Terms & Conditions- Lordsexch
Lordsexch.co
Description: Initial Terms and Conditions replacing general rules
Introduction
These terms and conditions and the documents referred and linked to below (the “Terms”)
set out the basis upon which the website operated under the URL www.Lordsexch.co (the
“Website”) and its related or connected services (collectively, the “Service”)
will be provided to you.
Please read these terms very carefully as they form a binding legal agreement between you - our
customer (the “Customer”) - and us. By opening an account (the “Account”)
and using the
Service you agree to be bound by these terms, together with any amendment which may be published
from time to time.
If anything is not clear to you please contact us using the contact details below by mail only:
[email protected]
General Terms
We reserve the right to amend the terms (including to any documents referred and linked to
below) at any time. When such amendment is not substantial, we may not provide you with prior
notice. You will be
notified in advance for material changes to the terms and may require you to re-confirm
acceptance to the updated terms before the changes come into effect. If you object to any such
changes, you must
immediately stop using the service and the termination provisions below will apply. Continued
use of the service indicates your agreement to be bound by such changes. Any bets not settled
prior to the changed
terms taking effect will be subject to the pre-existing terms.
If at any time you are in any doubt about how to place bets or otherwise use the service you
should refer back to these terms or contact our customer service department (Customer Service
Department) at
[email protected]
Your Obligations
You agree that at all times when using the Service:
You are over 18 years of age (or over the age of majority as stipulated in the laws of the
jurisdiction applicable to you) and can enter into a binding legal agreement with us.
It is the User’s responsibility to check and enter this site only if the user is in a country
where it is lawful to place bets on the service (if in doubt, you should seek local legal
advice). It is your responsibility to ensure that your use of the service is legal.
When sending money to us you are authorised to do so e.g. you are the authorised user of the
debit/credit card or other payment method you use.
You will not, by participating in the Services and/or placing bets be placed in a position of
actual, potential or perceived conflict of interest in any manner.
You have never failed to pay, or attempted to fail to pay a liability on a bet.
You are acting solely on your own behalf as a private individual in a personal capacity and not
on behalf of another party or for any commercial purposes.
By placing bets you may lose some or all of your money lodged with us in accordance with these
terms and you will be fully responsible for that loss.
You must use the service for legitimate betting purposes only and must not nor attempt to
manipulate any market or element within the service in bad faith or in a manner that adversely
affects the integrity
of the Service or us.
When placing bets on the service you must not use any information obtained in breach of any
legislation in force in the country in which you were when the bet was placed.
You must make all payments to us in good faith and not attempt to reverse a payment made or take
any action which will cause such payment to be reversed by a third party in order to avoid a
liability
legitimately incurred.
You must otherwise generally act in good faith in relation to us of the service at all times and
for all bets made through the service.
Registration
You agree that at all times when using the service:
In order to protect the integrity of the service and for other operational reasons we reserve
the right to refuse to accept a registration application from any applicant at our sole
discretion and without any
obligation to communicate a specific reason.
Before using the service, you must personally complete the registration form and read and accept
these terms. In order to start betting on the service, we will require you to become a verified
Customer which
includes passing certain checks. You may be required to provide a valid proof of identification
and any other document as it may be deemed necessary.
This includes but is not limited to, a picture ID (copy of passport, driver’s licence or
national ID card) and a recent utility bill listing your name and address as proof of residence
to the minimum.
We reserve the right to suspend wagering or restrict Account options on any Account until the
required information is received. This procedure is a statutory requirement and is done in
accordance with the
applicable gaming regulation and the anti-money laundering legal requirements. Additionally, you
will need to fund your Lordsexch Account using the payment methods set out on the payment
section of our
Website.
You must provide complete and accurate information about yourself, inclusive of a valid name,
surname, address and email address, and update such information in the future to keep it
complete and accurate. It
is your responsibility to keep your contact details up to date on your account. Failure to do so
may result in you failing to receive important account related notifications and information
from us, including
changes we make to these terms. We identify and communicate with our Customers via their
Registered Email Address. It is the responsibility of the Customer to maintain an active and
unique email account, to
provide us with the correct email address and to advise Lordsexch of any changes in their email
address. Each Customer is wholly responsible for maintaining the security of his Registered
Email Address to
prevent the use of his Registered Email Address by any third party. Lordsexch shall not be
responsible for any damages or losses deemed or alleged to have resulted from communications
between Lordsexch and
the Customer using the Registered Email Address. Any Customer not having an email address
reachable by Lordsexch will have his Account suspended until such an address is provided to us.
We will immediately
suspend your Account upon written notice to you to this effect if you intentionally provide
false or inaccurate personal information. We may also take legal action against you for doing so
in certain
circumstances and/or contact the relevant authorities who may also take action against you.
You are only allowed to register one Account with the service. Accounts are subject to immediate
closure if it is found that you have multiple Accounts registered with us.
This includes the use of representatives, relatives, associates, affiliates, related parties,
connected persons and/ or third parties operating on your behalf.
In order to ensure your financial worthiness and to confirm your identity, we may use any third
party information providers we consider necessary.
You must keep your password for the service confidential. Provided that the Account information
requested has been correctly supplied, we are entitled to assume that bets, deposits and
withdrawals have been
made by you. We advise you to change your password on a regular basis and never disclose it to
any third party. Passwords must contain at least one letter, one number and one special
character and must be at
least eight characters long. It is your responsibility to protect your password and any failure
to do so shall be at your sole risk and expense. You must log out of the Service at the end of
each session. If
you believe any of your Account information is being misused by a third party, or your Account
has been hacked into, or your password has been discovered by a third party, you must notify us
immediately by
email using your registered Email Address to
[email protected]
You must notify us if your registered email Address has been hacked into, we may, however,
require you to provide additional information/ documentation so that we can verify your
identity. We will immediately
suspend your Account once we are aware of such an incident. In the meantime you are responsible
for all activity on your Account including third party access, regardless of whether or not
their access was
authorised by you.
You must not at any time transmit any content or other information on the service to another
Customer or any other party by way of a screen capture (or other similar method), nor display
any such information
or content in a frame or in any other manner that is different from how it would appear if such
Customer or third party had typed the URL for the service into the browser line;
When registering, you will be required to choose the currency in which you will operate your
account. This will be the currency of your deposits, withdrawals and bets placed and matched
into the service as
set out in these terms. Some payment methods do not process in all currencies. In such cases a
processing currency will be displayed, along with a conversion calculator available on the page.
We are under no obligation to open an account for you and our website sign-up page is merely an
invitation to treat. It is entirely within our sole discretion whether or not to proceed with
the opening of an
account for you and, should we refuse to open an Account for you, we are under no obligation to
provide you with a reason for the refusal.
Upon receipt of your application, we may be in touch to request further information and/ or
documentation from you in order for us to comply with our regulatory and legal obligations.
Restricted Use
3.1 You must not use the Service:
if you are under the age of 18 years (or below the age of majority as stipulated in the laws of
the jurisdiction applicable to you) or if you are not legally able to enter into a binding legal
agreement with
us;
to collect nicknames, e-mail addresses and/or other information of other Customers by any means
(for example, by sending spam, other types of unsolicited e-mails or the unauthorised framing
of, or linking to,
the Service);
to disrupt or unduly affect or influence the activities of other Customers or the operation of
the Service generally;.
to promote unsolicited commercial advertisements, affiliate links, and other forms of
solicitation which may be removed from the Service without notice;.
in any way which, in our reasonable opinion, could be considered as an attempt to: (i) cheat the
Service or another Customer using the Service; or (ii) collude with any other Customer using the
Service in
order to obtain a dishonest advantage;
to scrape our odds or violate any of our Intellectual Property Rights; or.
for any unlawful activity whatsoever.
3.2 You cannot sell or transfer your account to third parties, nor can you acquire a player
account from a third party.
3.3 You may not, in any manner, transfer funds between player accounts.
3.4 We may immediately terminate your Account upon written notice to you if you use the Service
for unauthorised purposes. We may also take legal action against you for doing so in certain
circumstances.
Privacy
Any information provided to us by you will be protected and processed in strict accordance with
these Terms and our Privacy Policy.
We will not reveal the identity of any person who places bets using the service unless the
information is lawfully required by competent authorities such as Regulators, the Police (e.g.
to investigate fraud,
money laundering or sports integrity issues), or by Financial Entities such as banks or payment
suppliers or as permitted from time to time pursuant to the Privacy Policy.
Upon registration, your information will
be stored in our database. This means that your personal information may be transferred outside
the European
Economic Area (EEA) to jurisdictions that may not provide the same level of protection and
security as applied within the EU or EEA. By agreeing to these Terms you agree to the transfer
of your personal
information for the purpose of the provision of the Service object of this agreement and as
further detailed in our Privacy Policy.
Your Account
We accept Accounts in multiple currencies, please refer to:
https://Lordsexch.co account balances and transactions appear in the currency selected when the
account was originally opened.
We do not give credit for the use of the service.
We may close or suspend an Account and refund any monies held if you are not or we reasonably
believe that you are not complying with these Terms, or to ensure the integrity or fairness of
the Service or if
we have other reasonable grounds to do so. We may not always be able to give you prior notice.
We reserve the right to suspend an account without prior notice and return all funds.
Contractual obligations already matured will however be honoured.
We reserve the right to refuse, restrict, cancel or limit any wager at any time for whatever
reason, including any bet perceived to be placed in a fraudulent manner in order to circumvent
our betting limits
and/ or our system regulations.
If we close or suspend your account due to you not complying with these terms, we may cancel
and/or void any of your bets.
