from being exploited by money launderers and other individuals or entities engaged in illicit activities. Our unwavering commitment is to ensure that all activities occurring on the platform remain transparent, lawful, and secure.

Objective of the Policy

The core objective of this AML Policy is to establish a fortified safeguard within Lootbox to combat money laundering (ML) activities and other financial crimes. This policy sets forth measures that ensure all stakeholders, including employees, customers, and partners, operate in full compliance with applicable AML laws and regulations. Lootbox seeks to preserve the integrity of its platform and promote trust within the global financial system.

Governance and Oversight

To ensure the rigorous enforcement of this policy, Lootbox has appointed a dedicated AML Compliance Officer (AMLCO), who holds paramount responsibility for the prevention of money laundering. The AMLCO, reporting directly to senior management, ensures that all necessary actions are implemented to mitigate risks. Continuous oversight is performed through senior-level management reviews and comprehensive audits.

AML Compliance Framework

Lootbox’s AML Program is meticulously designed in alignment with:

• EU Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering and terrorist financing.

• EU Regulation 2015/847 on the integrity of fund transfers within the EU.

• BE Law of 18 September 2017 on measures aimed at curbing money laundering and the use of cash.

• Comprehensive sanctions imposed by the European Union against individuals and entities linked to unlawful activity.

Know Your Customer (KYC) and Enhanced Due Diligence

At Lootbox, an integral component of our AML strategy is the adoption of stringent Know Your Customer (KYC) protocols. We partner with Sumsub, an industry leader in identity verification, to authenticate the identities of all customers. The process includes:

• Verification of official government-issued documents such as passports, national ID cards, or driving licenses.

• Real-time liveness check to ensure authenticity and verification.

• Proof of address verification via recognized documentation, including utility bills or bank statements issued within the last three months.

In addition, ongoing monitoring is conducted to maintain current customer data, particularly for those deemed high-risk, ensuring that changes in behavior or circumstance are identified promptly.

Transaction Monitoring and Risk-Based Approach

Lootbox has instituted a multi-tiered system for transaction monitoring, powered by advanced technological tools, including AMLBot, to detect and respond to suspicious activities that fall outside of conventional patterns. While Lootbox performs continuous scrutiny of all transactional activity, we place enhanced focus on transactions of significant value and those that display atypical characteristics, ensuring compliance with a risk-based approach.

We monitor transactions for:

• Unusual volume or frequency of activity inconsistent with known customer profiles.

• Use of payment methods or geographical locations associated with high levels of risk.

• Complex, seemingly unstructured transactions aimed at concealing funds' origins.

• Layering or structuring techniques used to break down larger transactions.

• Unverified third-party payments or activities linked to individuals under sanctions or legal scrutiny.

These transactions are flagged for deeper investigation and, if warranted, escalated to regulatory authorities.

Screening for Illicit Activities and Tainted Funds

In our quest to preserve the integrity of our platform, we screen transactions for potential connections to:

• Terrorist financing.

• Proliferation of weapons of mass destruction.

• Sanctioned individuals or entities, including those listed by the EU, UN, or OFAC.

• Persons linked to organized crime, human trafficking, or drug smuggling.

• Other entities or individuals associated with high-risk industries or geographical regions under embargos.

Moreover, we are committed to ensuring that no problematic payments or tainted funds—such as those linked to criminal activities—enter or circulate within Lootbox’s coin pools. Transactions that fail to meet this criterion are immediately flagged and subjected to further scrutiny.

Lootbox ensures that transactions above a certain financial threshold undergo intensified monitoring, without disclosing these parameters to prevent circumvention by malicious actors.

Reporting Suspicious Activity

Lootbox adheres to a stringent process for the identification, review, and reporting of suspicious transactions. When a transaction is flagged as potentially suspicious by our monitoring systems or personnel, it is promptly escalated to our AML team for in-depth analysis. Should the AML team determine that the transaction poses a legitimate risk, it is reported to the Financial Intelligence Unit (FIU) for further investigation.

Training and Awareness

All employees of Lootbox undergo extensive training in AML procedures, with an emphasis on recognizing suspicious behavior and understanding the nuances of transaction monitoring tools such as AMLBot. Ongoing training ensures that employees remain abreast of evolving regulatory requirements and best practices in combating money laundering.

Record Keeping and Audits

To ensure full regulatory compliance, Lootbox maintains comprehensive records of all customer identification and transactional data for a minimum of 10 years. These records are securely stored and available only to authorized personnel. Internal audits are conducted regularly to evaluate the effectiveness of the AML framework, ensuring all systems, including Sumsub and AMLBot, function optimally.

Conclusion

Lootbox’s unwavering dedication to combating financial crime is reinforced by its comprehensive AML Policy. We remain vigilant in identifying, monitoring, and reporting suspicious activities to safeguard the integrity of our platform.

For further inquiries or reporting of suspicious activities, please contact: [email protected].