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KYC & AML Policy of Ludos Optima Ltd

Last updated: 14.05.2026

 

The Company adheres to and complies with “Know your customer” principles, which aim to prevent financial crime and money laundering through client identification and due.

 

Objective and scope of the policy

The purpose of this AML & KYC Policy or Policy on The Prevention of Laundering Proceeds of Crime and Financing of Terrorism and Know your Customer procedures is:

 

         To obtain information and develop employee awareness on the prevention of laundering proceeds of crime and financing of terrorism,

         To comply with the obligations regarding local regulations,

         To evaluate customers, transactions and services offered with a risk based approach and to mitigate those risks.

This policy shall be composed of the following measures:

         Know your customer principle

         Monitoring and control activities

         Suspicious transaction reporting

         Training

         Internal audit

 

Marius Club guarantee

All Users of http://marius.club Website ensure by accepting this Policy and Terms & Conditions at least the following:

 

a) The User has completed the registration form truthfully and correctly.

b) The User is not an individual under 18 years old or other legal age of majority in User's jurisdiction.

c) The User is neither under legal supervision nor restricted in his business activities.

d) The User has registered personally and not on the behalf of someone else.

e) The User uses the account for personal use and has no commercial intentions.

f) The User has no knowledge about any bet result of the underlying bet before placing it.

g) The User does not have multiple accounts on http://marius.club website.

h) The User has read and accepted this Policy.

i) The User cannot sell, transfer, assign and/or acquire by any other means the accounts to/from other Users.

j) The User assures that he/she won’t use his/her account to transfer funds amongst his/her accounts

Know your customer (KYC) procedures

Both international and local regulations require Ludos Optima Ltd (hereinafter "Marius Club") to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

 

Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (KYC). According to KYC, Marius Club establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.diligence.


The Company reserves the right, at any time, to ask for any KYC documentation it deems necessary to determine the identity and location of a
User in marius.club. We reserve the right to restrict the service, payment, or withdrawal until identity is sufficiently determined, or for any other reason in our sole discretion based on the legal framework.

 

We take a risk-based approach and perform strict due diligence checks and ongoing monitoring of all clients, customers, and transactions. As per the money laundering regulations, we utilize three stages of due diligence checks, depending on the risk, transaction, and customer type.

 

SDD — simplified due diligence is used in instances of extremely low-risk transactions that do not meet the required thresholds

 

CDD — customer due diligence is the standard for due diligence checks, used in most cases for verification and identification

 

EDD — Enhanced Due Diligence is used for high-risk customers, large transactions or special cases.

 

 

Separately and in addition to the above, when a User makes a deposit exceeding EUR 2000 or its equivalent, requests a withdrawal of any amount inside the marius.club, or attempts to or complete a transaction that is deemed suspicious (if there’re strong grounds to believe that there’s risk of commitment of fraud, money-laundering or any abuse on the part of the User or in case of frequent and major withdrawals by one User during a reasonably short period of time), then it is compulsory for them to complete the full KYC process.

 

Please note that Company can request you to undergo detailed KYC procedure under the present Policy before your deposit that is lower than EUR 2000 or its equivalent if such requirement is essential for processing payments through certain payment providers/institutions/banks.

 

During this process, the User will have to input some basic details about themselves and then send by email or upload:

 

1) A copy of Government Issued Photo ID (in some cases front and back depending on the ID document)

 

2) A selfie of themselves holding the ID doc

 

3) A bank statement/Utility Bill

 

Once uploaded or sent, the user will get a “Temporarily Approved” Status and the documents will now be on our side, and the “KYC Team” will have 24hrs to go over them and email the user about the outcome:

-          Approval

-          Rejection

-          More information needed – No change in Status

 

When the user is on “Temporarily Approved” Status then

-          They can use the platform normally

-          They cannot complete any withdrawal.

 

Marius Club will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Marius Club reserves the right to investigate certain Users who have been determined to be risky or suspicious.