If any amount is mistakenly credited to your account it remains our property and when we become
aware of any such mistake, we shall notify you and the amount will be withdrawn from your
Account.
If, for any reason, your account goes overdrawn, you shall be in debt to us for the amount
overdrawn.
You must inform us as soon as you become aware of any errors with respect to your Account.
Customers have the right to self-exclude themselves from https://Lordsexch.co. These requests have to
be received from the Customer’s Registered Email Address and have to be sent to
[email protected]
Customers may set limitations on the amount they may wager and lose. Such request has to be sent
from the Customer’s Registered Email Address to
[email protected]
Implementation and increasing of limits shall be processed diligently, however, any request for
removing or reducing limitations shall be done after a cooling-off period of seven days
following your request.
You cannot transfer, sell, or pledge Your Account to another person. This prohibition includes
the transfer of any assets of value of any kind, including but not limited to ownership of
accounts, winnings,
deposits, bets, rights and/or claims in connection with these assets, legal, commercial or
otherwise. The prohibition on said transfers also includes however is not limited to the
encumbrance, pledging,
assigning, usufruct, trading, brokering, hypothecation and/or gifting in cooperation with a
fiduciary or any other third party, company, natural or legal individual, foundation and/or
association in any way
shape or form.
Should you wish to close your account with us, please send an email from your Registered Email
Address to
[email protected]
Deposit of Funds
You may deposit funds into your Account by any of the methods set out on our Website. All
deposits should be made in the same currency as your Account and any deposits made in any other
currency will be
converted using the daily exchange rate obtained from www.xe.com, or at our own bank’s
prevailing rate of exchange following which your Account will be deposited accordingly.
Fees and charges may apply to customer’s deposits and withdrawals. Fee and charge details
can be found here: https://www.Lordsexch.co/payment-options. Any deposit made to an account
which is not rolled
over (risked) three times will incur a 3% processing fee and any applicable withdrawal fee. You
are responsible for your own bank charges that you may incur due to depositing funds with us.
Exceptions to this
rule are outlined in our “Payment Options” pages.
Lordsexch is not a financial institution and uses a third party electronic payment processors to
process credit and debit card deposits; they are not processed directly by us. If you deposit
funds by either a
credit card or a debit card, your Account will only be credited if we receive an approval and
authorisation code from the payment issuing institution. If your card’s issuer gives no
such authorisation,
your account will not be credited with those funds.
Your funds are deposited and held in the respective client account based on the currency of your
account.
We are not a financial institution and you will not be entitled to any interest on any
outstanding account balances and any interest accrued on the client accounts will be paid to us.
Funds originating from ill-gotten means must not be deposited with us.
Withdrawal of Funds
You may withdraw any or all of your account Balance within the transaction maximums as shown on
the Website here: https://www.Lordsexch.co/payment-options. Note that fees may apply as
outlined in section
7.b.
All withdrawals must be made in the currency of your account, unless otherwise stipulated by us.
We reserve the right to request documentation for the purpose of identity verification prior to
granting any withdrawals from your Account. We also reserve our rights to request this
documentation at any time
during the lifetime of your relationship with us.
All withdrawals must be made to the original debit, credit card, bank account, method of payment
used to make the payment to your Lordsexch.co Account. We may, and always at our own
discretion, allow you to
withdraw to a payment method from which your original deposit did not originate. This will
always be subject to additional security checks.
Should you wish to withdraw funds but your account is either inaccessible, dormant, locked or
closed, please contact our Customer Service Department at
[email protected]
Payment Transactions and Processors
You are fully responsible for paying all monies owed to us. You must make all payments to us in
good faith and not attempt to reverse a payment made or take any action which will cause such
payment to be
reversed by a third party in order to avoid a liability legitimately incurred. You will
reimburse us for any charge-backs, denial or reversal of payment you make and any loss suffered
by us as a consequence
thereof. We reserve the right to also impose an administration fee of $50, or currency
equivalent per charge-back, denial or reversal of payment you make.
We reserve the right to use third party electronic payment processors and or merchant banks to
process payments made by you and you agree to be bound by their terms and conditions providing
they are made
aware to you and those terms do not conflict with these Terms.
All transactions made on our site might be checked to prevent money laundering or terrorism
financing activity. Suspicious transactions will be reported to the relevant authority depending
on the jurisdiction
governing the transaction.
Errors
In the event of an error or malfunction of our system or processes, all bets are rendered void.
You are under an obligation to inform us immediately as soon as you become aware of any error
with the service.
In the event of communication or system errors or bugs or viruses occurring in connection with
the service and/or payments made to you as a result of a defect or effort in the Service, we
will not be liable
to you or to any third party for any direct or indirect costs, expenses, losses or claims
arising or resulting from such errors, and we reserve the right to void all games/bets in
question and take any other
action to correct such errors.
In the event of a casino system malfunction, or disconnection issues, all bets are rendered
void. In the event of such error or any system failure or game error that results in an error in
any odds
calculation, charges, fees, rake, bonuses or payout, or any currency conversion as applicable,
or other casino system malfunction (the “Casino Error”), we reserve the right to
declare null and
void any wagers or bets that were the subject of such Casino Error and to take any money from
your Account relating to the relevant bets or wagers.
We make every effort to ensure that we do not make errors in posting lines. However, if as a
result of human error or system problems a bet is accepted at an odd that is: materially
different from those
available in the general market at the time the bet was made; or clearly incorrect given the
chance of the event occurring at the time the bet was made then we reserve the right to cancel
or void that wager,
or to cancel or void a wager made after an event has started.
We have the right to recover from you any amount overpaid and to adjust your account to rectify
any mistake. An example of such a mistake might be where a price is incorrect or where we enter
a result of an
event incorrectly. If there are insufficient funds in your Account, we may demand that you pay
us the relevant outstanding amount relating to any erroneous bets or wagers. Accordingly, we
reserve the right to
cancel, reduce or delete any pending plays, whether placed with funds resulting from the error
or not.
General Rules
If a sport-specific rule contradicts a general rule, then the general rule will not apply.
The winner of an event will be determined on the date of the event’s settlement; we do not
recognise protested or overturned decisions for wagering purposes. The result of an event
suspended after the
start of competition will be decided according to the wagering rules specified for that sport by
us.
All results posted shall be final after 72 hours and no queries will be entertained after that
period of time. Within 72 hours after results are posted, the company will only reset/correct
the results due to
human error, system error or mistakes made by the referring results source.
Minimum and maximum wager amounts on all sporting events will be determined by us and are
subject to change without prior written notice. We also reserve the right to adjust limits on
individual Accounts as
well.
Customers are solely responsible for their own account transactions. Please be sure to review
your wagers for any mistakes before sending them in. Once a transaction is complete, it cannot
be changed. We do
not take responsibility for missing or duplicate wagers made by the Customer and will not
entertain discrepancy requests because a play is missing or duplicated. Customers may review
their transactions in the
My Account section of the site after each session to ensure all requested wagers were accepted.
For a wager to have action on any named contestant in a Yes/No Proposition, the contestant must
enter and compete in the event.
We attempt to follow the normal conventions to indicate home and away teams by indicating the
home and away team by means of vertical placement on the desktop site version. This means in
American Sports we
would place the home team on the bottom. For Non-US sports, we would indicate the home team on
top. In the case of a neutral venue, we attempt to include the letter “N” next to
the team names to
indicate this. For the Asian and mobile versions, we do not distinguish between European and
American Sports. On the Asian and mobile versions of the site, the home team is always listed
first. However, we do
not guarantee the accuracy of this information and unless there is an official venue change
subsequent to bets being placed, all wagers have action.
A game/match will have action regardless of the League heading that is associated with the
matchup. For example, two teams from the same League are playing in a Cup competition. If the
matchup is mistakenly
placed in the League offering, the game/match will still have action, as long as the matchup is
correct. In other words, a matchup will have action as long as the two teams are correct, and
regardless of the
League header in which it is placed on our Website.
If an event is not played on the same date as announced by the governing body, then all wagers
on the event have no action. If an event is posted by us, with an incorrect date, all wagers
have action based on
the date announced by the governing body.
Lordsexch reserves the right to remove events, markets and any other product from the website.
Lordsexch eserves the right to restrict the casino access of any player without prior notice.
In all futures wagering (for example, total season wins, Super Bowl winner, etc.), the winner as
determined by the Governing Body will also be declared the winner for betting purposes except
when the minimum
number of games required for the future to have “action” has not been completed.
Communications and Notices
All communications and notices to be given under these terms by you to us shall be sent to
[email protected]
All communications and notices to be given under these terms by us to you shall, unless
otherwise specified in these terms, be either posted on the Website and/or sent to the
Registered Email Address we hold
on our system for the relevant Customer. The method of such communication shall be in our sole
and exclusive discretion.
All communications and notices to be given under these terms by either you or us shall be in
writing in the English language when the service is not operated by Lordsexch, and must be given
to and from the
Registered Email Address in your Account.
Matters Beyond Our Control
We cannot be held liable for any failure or delay in providing the service due to an event of
Force Majeure which could reasonably be considered to be outside our control despite our
execution of reasonable
preventative measures such as: an act of God; trade or labour dispute; power cut; act, failure
or omission of any government or authority; obstruction or failure of telecommunication
services; or any other
delay or failure caused by a third party, and we will not be liable for any resulting loss or
damage that you may suffer. In such an event, we reserve the right to cancel or suspend the
Service without
incurring any liability.
