Anti-Money Laundering (AML) Policy

1. Purpose

Lucky Duck Labs LLC (“Lucky Duck,” “we,” “us,” or “our”) is committed to preventing money laundering, terrorist financing, fraud, and other illicit financial activity. This Anti-Money Laundering (“AML”) Policy outlines the procedures and controls we use to identify, monitor, and mitigate financial crime risks associated with our platform.

This Policy is designed to comply with applicable U.S. laws and regulations and to align with the requirements of our payment processors, financial partners, and service providers.

2. Scope

This AML Policy applies to:

• All users of the Lucky Duck platform
• All transactions, including paid entries, refunds, credits, and prize fulfillment
• All employees, contractors, and service providers acting on behalf of Lucky Duck

Lucky Duck is not a bank, money services business, or financial institution, but we voluntarily implement AML controls appropriate to our business model.

3. Risk-Based Approach

Lucky Duck uses a risk-based approach to AML compliance, meaning we apply heightened scrutiny where the risk of illicit activity is higher.

Risk factors considered include, but are not limited to:

• Transaction size and frequency
• Payment method behavior
• Refund activity patterns
• Account activity velocity
• Jurisdictional risk
• Identity inconsistencies

4. Customer Identification & Verification

We collect identifying information necessary to operate our platform and comply with legal and contractual obligations, which may include:

• Name and contact information
• Email address
• Billing and payment details
• Account activity history

For prize fulfillment, fraud prevention, or legal compliance purposes, we may require additional verification, including:

• Identity verification
• Proof of eligibility
• Tax documentation (where required by law)

Lucky Duck reserves the right to restrict, suspend, or terminate accounts that fail verification or provide false or misleading information.

5. Transaction Monitoring

We monitor transactions for suspicious or unusual activity, including but not limited to:

• Rapid or repetitive high-value transactions
• Unusual refund or chargeback behavior
• Attempts to exploit promotions, odds, or entry mechanics
• Structuring transactions to avoid limits or detection
• Use of multiple accounts to bypass restrictions

Monitoring may be conducted through automated tools, manual review, or third-party fraud and risk platforms.

6. Prohibited Activities

The following activities are strictly prohibited on the Lucky Duck platform:

• Use of the Services to launder money or conceal the origin of funds
• Use of stolen, fraudulent, or unauthorized payment methods
• Attempting to convert entries, credits, or prizes into cash equivalents through manipulation
• Coordinated abuse of promotions or refunds
• Acting on behalf of another person to obscure identity or ownership

Any suspected prohibited activity may result in immediate account suspension and reporting where required by law.

7. Refunds and Promotion Cancellations

Refunds issued by Lucky Duck — including refunds resulting from canceled or unsold promotions — are returned only to the original payment method used for the transaction.

Lucky Duck does not provide:

• Cash refunds
• Refunds to alternative payment instruments
• Refunds to third parties

This policy helps prevent misuse of refunds for laundering or value transfer.

8. Reporting and Escalation

If suspicious activity is detected, Lucky Duck may:

• Conduct enhanced review of the account or transaction
• Suspend or restrict account access
• Decline transactions
• Retain records and documentation
• Cooperate with payment processors or financial partners
• Report activity to appropriate authorities where legally required

Lucky Duck will comply with lawful requests from regulators, courts, or law enforcement agencies.

9. Record Keeping

We maintain records related to transactions, entries, refunds, and verifications for a period consistent with applicable laws, contractual obligations, and legitimate business needs.

Records are stored securely and accessed only by authorized personnel.

10. Third-Party Service Providers

Lucky Duck relies on regulated third-party service providers (such as payment processors and fraud prevention platforms) to support AML compliance.

These providers maintain their own AML programs and controls, which complement our internal policies.

11. Training and Awareness

Employees and contractors with access to financial systems or customer data are trained to:

• Identify red flags associated with fraud or money laundering
• Escalate concerns appropriately
• Follow internal controls and procedures

12. Policy Review and Updates

This AML Policy is reviewed periodically and updated as necessary to reflect changes in:

• Applicable laws and regulations
• Business operations
• Risk profile
• Industry best practices

Material updates will take effect upon publication.

13. Contact

Questions or concerns regarding this AML Policy may be directed to: hello@tryluckyduck.com