 

Marius Club reserves the right to verify User’s identity in an on-going basis, especially when their activity seemed to be suspicious (unusual for the particular User). In addition, Marius Club reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

 

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Marius Club Privacy Policy and related regulations including European Data Protection Regulations.

 

Once the User’s identity has been verified, Marius Club is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

 

Guideline for the “KYC Process”

 

1) Proof of ID:

 

a. Signature Is there

b. Country is not one of the following Restricted Countries as stated in the T&C:

          Afghanistan 

          Algeria

          American Samoa 

          Aruba 

          Australia

          Austria

          Bonaire, Sint Eustatius and Saba 

          Cambodia

          Cayman Islands 

          China 

          Christmas Island 

          Cocos Islands 

          Curaçao 

          Cyprus 

          France and it’s territories 

          French Guiana 

          French Polynesia 

          Germany

          Gibraltar 

          Guadeloupe 

          Guam 

          Heard and McDonald Islands 

          Iran 

          Iraq

          Israel 

          Laos 

          Lebanon 

          Libya 

          Martinique

          Mayotte 

          Netherlands and it’s territories

          New Caledonia 

          Norfolk Island 

          North Korea 

          Northern Mariana Islands 

          Pakistan 

          Puerto Rico 

          Qatar 

          Russia 

          Réunion 

          Saint Barthélemy 

          Saint Martin 

          Saint Pierre and Miquelon 

          Sint Maarten (Dutch part)

          Somalia 

          Spain 

          Syrian Arab Republic 

          Turkey 

          U.S. Virgin Islands 

          Ukraine

          Union of Comoros

          United Arab Emirates 

          United Kingdom 

          United States of America and its territories

          Wallis and Futuna 

          Yemen

         All FATF Blacklisted countries,

    any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority

 

c. Full Name matches client’s name

 

d. Document does not expire in the next 3 months

 

e. Owner is over 18 years of age or other age of majority

 

2) Proof of Residence

 

a. Bank Statement or Utility Bill

 

b. Country is not one of the following Restricted Countries as stated in the T&C:

 

          Afghanistan 

          Algeria

          American Samoa 

          Aruba 

          Australia

          Austria

          Bonaire, Sint Eustatius and Saba 

          Cambodia

          Cayman Islands 

          China 

          Christmas Island 

          Cocos Islands 

          Curaçao 

          Cyprus 

          France and it’s territories 

          French Guiana 

          French Polynesia 

          Germany

          Gibraltar 

          Guadeloupe 

          Guam 

          Heard and McDonald Islands 

          Iran 

          Iraq

          Israel 

          Laos 

          Lebanon 

          Libya 

          Martinique

          Mayotte 

          Netherlands and it’s territories

          New Caledonia 

          Norfolk Island 

          North Korea 

          Northern Mariana Islands 

          Pakistan 

          Puerto Rico 

          Qatar 

          Russia 

          Réunion 

          Saint Barthélemy 

          Saint Martin 

          Saint Pierre and Miquelon 

          Sint Maarten (Dutch part)

          Somalia 

          Spain 

          Syrian Arab Republic 

          Turkey 

          U.S. Virgin Islands 

          Ukraine

          Union of Comoros

          United Arab Emirates 

          United Kingdom 

          United States of America and its territories

          Wallis and Futuna 

          Yemen

         All FATF Blacklisted countries,

    any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority

 

 

c. Full Name matches client’s name and is same as in proof of ID.

 

d. Date of Issue:

 

In the last 3 months.

 

3) Selfie with ID

 

a. Holder is the same as in the ID document above

 

b. ID document is the same as in “1”. Make sure photo/ID number is the same

 

 

Notes on the “KYC Process”

 

1)    When the KYC process is unsuccessful then the reason is documented and a support ticket is created in the system. The ticket number along with an explanation is communicated back to the user.