Liability
TO THE EXTENT PERMITTED BY APPLICABLE LAW, WE WILL NOT COMPENSATE YOU FOR ANY REASONABLY
FORESEEABLE LOSS OR DAMAGE (EITHER DIRECT OR INDIRECT) YOU MAY SUFFER IF WE FAIL TO CARRY OUT
OUR OBLIGATIONS UNDER
THESE TERMS UNLESS WE BREACH ANY DUTIES IMPOSED ON US BY LAW (INCLUDING IF WE CAUSE DEATH OR
PERSONAL INJURY BY OUR NEGLIGENCE) IN WHICH CASE WE SHALL NOT BE LIABLE TO YOU IF THAT FAILURE
IS ATTRIBUTED TO
(I) YOUR OWN FAULT;
(II) A THIRD PARTY UNCONNECTED WITH OUR PERFORMANCE OF THESE TERMS (FOR INSTANCE PROBLEMS DUE TO
COMMUNICATIONS NETWORK PERFORMANCE, CONGESTION, AND CONNECTIVITY OR THE PERFORMANCE OF YOUR
COMPUTER
EQUIPMENT); OR
(III) ANY OTHER EVENTS WHICH NEITHER WE NOR OUR SUPPLIERS COULD HAVE FORESEEN OR FORESTALLED
EVEN IF WE OR THEY HAD TAKEN REASONABLE CARE. AS THIS SERVICE IS FOR CONSUMER USE ONLY WE WILL
NOT BE LIABLE FOR
ANY BUSINESS LOSSES OF ANY KIND.
IN THE EVENT THAT WE ARE HELD LIABLE FOR ANY EVENT UNDER THESE TERMS, OUR TOTAL AGGREGATE
LIABILITY TO YOU UNDER OR IN CONNECTION WITH THESE TERMS SHALL NOT EXCEED
(A) THE VALUE OF THE BETS AND OR WAGERS YOU PLACED VIA YOUR ACCOUNT IN RESPECT OF THE RELEVANT
BET/WAGER OR PRODUCT THAT GAVE RISE TO THE RELEVANT LIABILITY, OR
(B) EURO €500 IN AGGREGATE, WHICHEVER IS LOWER.
WE STRONGLY RECOMMEND THAT YOU (I) TAKE CARE TO VERIFY THE SUITABILITY AND COMPATIBILITY OF THE
SERVICE WITH YOUR OWN COMPUTER EQUIPMENT PRIOR TO USE; AND
(II) TAKE REASONABLE PRECAUTIONS TO PROTECT YOURSELF AGAINST HARMFUL PROGRAMS OR DEVICES
INCLUDING THROUGH INSTALLATION OF ANTI-VIRUS SOFTWARE.
Gambling By Those Under Age
If we suspect that you are or receive notification that you are currently under 18 years or were
under 18 years (or below the age of majority as stipulated in the laws of the jurisdiction
applicable to you)
when you placed any bets through the service your account will be suspended to prevent you
placing any further bets or making any withdrawals from your account. We will then investigate
the matter, including
whether you have been betting as an agent for, or otherwise on behalf, of a person under 18
years (or below the age of majority as stipulated in the laws of the jurisdiction applicable to
you). If having
found that you: (a) are currently; (b) were under 18 years or below the majority age which
applies to you at the relevant time; or © have been betting as an agent for or at the
behest of a person under
18 years or below the majority age which applies:
all winnings currently or due to be credited to your account will be retained;
all winnings gained from betting through the service whilst under age must be paid to us on
demand (if you fail to comply with this provision we will seek to recover all costs associated
with recovery of such
sums); and/or
iii. any monies deposited in your Lordsexch.co account which are not winnings will be returned
to you.
This condition also applies to you if you are over the age of 18 years but you are placing your
bets within a jurisdiction which specifies a higher age than 18 years for legal betting and you
are below that
legal minimum age in that jurisdiction.
In the event we suspect you are in breach of the provisions of this Clause 15 or are attempting
to rely on them for a fraudulent purpose, we reserve the right to take any action necessary in
order to
investigate the matter, including informing the relevant law enforcement agencies.
Anti Money-Laundering and KYC Policy
It is the policy of Lordsexch to actively prevent the services of the firm being used to
facilitate financial crime, money laundering and terrorist financing.
Strict compliance with all applicable regulations will also protect the senior management and
staff of the firm, as individuals, from the risks of breaches of the law, regulations, and
supervisory
requirements, and to preserve the reputation of the Lordsexch against the damage that could be
caused by being implicated in money laundering and terrorist financing activities.
To achieve these objectives, it is the policy of this firm that:
Every staff member shall meet their personal obligations as appropriate to their role and
responsibilities;
Commercial considerations cannot take precedence over Lordsexch anti-money laundering
commitment;
The firm shall appoint a Money Laundering Reporting Officer/Nominated Officer (“MLRO”),
and a deputy to cover in their absence, and they shall be afforded every assistance and
cooperation by all
members of staff in carrying out their duties and responsibilities. The deputy will be the
Director Chief Executive Officer (CEO).
Lordsexch will strictly comply with all applicable AML/CFT rules and regulations with specific
emphasis on:
A culture of compliance to be adopted and promulgated throughout the firm towards the prevention
of financial crime;
A commitment to ensuring that customer’s identities will be satisfactorily verified at
required thresholds;
A commitment to “knowing its customer” appropriately - both at acceptance and
throughout the business relationship - through taking appropriate steps to verify the customer’s
identity and
monitoring their use Lordsexch services;
A commitment to ensuring that staff are trained and made aware of the law and their obligations
under it, and to establishing procedures to implement these requirements; and
Recognition of the importance of staff promptly reporting their suspicions internally:
At the heart of our policies, procedures and controls, and consistent with FATF Recommendation
1, is the risk-based approach. The risk-based approach means that we focus our resources on the
areas of greatest
risk.
Our policies, procedures and internal controls are designed to ensure compliance with all
applicable anti-money laundering and anti-terrorist financing regulations and regulatory
guidelines and will be
reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal
controls are in place to account for both changes in regulations and changes in our business.
15.1 Money Laundering and Terrorism Financing
Money Laundering means:
The conversion or transfer of property, knowing that such property is derived from criminal
activity or from an act of participation in such activity, for the purpose of concealing or
disguising the illicit
origin of the property or of assisting any person who is involved in the commission of such an
activity to evade the legal consequences of that person's action;
The concealment or disguise of the true nature, source, location, disposition, movement, rights
with respect to, or ownership of, property, knowing that such property is derived from criminal
activity or from
an act of participation in such an activity;
The acquisition, possession or use of property, knowing, at the time of receipt, that such
property was derived from criminal activity or from an act of participation in such an activity;
Participation in, association to commit, attempts to commit and aiding, abetting, facilitating
and counselling the commission of any of the actions referred to in points (a), (b) and (c).
Money laundering shall be regarded as such even where the activities which generated the
property to be laundered were carried out in the territory of another Member State or in that of
a third country.
Terrorism financing means the provision or collection of funds, by any means, directly or
indirectly, with the intention that they be used or in the knowledge that they are to be used,
in full or in part, in
order to carry out any terrorist act.
15.2 Organization of the AML/CFT function
15.2.1
Senior Management
Senior Management are responsible for the overall compliance policy of Lordsexch and ensuring
adequate resources are provided for the proper training of staff and the implementing of risk
systems. This
includes computer software to assist in oversight. Senior management will receive and consider
the monthly compliance reports sent by the MLRO and authorise changes based on the
recommendations if required.
Senior Management consists of the Board of Directors, the Executive Management Committee and the
MLRO.
15.2.2
The Nominated Officer/Money Laundering
Reporting Officer
Responsible for receiving internal disclosures and making reports to the Gaming Control Board,
Curacao. First point of contact for all
compliance issues
from staff. Prepares monthly report for consideration of senior management and conducts risk
assessments of compliance systems. Undertakes regular random analysis of transactions including
assessment of
documentary evidence provided by customers. Assists in making any necessary amendments to AML
Policy in line with risk assessment. Ensures everyone is periodically informed of any changes in
anti- money
laundering or anti-terrorist financing legislation, policies and procedures, as well as current
developments and changes in money laundering or terrorist activity financing schemes particular
to their jobs.
Reviews customer identification information to ensure that all the necessary information has
been obtained. Establishes and implement the risk scoring matrix following regulatory guidance
and for review and
approval by Senior Management.
15.2.3
Staff
Responsible for knowing the AML Compliance Policy and understanding responsibilities. Ensure
company procedures are adhered to and obtaining all documentary evidence as outlined within the
manual. Ensure that
all suspicious and unusual activity is reported to the MLRO.
15.3 The Compliance Programme
5.1 The Money Laundering
Reporting Officer (MLRO)
Lordsexch has appointed a MLRO with full responsibility for Lordsexch’s anti-money
laundering compliance.
The MLRO:
Will monitor the day-to-day operation of Lordsexch TRADING’s AML/CFT policies and respond
to any reasonable request made by the law enforcement and/or the Gaming Control Board, Curacao.
Has the authority to act independently in carrying out their responsibilities, which includes
direct access to the Gaming Control Board, Curacao and appropriate law enforcement agencies, in
order that any
suspicious activity may be reported to the right quarter as soon as is practicable.
Has the authority and the resources necessary to discharge their responsibilities effectively.
Is from a senior level and has direct access to senior management and the board of directors.
May choose to delegate certain duties to other employees, but wherever such a delegation is
made, the MLRO retains ultimate responsibility for the implementation of the compliance regime.
