Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

This policy sets out Lunaris Casino's approach to preventing money laundering, terrorist financing, and related financial crimes. As a B2C provider of sportsbook and casino solutions, Lunaris is committed to maintaining the integrity of the financial system by ensuring that our technology, services, and platforms are not misused for illicit purposes.

This policy applies to:

• All Lunaris employees, contractors, and consultants.
• All products, services, and platforms provided to clients.
• All client relationships, including onboarding, monitoring, and reporting.

Lunaris Casino adheres to:

• The Financial Action Task Force (FATF) Recommendations.
• The EU Anti-Money Laundering Directives (where applicable).
• US Bank Secrecy Act (BSA) and FinCEN regulations.
• Applicable local laws in the jurisdictions where Lunaris or its clients operate.

Where conflicts exist between jurisdictions, the highest applicable standard will apply.

Lunaris Casino adopts a risk-based approach (RBA) to AML/CTF compliance. This means applying enhanced due diligence and monitoring where higher risks are identified, particularly in relation to:

• High-risk jurisdictions (as identified by FATF or national regulators).
• Politically Exposed Persons (PEPs).
• High-value or unusual transaction patterns.
• Clients with complex or opaque ownership structures.

Before entering into a business relationship, Lunaris requires all clients to undergo Know Your Customer (KYC) procedures, including:

• Verification of client legal entity, beneficial ownership, and control structures.
• Identification of directors, officers, and authorized signatories.
• Screening against sanctions lists (OFAC, UN, EU, HMT, etc.) and PEP databases.
• Assessment of the client's AML/CTF framework to ensure alignment with regulatory standards.

Enhanced Due Diligence (EDD) will be applied where higher risks are identified.

Lunaris Casino platforms are equipped with monitoring systems to:

• Detect unusual betting activity, abnormal deposit/withdrawal patterns, or attempts at structuring transactions.
• Flag transactions involving high-risk jurisdictions or counterparties.
• Provide clients with automated alerts, risk scoring, and reporting capabilities.

• Lunaris staff must immediately escalate any suspicious activity to the AML Compliance Officer (MLRO).
• Where required by law, suspicious activity reports (SARs/STRs) will be filed with the relevant Financial Intelligence Unit (FIU).
• Lunaris will fully cooperate with regulators and law enforcement agencies in AML/CTF investigations.

• Board of Directors: Responsible for overall compliance oversight.
• AML Compliance Officer (MLRO): Manages AML/CTF program, reporting obligations, and staff training.
• Employees: Required to follow this policy, complete training, and escalate suspicious activity.

All relevant employees will undergo annual AML/CTF training, including:

• Identifying red flags in sports betting and casino activity.
• KYC/CDD best practices.
• Proper handling of suspicious activity and escalation protocols.

In accordance with FATF and local regulations, Lunaris Casino will retain:

• KYC documentation for at least 5 years after client relationship termination.
• Transaction and monitoring logs for a minimum of 5 years.
• Internal audit trails and compliance reports.

This policy will be reviewed annually by the AML Compliance Officer and approved by the Board of Directors, or more frequently if regulatory requirements change.