2)    Marius Club may reject any User in its sole discretion without being obliged to disclose any reason for the rejection.

3)    Once all proper documents are in our possession then the account gets approved.

4)    In case the automatic procedures fail, Marius Club shall contact the User by email or other means to obtain the information and documents needed. In case the User does not provide the documents in the requested form and any other information requested to satisfy the AML/KYC check, Marius Club may deny the User’s withdrawal or “freeze” the account of the User for playing (in case of KYC check during depositing) until such document or information is provided.

 

“Other AML measures”

 

1)    If a user has not passed full KYC then they cannot make additional deposits or withdrawals of any amount.

2)    If a user has passed the KYC process successfully then

a.     There is a deposit limit per transaction (maximum limit varies depending on payment service providers’ limits)

b.     Prior to any withdrawal there is a detailed algorithmic and manual check on the activity and balance of the user to see if the amount withdrawn is a result of proper activity in the platform.

3)    Under no circumstances may a user transfer funds directly to another user.

 

Anti-money laundering policy

Marius Club enforces a strict anti-money laundering policy with zero tolerance to money laundering activities. We define money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.

All Marius Club affiliates are obligated to comply with this anti-money laundering policy and internal AML Manuals and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.

Marius Club ensures complete compliance with laws pertaining to anti-money laundering through its related policy.

Marius Club implements a range of filtration operations for swift and accurate identification of any financial activities that may constitute or are related to money laundering. This helps ensure a money laundering-free financial operations throughout the Marius Club Platform.

All Users acknowledge, undertake and agree to the following terms regarding their use of marius.club Website and games available on it, opening and maintenance of User Account at Marius Club and for all financial transactions as a Marius Club client:

a) The User will comply (while being a Marius Club client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities.

b) Marius Club operates under certain obligations known as “know-your-client” obligations which grant Marius Club the right to implement anti-money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity.

c) The User agrees fully cooperate with Marius Club with respect to anti-money laundering efforts. This involves providing information that Marius Club requests regarding the client’s business details, account usage, financial transactions etc. to help Marius Club perform its duties as dictated by Applicable laws regardless of jurisdiction.

d) Marius Club reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices.

e) Marius Club reserves the right to suspend or cancel any account or freeze the funds at the account if there is reason to believe that the account is being used for activities that are deemed unlawful or fraudulent.

f) Marius Club has the right to use client information for the investigation and/or prevention of fraudulent or otherwise illegal activities.

g) Marius Club has the right to share client information with:

         Investigative agencies or any authorized officers who are helping Marius Club to comply with applicable law, including anti-money laundering laws and know-your-client obligations on the basis of the Non-disclosure agreement concluded between Marius Club and such agencies or officers;

         Organizations that help Marius Club to provide the services that it offers to its clients on the basis of the Non-disclosure agreement concluded between Marius Club and such organizations;

         Government, law enforcement agencies and courts;

         Regulatory bodies and financial institutions.

 

Activities that Marius Club considers possible indications of money laundering include:

a) The client showing unusual apprehension or reservations about Marius Club’s anti-money laundering policies.

b) The client’s interest in conducting financial transactions which are contrary to good business sense or are inconsistent with the client’s business policy.

c) The client failing to provide the proof of legitimate sources for their funds.

d) The client providing false information regarding the source of their funds.

e) The client having a history of being the subject of news that is indicative of civil or criminal violations.

f) The client seems to be acting as a ‘front man’ for an unrevealed person or business, and does not satisfactorily respond to requests for identifying this person or business.

g) The client not able to easily describe the nature of his/her industry.

h) The client frequently makes large deposits and demands dealing in cash.

i) The client maintains multiple accounts and conducts an unusually high number of inter-account or 3rd party transactions.

j) The client’s previously usually inactive account starts receiving a surge of wire activity.

The above list is by no means an exhaustive list. Marius Club monitors its client and account activity in light of several other red flags and takes appropriate measures to prevent money laundering.