At least annually, the MLRO will issue a report (the MLRO Report) to the senior management of
Lordsexch on the operation and effectiveness of the money laundering controls. This report will
cover
improvements, remedial programmes, the outcome of any internal audit reviews of the AML/CFT
processes, and other relevant items.
15.4 Compliance Policies and Procedures
Lordsexch has policies and procedures to assess the risks related to money laundering and
terrorist financing. These policies and procedures are:
Written and maintained by the MLRO under the supervision of senior management
Approved by senior management
Communicated, understood and adhered to by everyone dealing with customers or their
transactions, including those who work in the areas relating to customer identification, record
keeping, and reportable
transactions, who need enough information to process and complete a transaction properly as well
as to ascertain the identity of customers and keep records as required.
Policies and procedures which incorporate the reporting, record keeping, customer
identification, risk assessment and risk mitigation requirements applicable.
Although directors and senior officers may not be involved in day-to-day compliance, they need
to understand the statutory duties placed upon them, their staff and Lordsexch itself.
15.4.1 The Risk-Based Approach
In money laundering and terrorist financing, a risk-based approach covers the following:
The risk assessment of customer relationships and business activities;
The risk mitigation to implement controls to handle identified risks;
Keeping customer identification, beneficial ownership and business relationship information up
to date; and
The ongoing monitoring of business relationships and transactions.
Existing regulatory obligations, such as for customer identification, are a minimum baseline
requirement. Where enhanced due diligence is appropriate, a principle of the risk-based approach
is to focus
resources where they are most needed to manage risks within our tolerance level.
15.4.2 Risk Mitigation
Risk mitigation is implementing controls to limit the potential money laundering and terrorist
financing risks identified in the risk assessment so as to stay within the risk tolerance level.
When the risk
assessment determines that risk is high for money laundering or terrorist financing, then we
will develop risk mitigation strategies and apply them.
In all situations, risk mitigation controls and measures include:
Focussing on operations (products and services, customers and business relationships, geographic
locations, and any other relevant factors) that are more vulnerable to abuse by money launderers
and criminals;
Informing senior management of compliance initiatives, identified compliance deficiencies,
corrective action taken, and suspicious transaction reports filed;
Providing for program continuity despite changes in management, employees or structure;
Focussing on meeting all regulatory record keeping and reporting requirements, recommendations
for anti-money laundering and anti-terrorist financing compliance and providing for timely
updates in response to
changes in requirements;
Enabling the timely identification of reportable transactions and ensure accurate filing of
required reports;
Incorporating anti-money laundering and anti-terrorist financing compliance into job
descriptions and performance evaluations of appropriate personnel; and
Providing for adequate supervision and training of employees that handle currency transactions,
complete reports, monitor for suspicious transactions, or engage in any other activity that
forms part of the
anti-money laundering and anti-terrorist financing program.
Increasing awareness of high risk situations within all business lines;
Increasing the frequency of ongoing monitoring of transactions or business relationships;
Escalating the approval of the establishment of an account or relationship even if not otherwise
required to do so;
Increasing the levels of ongoing controls and reviews of relationships;
Requesting high-risk customers provide additional, documented information regarding controls
they have implemented to safeguard their operations from abuse by money launderers and
terrorists;
Verifying the identity of customers by reference to reliable, independent source documents, data
or information;
Preventing any transaction with a potential customer until identification and account opening
information has been obtained;
Implementing an appropriate process to approve all relationships identified as high-risk as part
of the customer acceptance process or declining to do business with potential customers because
they exceed
Lordsexch’s risk tolerance level;
Implementing a process to exit from an existing high-risk relationship which management sees as
exceeding Lordsexch’s risk tolerance level.
15.4.3 Risk Assessment
Lordsexch is required to and will analyse potential threats and vulnerabilities to money
laundering and terrorist financing to which the business may be exposed to in a risk assessment.
The risk assessment will document and consider the following:
Products, services and delivery channels
Geographic locations and areas of operation
Customers
The risk assessment may identify high-risk situations for which risk mitigation controls and
monitoring may be required. The risk assessment is not static and will change over time.
When a customer is identified as high-risk, they are subject to more frequent ongoing monitoring
and updating of customer identification information, as well as any other appropriate enhanced
measures.
Lordsexch shall perform an initial risk assessment at the beginning of a new customer
relationship and for existing customers on an ongoing basis.
15.5 Client and Business Risk
15.5.1 Products, Services and Delivery Channels
Lordsexch will identify products and services or combinations of them that may pose an elevated
risk of money laundering or terrorist financing. For example, products and services that support
the movement
and conversion of assets into, through and out of the financial system pose a high risk. Certain
services have also been identified by financial regulators, governmental authorities or other
credible sources
as being potentially high-risk for money laundering or terrorist financing.
Wire transactions;
Transactions involving third parties;
Non-face-to-face business relationships.
15.5.2 Geographic Locations and Areas of Operation
Certain geographic locations potentially pose an elevated risk for money laundering and
terrorist financing. These have been described by the FATF and by other resources such as
Transparency International.
Clients from, or identified as linked to these countries will be regarded as high risk:
Any country subject to sanctions, embargoes, or similar measures;
Any country identified by credible sources as providing funding or support for terrorist
activities, or that have designated terrorist organisations operating within their country;
Any country known to be a tax haven, source of narcotics or other significant criminal activity;
Any country identified by the Financial Action Task Force (FATF) as non-cooperative in the fight
against money laundering or terrorist financing or subject to a FATF statement;
Any country identified by credible sources as lacking appropriate money laundering or terrorist
financing laws and regulations, or as having significant levels of corruption.
Lordsexch does not do business with or provide services to anyone in any country belonging to a
list of select countries subject to comprehensive international sanctions.
15.5.3 Customer Relationships
The risk assessment requires to know your customers (“KYC”). This is not limited to
identification or record keeping, but it is also about understanding the customers –
including their
activities, transaction patterns, and how they operate.
Examples of the factors that will be considered are:
How long we have known the customer and had a business relationship;
Customers wanting to carry out large transactions;
Customers with regulatory or enforcement issues;
Customers with multiple online complaints;
Customers whose identification is difficult to verify;
Customers whose who are politically exposed.
Each customer is risk-rated as either posing a low, medium or high risk of money laundering
and/or terrorist financing. The rating given at the beginning of the business relationship may
be adjusted after the
re-assessment and may change over time. The
level of customer due diligence will vary depending on the risk rating of the customer at the
beginning of the
relationship and as it changes. For all high-risk players, enhanced due diligence is applied
right away.
15.5.4 Regulatory risk
Regulatory risk means not meeting our obligations under applicable legislation. Examples of
breaches of regulatory obligations include:
Customer identification not done properly;
Failure to train staff adequately;
Bot having an anti-money laundering and anti-terrorist financing (AML/CFT) program;
Failure to report suspicious transactions;
Not having an MLRO;
Failing to keep complete customer records.
15.5 Compliance Training
Lordsexch has a training program for all relevant employees and other individuals who act on
behalf of the Company. The goal of this
training is to make
sure that those who have contact with customers, who see customer transaction activity or who
handle funds in any way understand the reporting, customer identification and record keeping
requirements.
All new employees of Lordsexch are required to complete anti-money laundering and terrorist
financing compliance training within their first three months of employment, and for
customer-facing staff training
is delivered prior to dealing with customers.
Training is currently conducted through a customised course. The
training program is delivered electronically (via a learning management system). The
training program is reviewed and updated by the MLRO to reflect requirements as they
change. The compliance training includes a
test which everyone must
pass in order to consider their training complete.
To ensure employee training is kept up to date, all existing employees will receive follow up
training on new and existing AML and regulatory requirements on a regular basis (at least within
one year of their
last training). If the online training test results show that a staff member does not
understanding the training material, Lordsexch will ensure that the staff member receives
specialised one-on-one training
to understand the material.
An employee log of assigned and completed training materials is kept by the MLRO and the Human
Resources department for administrative purposes. Retention
of these records is for a period of five years.
Compliance training is adjusted in accordance to the employee’s role within the company.
The MLRO will review functions and arrange to provide suitable and customised training.
Our training will include at a minimum:
An understanding of the reporting, customer identification and record keeping requirements as
well as penalties for not meeting those requirements;
Making all employees aware of the internal policies and procedures for deterring and detecting
money laundering and terrorist financing that are associated with their jobs;
Delivering to employees and suppliers a clear understanding of their responsibilities under
these policies and procedures;
All those who have contact with customers, who see customer transaction activity, who handle
cash or funds in any way or who are responsible for implementing or overseeing the compliance
regime must
understand the reporting, customer identification and record keeping requirements.
Making all employees aware of how Lordsexch is vulnerable to abuse by criminals laundering the
proceeds of crime or by terrorists financing their activities;
Making all employees and agents aware that they cannot disclose that they have made a suspicious
transaction report, or disclose the contents of such a report, with the intent to prejudice a
criminal
investigation, whether it has started or not;
That all employees and agents understanding that no criminal or civil proceedings may be brought
against them for making a report in good faith;
Background information on money laundering so everyone who needs to can understand what money
laundering is, why criminals choose to launder money and how the process usually works;
Details of what terrorist financing is and how that process usually works.
The MLRO is responsible for ensuring that everyone is informed of changes in anti-money
laundering or anti-terrorist financing legislation, policies and procedures, and current
developments in money
laundering or terrorist activity financing schemes particularly relevant to their jobs.
Certain employees, such as those in compliance, customer services and operations, require types
of specialised additional training which will be provided either through external services or
internally.
The training program is reviewed and
updated to reflect changes in requirements.
