AML Policy

1. Purpose and Scope

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML Policy”) sets out the principles and controls adopted by Luminia S.R.L. (“Luminia,” “Lotto Nuts,” “we,” “us,” or “our”) to prevent the misuse of the Services for money laundering, terrorist financing, fraud, or other illicit activities.

This Policy applies to:

• All users of the Site and Services as described in the Terms Of Use; and
• All transactions are facilitated through the Services.

2. Regulatory Positioning

Luminia:

• Is not a lottery operator, gambling operator, or financial institution;
• Does not accept wagers or hold gambling stakes;
• Provides administrative and courier-style facilitation services only.

Notwithstanding the above, Luminia voluntarily applies AML controls consistent with international best practices.

3. Risk-Based Approach

Luminia adopts a risk-based approach to AML compliance, taking into account:

• User location
• Transaction patterns
• Payment methods
• Behavioral indicators

Enhanced scrutiny may be applied where elevated risk is identified.

4. Customer Due Diligence 

4.1 Identity Verification

We may require users to provide information and documentation to verify their identity, including:

• Full name
• Date of birth
• Government-issued identification
• Proof of address

Verification may be conducted directly or through trusted third-party verification providers.

4.2 Ongoing Monitoring

User activity may be monitored on an ongoing basis to identify:

• Unusual or suspicious transactions
• Inconsistent or misleading information
• Activity that may indicate fraud or illicit conduct

Luminia reserves the right to request additional information at any time.

4.3 Enhanced Due Diligence

Enhanced due diligence may be applied in cases involving:

• High-risk jurisdictions
• Politically exposed persons (PEPs)
• Unusual transaction volumes or patterns

Failure to provide requested information may result in service restriction or termination.

5. Transaction Controls

Luminia may:

• Delay, suspend, or refuse transactions
• Impose limits on account activity
• Restrict withdrawals or prize-related assistance

Where required to comply with applicable laws or mitigate risk.

6. Reporting and Cooperation with Authorities

Where required by law, Luminia may:

• Report suspicious activity to competent authorities 
• Share information with regulators or law enforcement
• Comply with lawful information requests

Luminia does not notify users where doing so would breach legal obligations.

7. Record Keeping

Luminia retains AML-related records for a period consistent with applicable laws and regulatory best practices.

8. User Obligations

Users agree to:

• Provide accurate and truthful information
• Use the Services for lawful purposes only
• Cooperate with verification and compliance requests

Providing false or misleading information may result in immediate account termination.

9. No Guarantee of Service Continuity

Luminia does not guarantee uninterrupted access to the Services and may suspend or terminate access where AML concerns arise, without liability.

10. Updates to This Policy

This AML Policy may be updated periodically to reflect changes in law, regulation, or internal risk assessments. Updates will be published on the Site.

11. Contact

For AML or compliance-related inquiries: support@lottonuts.com