15.6. Minimum standards – KYC POLICY
Lordsexch has established standards regarding Know-Your-Customer (“KYC”). These
standards require due diligence on each prospective customer before entering into a business
relationship via
identification and verification of his identity and, as the case may be, his representatives and
beneficial owners on the basis of documents, data or information obtained from a reliable and
independent
source compliant with the domestic and European AML/CFT legislation and regulation.
Interpretation of the KYC principle begins with identification of the customer by means of the
necessary identification documents.
That identification, completed by other information gathered, enables the Customer Acceptance
Policy to be applied.
In addition to these objective criteria, there are subjective elements which may arouse
suspicions regarding a customer and to which particular attention should be paid.
Finally, as KYC does not involve static data, but dynamic data through the relationship with the
customer, it also needs follow-up and ongoing monitoring of the customer.
15.6.1. Customer identification and verification (KYC)
The formal identification of customers on entry into commercial relations is a vital element,
both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles :
- Each customer (= each individual person and/or each person involved in the case of a legal
entity) must be identified by means of original supporting documents.
- These documents will be recorded in a centralised system.
- The identification must be completed by "face-to-face" contact.
- Distance identification is also authorised and possible within a dedicated acceptance process,
but limits the opportunity to carry out certain transactions or to access certain products.
- Each person identified must be registered by IT means.
- A person will not be accepted as a customer if the identification process proves to be
incomplete.
The specific case of the due diligence exercised on the acceptance of politically exposed
persons (PEP).
Concrete application at Lordsexch is reflected by a specific identification procedure for
customers referenced as PEP, whatever their place of residence.
15.6.2. Risk Profile calculation
To assist in determining the level of AML/CFT due diligence to be exercised with regard to the
Customer, a “Compliance” risk profile is calculated first of all on entry into
relations (Low,
Medium, High), and is then recalculated daily.
15.6.3. Customer acceptance policy
15.6.3.1. Customer Identification
Client Identification is intended to confirm the existence and identify the individual with
which Lordsexch has a business relationship and obtain supporting identity information.
This includes measures to:
Confirm the existence of the individual through identification documents;
Conduct due diligence into the identity of the customer including:
Cross-referencing customer names against government watch lists;
Determining whether the customers are politically exposed persons;
Determining whether any third parties are involved;
Reviewing relevant publicly available information on the customer (e.g. adverse media, social
media);
Reviewing their background, reputation;
Keep records of all information and documents obtained.
15.6.3.2. Identifying Information for Customers
This section sets out the standard identification requirements for individuals who have entered
into a business relationship with Lordsexch. This outline is likely to be sufficient for most
situations. If,
however, the customer is assessed as presenting a higher money laundering or terrorist financing
risk, in line with our identified risk matrix, then Lordsexch requires additional identity
information to be
provided and increase the level or verification accordingly.
Where the result of the standard verification check gives rise to concern or uncertainty over
identity, the number of matches that will be required to be reasonably satisfied as to the
individual’s
identity will increase. Any concerns must
be reported to the MLRO.
If a customer is unable to produce a primary ID, the reasons for this should be noted and they
may not be able to maintain an account.
All documentary evidence must be recent.
Passports and drivers’ licenses should be valid and not expired
Utility bills should be dated within the last 3 months
In terms of beneficial ownership, we will ask every customer whether they are acting in their
own capacity or on behalf of another person. If they are acting for another person then we will
require details of
such.
Sources of evidence
Proof of Identity - Acceptable photo identity:
Valid passport; or
Valid photo card driving licence (full or provisional); or
National identity card (non-UK nationals issued by EEA member states and Switzerland);
or
Identity card issued by the Electoral Office for Northern Ireland
Proof of Identity - Acceptable non-photo evidence of identity:
Documents issued by a government department, incorporating the person’s name and
residential address or their date of birth. E.g. (for proof of address or date of birth):
Instrument of a court appointment (such as a grant of probate, bankruptcy); or
Current council tax demand letter or statement; or
Current (within the last 3 months) bank statements, or credit/debit card statements issued by a
regulated financial sector firm in the UK, EU or equivalent jurisdiction; or
A recent (last available) utility bill (gas, water, electricity, telephone); it must be a bill
or statement of account (not correspondence); statements printed off the internet are not
acceptable on their own
(a secondary check will be required such as a reference to a telephone directory including an
online telephone directory); or
Valid photo card driving licence (full or provisional); or
A solicitor’s letter confirming recent house purchase or land previous address.
When accepting evidence of identity from a customer, it is important that we make sufficient
checks on the evidence provided to satisfy us of the customer’s identity, and that we keep
a record of the
checks made. This will be done by the MLRO or under the supervision of the MLRO.
Usual checks on photo ID may include:
Likeness against the customer
Does the date of birth on the evidence match the apparent age of the customer?
Is the ID valid?
Is the spelling of names the same as other documents provided by the customer?
Checks on secondary evidence of ID may include:
Do the addresses match the address given on the photo ID?
Does the name of the customer match with the name on the photo ID?
15.6.3.3. Identity Verification Triggers
Verification of the identity of the customer occurs either when the customer has reached the
€2,000 threshold or if the player is considered to be a high-risk player upon registration.
The main trigger
for Identity Verification is considered a single transaction (or smaller, linked transactions)
that reach or exceed €2,000 either at deposit or withdrawal stage. For example,
transactions will be
considered as linked when they are carried out by the same customer during a single period of
being logged on to the Lordsexch website or if they are carried out in 48 hours.
In all cases, the customer will receive a notification to upload identity verification documents
listed above. Each document that is
provided by customers
to Lordsexch is checked manually by dedicated staff.
Further events that may trigger Identity Verification processes:
When a customer requests a withdrawal to a different account than one that was used to make a
deposit (e.g. due to the fact that certain payment service providers do not support incoming
payments or other
reasons). In these cases, the withdrawal requests will be immediately deducted from the customer’s
account, however, will not be processed until the customer’s identity has been verified to
ensure
that the funds are going to the right person;
When a customer makes multiple deposits within a short timeframe (five or more deposits in one
hour);
Staff identifies suspicious deposit patterns and or several payment cards are used (three or
more different payment methods used within one week);
Registration country and IP do not match – In such cases, the player account may not be
blocked and the player may still make deposits and play games, however, no withdrawal will be
allowed until
verification has been carried out;
When a deposit exceeds €5,000.
Copies will be kept of all the documents used for identification.
15.6.3.4. Additional Documents
Additional documents may be requested from customers to substantiate their activities or to
better understand their patters:
Proof of Bank Account – This may be a screenshot or copy of the bank statement stating the
customer’s name and IBAN and the name of the bank (for instances when a customer requests
a withdrawal to
be deposited to a bank account);
Proof of Payment Card – This may be a photo or copy of the front side of the card in
question or a bank statement that will include both the card details and the name of the
customer (for instances when
suspicious deposit patters are identified) –
To protect the customer’s card data, Lordsexch informs them that they may obfuscate some
of the card details, however, the customer’s name, as well as the first and last four
digits of the card
number must be visible.
Bank Statements and Payslips – These may be requested from customers displaying
potentially problematic gambling patterns and when external information available on the
customer does not validate the
amounts being gambled. In such cases Lordsexch would ask its higher volume customers for
documents which would support the funds being spent on gambling.
15.6.3.5. Mitigation of Impersonation Risk
Various additional customer identity checks are permitted on a risk-based approach. These checks
may include:
Requiring the first payment to be carried out through an account in the customer’s name
with an EU/EEA regulated credit institution or one from an equivalent jurisdiction;
Verifying additional aspects of the customer’s identity, or of their electronic ‘footprint’;
Telephone contact with the customer prior to opening the account on a home or business number
which has been verified (electronically or otherwise) or a call to the customer before further
transactions are
permitted, using it to verify additional aspects of personal identity information that have been
previously provided during the setting up of the account;
15.6.3.6. Keeping Information Up-to-Date
Once the identity of a customer has been confirmed, it does not have to be confirmed again.
However, if there is any doubt about the information held, then that identification will be
obtained again,
including the identification of the customer.
Lordsexch may review the customer documentation and then update it as appropriate. Any changes to identification such as a
change of name of the customer
would require new documents to be obtained.
15.6.4. Ongoing transaction monitoring
There are certain automated controls in place to monitor customer activities, for example:
First time deposits;
Cash-out alerts for cash-outs greater than €1,000;
Activity alerts when customer pays to, or stakes with the casino €2,000 during any period
of 24 hours;
Credit Card BIN alerts (when Credit Card country differs from player account country/IP);
In addition, all cash-out requests are processed manually by the Payments Team and are reviewed
on a daily basis. Every request undergoes
security checks
before approval in order to determine that the origin of the funds/wins is compliant with the
Gaming Control Board Curacao Policy and the terms and conditions of the Company.
15.7. Organization of internal control
Any member of Lordsexch can report suspicious activities to the MLRO, as Lordsexch’s
Nominated Officer. A suspicious activity is one where it is known, or suspected, there are
reasonably grounds to know
or suspect that a person is engaged in, or attempting, money laundering or terrorist financing.
15.7.1. Suspicious transactions reporting
Having knowledge means knowing something to be true. Knowledge can be inferred from the
surrounding circumstances; so, for example, a failure to ask obvious questions may imply
knowledge. The knowledge must, however, have come
to Lordsexch during the course of business, or
from a disclosure (to the MLRO).
Suspicion is more subjective and falls short of proof based on firm evidence. Suspicion is more
than speculation and is based on some foundation.
An unusual transaction is not necessarily suspicious. Unusual patterns of gambling, including
the spending of particularly large amounts of money in relation to the casino or customer’s
profile, should
receive attention, but unusual behaviour should not necessarily lead to grounds for knowledge or
suspicion of money laundering, or the making of a report to the FIAU. The MLRO is required to
assess all of the
circumstances and, in some cases, it may be helpful to ask the customer or others more
questions. The choice depends on what is already known about the customer and the transaction,
and how easy it is to make
enquiries.
Members of staff who consider a transaction or activity to be suspicious, would not necessarily
be expected to know or to establish the exact nature of any underlying criminal offence, or that
the particular
funds or property were those arising from a crime, money laundering or terrorist financing.
“Reasonable grounds to know or suspect” introduces an objective test of suspicion.
The test is likely to
be met when there are facts or circumstances, known to the member of staff, from which a
reasonable person (in a payments firm) would have inferred knowledge, or formed the suspicion,
that another person was
engaged in money laundering or terrorist financing.
A defence of failing to meet the test of suspicion, would be for staff to demonstrate that they
took reasonable steps to know the customer and the rationale for the transaction, activity or
instruction.
15.7.2 How to Make a Suspicious Activity Report
Any member of staff, who is suspicious that a transaction may involve money laundering or who
becomes aware during the course of their work that someone else is involved in money laundering,
must make a
disclosure to the MLRO using the Lordsexch Suspicious Transaction Report form.
Once completed, the form should be printed off. The member of staff making the report must sign
and date the form before giving it to the MLRO. The MLRO
will take note of the date and time of report receipt.
Upon receipt of the form by the MLRO, they will then decide what is to be done as a result of
the report, e.g., whether the matter must be reported to Gaming Control board, Curacao. or not,
or further
enquiries made and record its decision and the reason for it in the customer files. The member
of staff concerned must be informed of the decision and the reasons for it.
If the matter is to be referred to GCB, the MLRO or a subordinate will complete the FIAU report
form and discussing with the reporting member of staff how matters with the customer are to be
conducted from
that stage. The GCB report form must be signed off by the MLRO or the CEO.
Lordsexch must not proceed with a transaction whilst we await consent from the concerned from
GCB it is given 7 working days (not including weekends or bank holidays) to consider the report.
If we hear nothing then we may continue with the transaction but not inform the customer about
the report. GCB may give consent to proceed earlier than this time limit. They may also refuse
consent in which
case they have a further 31 calendar days (including weekends or bank holidays) to further
consider the report. After this they must either begin proceedings or allow the transaction to
continue.
The MLRO will submit a softcopy version of the report to the GCB. Any paper file for each matter
will be kept by the MLRO.
There must be no record on the customer file or on the computer system which refers in any way
to suspicious activity reporting, money laundering, etc., to avoid the risk of tipping off. It
is a criminal
offence to inform a customer that a SAR has been submitted, or to inform them of an
investigation into their affairs.
All records of SARs will be kept in the central reporting file, which is kept by the MLRO.
15.7.3 How to Identify
Suspicious Activity
Transactions may give reasonable grounds to suspect that they are related to money laundering or
terrorist activity financing regardless of the sum of money involved. There is no monetary
threshold for making
a SAR. Suspicious transactions may involve several factors that on their own seem insignificant,
but together raise suspicion that the transaction is related to the commission or attempted
commission of a
money laundering or terrorist activity financing offence, or both. As a general guide, a
transaction may be connected to money laundering or terrorist activity financing when we think
that it (or a group of
transactions) raises questions or gives rise to discomfort, apprehension or mistrust.
Lordsexch will examine, as far as reasonably possible, the background and purpose of all
complex, unusual large transactions, and all unusual patterns of transactions, which have no
apparent economic or
lawful purpose.
The context in which the transaction occurs or is attempted is a significant factor in assessing
suspicion and this will vary from one customer to another.
Transactions will be evaluated in terms of what seems appropriate and is within normal practices
in business and based on our knowledge of the customer. The fact that transactions do not appear
to be in
keeping with normal industry practices may be a relevant factor.
Reasonable evaluation of relevant factors, including the knowledge of the customer's
business, financial history, background and behaviour is the basis of assessing suspicion.
Behaviour is suspicious,
not people. We have listed below some indicators to help with this assessment.
15.7.4 Indicators of Suspicious Transactions
Certain products, services, activities or channels may pose a higher risk of misuse for money
laundering. Listed below are several anti-money laundering risk indicators or “red flags”
that might
be grounds for suspicion. The list is not exhaustive and not conclusive but will be used as a
guide for inquiry and follow-up, alongside other material.
A single indicator does not necessarily indicate reasonable grounds to suspect money laundering
or terrorist financing activity. However, if several indicators are present during one or a
series of
transactions, then we will take a closer look at other factors before deciding whether the
transaction must be reported.
In the case of a transaction aborted in the belief that the property is owned or controlled by
or on behalf of a terrorist or a terrorist group, then there must be a terrorist property
report. If there are
reasonable grounds to suspect that the transaction is related to an attempted commission of a
terrorist activity financing or money laundering offence, then a suspicious transaction report
about the attempted
transaction is also required.
Becoming aware of certain indicators could trigger reasonable grounds to suspect that one or
more transactions from the past (that had not previously seemed suspicious) were related to
money laundering or
terrorist financing.
15.7.4.1 Application and Identification
Information mismatch from application
Application information/address/customer differs from initial registration
Inability to provide government issued identification details
Change of address to high-fraud area or to problematic jurisdiction, shortly after the
application
Lack of reliable third party and/or governmental verification of individual
The address indicated (or corroborated) is identified as mail drop or other high-risk address,
as opposed to a physical street address
Transaction volume, deposits, and cash-outs are inconsistent
15.7.4.2 Account Settlement
Large, cross-border wire transfer payments
Settlements/partial settlements from unrelated third parties
Excessive/ongoing large credit refunds
15.7.4.3 Transaction and Customer Monitoring
Stakes wagered by a customer become unusually high or out of the ordinary and the customer is
believed to be spending beyond his or her known means. This requires some knowledge of the
customer but,
nevertheless, there may be circumstances that appear unusual and raise the suspicion that he is
using money obtained unlawfully.
It may be that the customer lives in low cost accommodation with no known source of income but
nonetheless is spending money well above his or her apparent means.
There is no set amount which dictates when a SAR should be made and much will depend on what is
known, or suspected, about the customer.
A customer exhibits unusual gambling patterns with an almost guaranteed return or very little
financial risk.
It is accepted that some customers prefer to gamble in this way but, in some instances, the
actions may raise suspicion because they are different from the customer’s normal gambling
practices.
Money is deposited by a customer or held over a period and withdrawn by the customer without
being used for gambling.
For instance, suspicions should be raised by any large amounts deposited in gaming machines or
gambling accounts that are then cashed or withdrawn after very little game play or gambling.
A customer regularly gambles large amounts of money and appears to find a level of losses
acceptable.
In this instance, the customer may be spending the proceeds of crime and sees the losses as an
acceptable consequence of the process of laundering those proceeds.
A customers spend increases over a period of time, thereby masking high spend and potential
money laundering.
A customer spends little, but often, and his annual aggregate spend is high and out of kilter
with his expected spend.
A customer displays gambling patterns where spend is high but the risk is low, for example
gambling on red and black in roulette. The customer could be laundering money in a way that
guarantees minimal loss.
Instances of high spend by customers that lead to significant commercial risk for the operator
may also indicate suspicious activity.
Indicators to help establish suspicion that a transaction may be related to a terrorist activity
financing offence mostly resemble those relating to money laundering, although there are some
differences. For
example, amounts relating to terrorist financing generally may be smaller.
15.7.4. Financial Sanctions
It is the policy of Lordsexch to verify the identity of all customers, and to check that they
are not the subject of sanctions or other statutory measures prohibiting the Company from
providing its services.
The member of staff conducting verification of identity will complete the process by checking
that the customer is not the subject of sanctions or other statutory measures, using the
screening methods set out
by the MLRO. These include the direct
questions to the prospective customer, screening of all new customers against sanctions and
other databases (via
direct reference to an official list or using a commercially available product), and ongoing
screening of all customer names (via ongoing subscription to commercially available products and
automatic
uploads).
15.7.5. Adverse Media
Along with Sanctions and PEP databases, third-party providers offer a service that screens
individuals for adverse media.Lordsexch uses such a service to identify if a customer has been
identified by the
media as having links to financial crime, terrorist financing and/or other criminal
activity. These individuals, once
confirmed to be one and the same in
both media and among the Lordsexch customers, would only be allowed to continue using Lordsexch
services after a close review by the MLRO and/or senior management.
15.8. Anti-Bribery and Whistleblowing
As an extension to the AML/CFT efforts, Lordsexch also employs Anti-Bribery and Whistleblowing
Policies and Procedures. These are
standalone documents
that are available to all employees and are part of their onboarding package.
15.9. Employee Background Checks
Lordsexch is committed to establish and maintain procedures which enable it to be satisfied as
to the integrity of all new staff members and by extension their likeliness to follow the
Lordsexch policies and
procedures. To meet this requirement, the Human Resource Department is responsible for
undertaking all of the checks listed in relation to new members of staff and for retaining the
appropriate records:
Obtain and confirm references, if required;
Confirm their employment history and the qualifications they have;
Request a recent police conduct certificate; and
Request details of any regulatory action taken against them.
Fraud
We will seek criminal and contractual sanctions against any Customer involved in fraud,
dishonesty or criminal acts. We will withhold payment to any Customer where any of these are
suspected. The Customer
shall indemnify and shall be liable to pay to us on demand, all costs, charges or losses
sustained or incurred by us (including any direct, indirect or consequential losses, loss of
profit, loss of business
and loss of reputation) arising directly or indirectly from the Customer’s fraud,
dishonesty or criminal act.
Responsible Gaming Policy
Lordsexch is committed to endorsing responsible wagering among its customers as well as
promoting the awareness of problem gambling and improving prevention, intervention and
treatment.
Lordsexch’s Responsible Gambling Policy sets out its commitment to minimizing the negative
effects of problem gambling and to promoting responsible gambling practices.
Lordsexch supports the generation of online gamblers offering them a wide range of games and
entertainment. We also take responsibility for our product line-up.
The aim of Lordsexch is to provide the world’s safest and most innovative gaming platform
for adults. The offered clear and safe products allow each user to play within his financial
means and to
receive the highest quality service. Integrity,
fairness and reliability are the guiding principles of Lordsexch’s work. It is therefore
clear that
Lordsexch should do its best to avoid and reduce the problems, which can arise from
participation in gambling, particularly in cases of immoderate playing. At the same time it is
important to respect the
rights of those who take part in games of chance to a reasonable extent as means of
entertainment.
Responsible Gaming at Lordsexch is based on three fundamental principles: Security of the
player, Security of the game and Protection against gaming addiction. Together with research
institutes, associations
and therapy institutions, we work on creation of a responsible, secure and reliable framework
for online gaming.
Player security
We take responsibility for the security of our players. Protection of the players is based on
forbidding the attendance of the minors from participation in games and the protection of
privacy, which involves
responsible processing of personal data and payments. Fairness and the random nature of the
products offered are monitored closely by independent organizations. Marketing communication is
also geared towards
player protection: we promise only what players can receive in our transparent line.
Protection against gaming addiction: research – prevention – intervention
The majority of users who make sports bets, casino bets and other gaming offers play in
moderation for entertainment. Certain habits and behavior patterns (such as shopping, playing
sports, eating or
consumption of alcohol) which are considered to be normal and not causing any concern can
develop into addiction for some people and cause problems. In the same way, bets on sports and
gambling can lead to
problems for a small group of customers.
Clients with gaming addiction are prohibited from further participation in the gaming line-up.
Subsequently the customers are provided with contacts of organizations where they can receive
professional advice
and support.
Self-responsibility is the most sustainable form of prevention
The basic principle promoted by Lordsexch is that the final decision and responsibility on
whether to play or not, and how much money can be spent on the game should be assumed by the
customer himself.
Self-responsibility of the customer is therefore the most effective form of protection from
addiction. Lordsexch sees its responsibility in assisting the customers by providing transparent
products, full
information and keeping a clear line of conduct.
Protection of minors
Lordsexch does not allow minors (persons under the age of 18) to participate in games and make
bets. That’s why the confirmation of having reached the age of majority and the
confirmation of date of
birth are mandatory requirements during registration. Lordsexch considers the issue of minors
taking part in games and betting very seriously. In order to offer the best possible protection
of minors, we also
rely on the support of parents and caregivers. Please keep your data for account access in a
safe place (user ID and password).
Furthermore, we would recommend that you install filter software. This software will allow you
to restrict the access to Internet resources inappropriate for children and teenagers.
Responsibility towards problems
Lordsexch offers a variety of games and bets, which are forms of entertainment for the majority
of customers. At the same time the company takes responsibility for its customers by providing
support and tools
for maintenance of a secure and entertaining environment taking into account the associated
risks.
The clients who have difficulty in assessing risks, recognizing their own limits or those who
suffer from gambling addiction are not able to enjoy our product line-up responsibly and
perceive it as a form of
entertainment. Lordsexch takes responsibility for such users by blocking their access to its
products for their own protection.
Get informed with the main issues
Most people play for pleasure. Moderate participation in games within their financial capacity
is fully acceptable. However, for a small percentage of people gambling is not a form of
entertainment, it is a
challenge that must be considered seriously.
What is the problematic game behavior?
A problematic game behavior is considered to be such behavior, which interferes mode of life,
work, financial position or health of a person or his family. Long participation in games is
counter indicative to
such person as it can lead to negative consequences.
In 1980 the pathological game dependence has been officially recognized and enlisted in the list
of psychological diseases of international classification system DSM-IV and ICD-10. It is
defined as long,
repeating and frequently amplifying inclination for game, despite of existing negative personal
and social circumstances, such as a debt, rupture of family relations and delay of professional
growth.
In what cases behavior of a person should be considered as dependence?
It is necessary to underline that the diagnoses of game dependence can be qualified only by
experts. The material presented on this web-page will help you to estimate and define your own
game behaviour.
The special hazard of addictions that are not associated with any substance is that it is very
difficult to define the line between pleasure and addiction. Nevertheless, there are some
diagnostic signals that
may point out the existing problems. In the presence of at least five of the following symptoms,
the likelihood of the severe dependence is high:
The player is deeply involved in gambling, all his thoughts are only about the game.
Bet sum increases in course of time.
Attempts to quit or control his participation in the games appear to be unsuccessful.
When limiting his participation in gambling, a person experiences irritation and disappointment.
The game is a way to escape from problems or discomfort.
The player tries to win back the lost amount,
Lies about his playing behavior,
Commits illegal acts,
Spoils or breaks the relationship with family and colleagues,
Borrows to participate in the games.
Rules for responsible games
Following the rules placed below, you can enjoy the game without anxiety:
Start playing only when you are calm and concentrated.
Take regular breaks.
Define for yourself beforehand the monthly amount you can spend on the game.
Once setting a maximum limit, do not further increase it.
Before you start playing, define the maximum amount of winning, after reaching of which you
should stop playing.
Define the amount you can afford to lose beforehand.
Do not start playing under alcohol or drug influence.
Do not start playing in a depressed state.
Intellectual Property
We trade as Lordsexch and the Lordsexch name and logo are registered trademarks. Any
unauthorised use of our trademark and logo may result in legal action being taken against you.
The www.Lordsexch.co uniform resource
locator (URL) is owned by us and no unauthorised use of the URL is permitted on another website
or digital platform
without our prior written consent.
As between us and you, we are the sole owners of the rights in and to the Service, our
technology, software and business systems (the “Systems”) as well as our odds.
you must not use your personal profile for your own commercial gain (such as selling your status
update to an advertiser); and
when selecting a nickname for your Account we reserve the right to remove or reclaim it if we
believe it appropriate.
You may not use our URL, trademarks, trade names and/or trade dress, logos (the “Marks”)
and/or our odds in connection with any product or service that is not ours, that in any manner
is likely to
cause confusion among Customers or in the public or that in any manner disparages us.
Except as expressly provided in these Terms, we and our licensors do not grant you any express
or implied rights, licence, title or interest in or to the Systems or the Marks and all such
rights, licence,
title and interest specifically retained by us and our licensors. You agree not to use any
automatic or manual device to monitor or copy web pages or content within the Service. Any
unauthorised use or
reproduction may result in legal action being taken against you.
Your Licence
Subject to these terms and your compliance with them, we grant to you a non-exclusive, limited,
non transferable and non sub-licensable licence to access and use the Service for your personal
non-commercial
purposes only. Our licence to you terminates if our agreement with you under these Terms ends.
Save in respect of your own content, you may not under any circumstances modify, publish,
transmit, transfer, sell, reproduce, upload, post, distribute, perform, display, create
derivative works from, or in
any other manner exploit, the service and/or any of the content thereon or the software
contained therein, except as we expressly permit in these terms or otherwise on the website. No
information or content
on the service or made available to you in connection with the Service may be modified or
altered, merged with other data or published in any form including for example screen or
database scraping and any
other activity intended to collect, store, reorganise or manipulate such information or content.
Any non-compliance by you with this Clause may also be a violation of our or third parties’
intellectual property and other proprietary rights which may subject you to civil liability
and/or criminal
prosecution.
Your Conduct and Safety
We would like you to enjoy the Service. However, for your protection and that of all Customers,
the posting of any content on the service, as well as conduct in connection therewith and/or the
service, which
is in any way unlawful, inappropriate or undesirable is strictly prohibited - it is Prohibited
Behaviour. If you engage in Prohibited Behaviour, or we determine in our sole discretion that
you are engaging in
Prohibited Behaviour, your Lordsexch.co Account and/or your access to or use of the Service may
be terminated immediately without notice to you.
Legal action may be taken against you by another Customer, other third party, enforcement
authorities and/or us with respect to you having engaged in Prohibited Behaviour.
Prohibited Behaviour includes, but is not limited to, accessing or using the Service to:
promote or share information that you know is false, misleading or unlawful;
conduct any unlawful or illegal activity, such as, but not limited to, any activity that
furthers or promotes any criminal activity or enterprise, provides instructional information
about making or buying
weapons, violates another Customer’s or any other third party’s privacy or other
rights or that creates or spreads computer viruses;
iii. harm minors in any way;
transmit or make available any content that is unlawful, harmful, threatening, abusive,
tortuous, defamatory, vulgar, obscene, lewd, violent, hateful, or racially or ethnically or
otherwise objectionable;
transmit or make available any content that the user does not have a right to make available
under any law or contractual or fiduciary relationship, including without limitation, any
content that infringes a
third party’s copyright, trademark or other intellectual property and proprietary rights;
transmit or make available any content or material that contains any software virus or other
computer or programming code (including HTML) designed to interrupt, destroy or alter the
functionality of the
Service, its presentation or any other website, computer software or hardware;
vii. interfere with, disrupt or reverse engineer the Service in any manner, including, without
limitation, intercepting, emulating or redirecting the communication protocols used by us,
creating or using
cheats, mods or hacks or any other software designed to modify the Service, or using any
software that intercepts or collects information from or through the Service;
viii. retrieve or index any information from the Service using any robot, spider or other
automated mechanism;
participate in any activity or action that, in the sole and entire unfettered discretion of us
results or may result in another Customer being defrauded or scammed;
transmit or make available any unsolicited or unauthorised advertising or mass mailing such as,
but not limited to, junk mail, instant messaging, "spim", "spam", chain
letters, pyramid
schemes or other forms of solicitations;
create Lordsexch.co Accounts by automated means or under false or fraudulent pretences;
xii. impersonate another Customer or any other third party, or
xiii. any other act or thing done that we reasonably consider to be contrary to our business
principles.
The above list of Prohibited Behaviour is not exhaustive and may be modified by us at any time
or from time to time. If you become aware of the misuse of the service by another Customer or
any other person,
please contact us through the “Contact Us” section of the Website. We reserve the
right to investigate and to take all such actions as we in our sole discretion deems appropriate
or necessary
under the circumstances, including without limitation, deleting the Customer’s posting(s)
from the Service and/or terminating their account, and take any action against any Customer or
third party who
directly or indirectly in, or knowingly permits any third party to directly or indirectly engage
in, Prohibited Behaviour, with or without notice to such Customer or third party.
Links to Other Websites
The Service may contain links to third party websites that are not maintained by, or related to,
us, and over which we have no control. Links to such websites are provided solely as a
convenience to
Customers, and are in no way investigated, monitored or checked for accuracy or completeness by
us. Links to such websites do not imply any endorsement by us of, and/or any affiliation with,
the linked
websites or their content or their owner(s). We have no control over or responsibility for the
availability nor their accuracy, completeness, accessibility and usefulness. Accordingly when
accessing such
websites we recommend that you should take the usual precautions when visiting a new website
including reviewing their privacy policy and terms of use.
Self-exclusion
If you feel you are at risk of developing a gambling problem or believe you currently have a
gambling problem, please consider using Self-Exclusion which prevents you gambling with
Lordsexch for a specified
period of 6 months, 1 year, 2 years, 5 years or permanently.
If you want to stop playing for other reasons, please consider a Time-Out or using Account
Closure.
What happens when you self-exclude?
During a period of Self-Exclusion you will not be able to use your account for betting, although
you will still be able to login and withdraw any remaining balance. It will not be possible to
re-open your
account for any reason, and Lordsexch will do all it can to detect and close any new accounts
you may open.
Next steps
Whilst we will remove you from our marketing databases, we also suggest that you remove bet365
from your notifications and delete/uninstall all Lordsexch apps, downloads and social media
links. You may also
wish to consider installing software that blocks access to gambling websites, click here for
more information.
We recommend that you seek support from a problem gambling support service to help you deal with
your problem.
You can self-exclude your account in the My Gambling Controls section of Members by choosing
Self-Exclusion.
Alternatively you can contact our customer care team for assistance and further information.
Self-Exclusion Notice
Should you opt to self-exclude from Lordsexch, we strongly recommend that you seek exclusion
from all other gambling operators you have an account with.
You can self-exclude by contacting other gambling operators directly or you can exclude from
other Northern Territory licensed operators by completing a Self-Exclusion Notice form.
Once completed the Northern Territory Self-Exclusion Notice form should be submitted to the
nominated site, sports bookmaker or betting exchange operator.
Complaints
If you have any concerns or questions regarding these terms you should contact our Customer
Service Department via email at
[email protected]
NOTWITHSTANDING THE FOREGOING, WE TAKE NO LIABILITY WHATSOEVER TO YOU OR TO ANY THIRD PARTY WHEN
RESPONDING TO ANY COMPLAINT THAT WE RECEIVED OR TOOK ACTION IN CONNECTION THEREWITH.
Any Customer of the Service who has any concerns or questions regarding these Terms regarding
the settlement of any Lordsexch.co market should contact our Customer Service Department at
[email protected]
using their Registered Email Address.
If a Customer is not satisfied with how a bet has been settled then the Customer should provide
details of their grievance to our Customer Service Department via email at
[email protected]
We shall use our reasonable endeavours to respond to queries of this nature within a few days
(and in any event we intend to respond to all such queries within 28 days of receipt).
Disputes must be lodged within three (3) days from the date the wager in question has been
decided. No claims will be honored after this period. The Customer is solely responsible for
their Account
transactions. Complaints/disputes have to be sent to
[email protected]
and must be sent from the Customer’s Registered Email Address.
In the event of a dispute arising between you and us our Customer Service Department will
attempt to reach an agreed solution. Should our Customer Service Department be unable to reach
an agreed solution with
you, the matter will be escalated to our management in accordance with our Complaints Procedure
(available upon request).
The Customer has the right to lodge a complaint with one of our licensing bodies should all
efforts to resolve a dispute to the Customer’s satisfaction have failed.
Registration and Account Security
Customers of the service must provide their real names and information and, in order to comply
with this, all Customers must commit to the following rules when registering & maintaining
your Account:
you must not provide any false personal information on the Service, or create an Account for
anyone other than yourself;
you must not use your personal profile for your own commercial gain (such as selling your status
update to an advertiser); and
iii. when selecting a nickname for your Account we reserve the right to remove or reclaim it if
we believe appropriate.
Assignment
Neither these terms nor any of the rights or obligations hereunder may be assigned by you
without the prior written consent of us, which consent will not be unreasonably withheld. We
may, without your
consent, assign all or any portion of our rights and obligations hereunder to any third party
provided such third party is able to provide a service of substantially similar quality to the
Service by posting
written notice to this effect on the Service.
Severability
In the event that any provision of these terms is deemed by any competent authority to be
unenforceable or invalid, the relevant provision shall be modified to allow it to be enforced in
line with the
intention of the original text to the fullest extent permitted by applicable law. The validity
and enforceability of the remaining provisions of these terms shall not be affected.
Breach of These Terms
Without limiting our other remedies, we may suspend or terminate your account and refuse to
continue to provide you with the service, in either case without giving you prior notice, if, in
our reasonable
opinion, you breach any material term of these Terms. Notice of any such action taken will,
however, be promptly provided to you.
Governing Law and Jurisdiction
This Agreement shall in all respects be governed, interpreted by, and construed in exclusive
accordance with the laws of Curacao. All disputes, differences, complaints etc., shall be
subject to Arbitration
under the Curacao. The arbitrator will be appointed by the company after due consent from the
company and the user. The place of arbitration shall be Curacao.
General Provisions
Term of agreement. These terms shall remain in full force and effect while you access or use the
service or are a Customer of Lordsexch.co These terms will survive the termination of your
Lordsexch.co
Account for any reason.
Gender. Words importing the singular number shall include the plural and vice versa, words
importing the masculine gender shall include the feminine and neuter genders and vice versa and
words importing
persons shall include individuals, partnerships, associations, trusts, unincorporated
organisations and corporations.
Waiver. No waiver by us, whether by conduct or otherwise, of a breach or threatened breach by
you of any term or condition of these Terms shall be effective against, or binding upon, us
unless made in writing
and duly signed by us, and, unless otherwise provided in the written waiver, shall be limited to
the specific breach waived. The failure of us to enforce at any time any term or condition of
these Terms shall
not be construed to be a waiver of such provision or of the right of us to enforce such
provision at any other time.
Headings. The division of these Terms into paragraphs and sub-paragraphs and the insertion of
headings are for convenience of reference only, and shall not affect or be utilised in the
construction or
interpretation of these Terms agreement. The terms "these Terms", "hereof",
“hereunder” and similar expressions refer to these Terms and not to any particular
paragraph or
sub-paragraph or other portion hereof and include any agreement supplemental hereto. Unless the
subject matter or context is inconsistent therewith, references herein to paragraphs and
sub-paragraphs are to
paragraphs and sub-paragraphs of these Terms.
Acknowledgement. By hereafter accessing or using the Service, you acknowledge having read,
understood and agreed to each and every paragraph of these Terms. As a result, you hereby
irrevocably waive any
future argument, claim, demand or proceeding to the contrary of anything contained in these
Terms.
Language. In the event of there being a discrepancy between the English language version of
these rules and any other language version, the English language version will be deemed to be
correct.
Restricted countries: Lordsexch is one of the largest bookies in the world and also one of the
best known, but this bookmaker does not operate in all countries of the world due to
restrictions by the
governments of each country. Therefore, our service is restricted in the following countries:
Australia, Aruba, Bonaire, Curacao, France, The Netherlands, Saba, Statia, St. Maarten,
Singapore, Spain, the
United Kingdom, the USA and any other jurisdiction that the Central Government of Curacao deems
online gambling illegal. This includes all of the named Nations' Territories and
Possessions.
Entire agreement. These Terms constitute the entire agreement between you and us with respect to
your access to and use of the Service, and supersedes all other prior agreements and
communications, whether
oral or written with respect to the subject matter hereof.
Betting Rules
Any dispute related to the sports betting product shall be emailed to:
[email protected]
Casino Rules
Any dispute related to the casino product shall be emailed to:
[email protected]
Complete casino rules can be accessed from within the casino games.
ACCEPTING THE TERMS AND CONDITIONS
You hereby accept the fact that you have read, understood and are willing to abide by the above
Terms and Conditions.