Sky Margins Limited, operating LotterySpy (“we,” “us,” or “our”), is committed to maintaining a strong culture of integrity, security, and responsible platform operation. We actively work to prevent and guard against our platform being used, directly or indirectly, as a medium for money laundering, terrorist financing, proliferation financing, fraud, or any other activity that facilitates criminal or terrorist activity.

We are equally committed to preventing the misuse of our technology platform and available payment channels for unlawful purposes.

This Anti-Money Laundering and Counter-Terrorist Financing Policy (this “Policy”) explains our approach to customer risk assessment, customer due diligence, transaction monitoring, suspicious activity detection and reporting, sanctions screening, record-keeping, and cooperation with competent authorities, in accordance with applicable laws and regulatory requirements in the Republic of Ghana.

This Policy is designed to support compliance with the applicable anti-money laundering and counter-terrorist financing framework of the Republic of Ghana, including:

• The Anti-Money Laundering Act, 2020 (Act 1044), as amended;
• The Anti-Terrorism Act, 2008 (Act 762), as amended by the Anti-Terrorism (Amendment) Act, 2012 (Act 842);
• The Financial Intelligence Centre Act, 2016 (Act 917);
• Applicable regulations, guidelines, directives, notices, and other requirements issued by Ghana’s Financial Intelligence Centre (“FIC”) or another competent authority; and
• Applicable United Nations and domestic sanctions requirements concerning designated persons, entities, and jurisdictions.

This Policy is intended to operate alongside any licensing, regulatory, contractual, and statutory requirements that apply to Sky Margins Limited and the services actually provided through LotterySpy.

Money Laundering refers generally to processes through which criminal proceeds are concealed, disguised, converted, transferred, or otherwise made to appear legitimate.

Terrorist Financing refers generally to the provision, collection, possession, movement, or availability of funds or other property for purposes connected with terrorism, as defined by applicable law.

Proliferation Financing refers generally to the provision of funds or financial services connected with the manufacture, acquisition, possession, development, export, transport, or use of weapons of mass destruction or related materials, where prohibited by applicable law.

Predicate Offence means a criminal offence that generates proceeds which may subsequently become the subject of a money laundering offence.

Customer Due Diligence (CDD) means the procedures used to identify and understand customers and assess the risks associated with their relationship or activity.

Enhanced Due Diligence (EDD) means additional measures applied where a customer, transaction, relationship, or other circumstance presents increased financial crime risk.

Suspicious Transaction Report (STR) means a report submitted to the appropriate competent authority where activity gives rise to a legally reportable suspicion.

• Placement — the introduction or movement of illicit proceeds into financial or commercial channels.
• Layering — the use of transactions or transfers intended to make the origin, ownership, movement, or destination of illicit funds more difficult to identify.
• Integration — the reintroduction of previously concealed proceeds into the legitimate economy in a manner intended to make them appear legitimate.

Our controls are designed to identify and manage risks associated with these and other financial crime typologies that may be relevant to our platform.

This Policy applies to users of the LotterySpy platform, including individuals who register accounts, make payments, purchase available Products or services, receive payments where applicable, or otherwise transact through the Site.

It also applies to employees, contractors, and Forecasters to the extent that their responsibilities involve customer accounts, payments, transactions, platform security, or financial crime risk.

Employees and contractors are expected to escalate relevant knowledge or reasonable suspicion of money laundering, terrorist financing, proliferation financing, fraud, or other financial crime through the internal procedures established by LotterySpy.

LotterySpy recognizes that digital platforms and payment channels can potentially be misused for financial crime. Depending on the services and payment functionality actually available on the platform, relevant risks may include:

• Using proceeds of crime to purchase LotterySpy Products or services for the purpose of disguising or transferring the source of funds.
• Using another person’s account, payment method, or wallet to move funds or conceal the identity of the person controlling the funds.
• Structuring transactions across multiple accounts, payment instruments, or wallets in an attempt to avoid applicable monitoring or reporting requirements.
• Rapid movement of funds through an account without a clear or reasonable relationship to the customer’s expected activity.
• Attempts to manipulate, circumvent, or exploit platform, payment, identity-verification, or security controls.

These risks may arise through external users, third parties, or internal misconduct. LotterySpy therefore applies controls intended to identify, investigate, and escalate potentially suspicious activity.

We apply a risk-based approach to customer due diligence. This means that the level and nature of monitoring or verification may vary according to the risk presented by a customer, account, transaction, product, payment method, or other relevant circumstance.

Factors that may contribute to a higher-risk assessment include:

• The outcome of our Know Your Customer (KYC) process;
• The payment methods or instruments used;
• Multiple accounts or apparently linked accounts or payment wallets;
• Transaction patterns that appear inconsistent with the customer’s expected activity;
• False, incomplete, inconsistent, or unverifiable identity information;
• Information suggesting that an account may be operated by a person who does not satisfy our eligibility requirements;
• Requests to transfer funds or applicable payouts to unrelated third parties;
• Potential collusion, fraud, manipulation, or employee misconduct; and
• Attempts to interfere with, circumvent, or tamper with our website, systems, databases, or controls.

Where an account or activity presents increased risk, we may request additional information, apply enhanced monitoring, restrict particular activities, delay a transaction while checks are completed, or take other measures permitted by applicable law.

Where required or permitted by law, we may restrict or terminate an account and report relevant activity to the appropriate competent authority.

Depending on the services you use and the level of verification required, we may collect information such as:

• Date of birth or age information;
• Gender, where required for account or verification purposes;
• First and last name;
• Email address;
• Country of residence;
• Telephone or mobile number;
• Payment or mobile money wallet information;
• Username and account credentials; and
• Identification documents or photographs where additional identity verification is required.

The information collected will depend on the account, transaction, Product, applicable regulatory requirements, and risk assessment involved.

Personal information and transaction records collected for compliance purposes are retained in accordance with applicable law and our Privacy Policy.

Customer due diligence may include collecting and verifying information necessary to establish the customer’s identity, understand the nature of the relationship, assess relevant risk, and meet applicable legal requirements.

Where a customer, transaction, or relationship presents increased risk, Enhanced Due Diligence may include:

• Requesting a valid government-issued identification document;
• Additional identity verification;
• Requesting information or documentation concerning the source of funds or source of wealth where appropriate;
• Additional verification of the payment method or wallet associated with the account;
• Additional transaction monitoring; and
• Escalation to appropriate management or the AML Compliance Officer before certain transactions or payments are completed.

The specific measures applied will depend on the nature and level of risk identified and the requirements of applicable law.

Identity verification may include several stages depending on the services being accessed and the applicable risk assessment.

1. A one-time verification code may be sent by SMS or another approved method to the contact information associated with your account.
2. You may be required to enter the verification code through the Site.
3. Where additional verification is required, you may be asked to provide appropriate identification or supporting information.
4. For qualifying transactions or higher-risk situations, additional identity verification may be required before a transaction or applicable payout can be completed.

Completion of one verification step does not prevent LotterySpy from requesting additional information where required by law, our risk assessment, or our internal compliance procedures.

Customer due diligence does not necessarily end at registration. Where appropriate, we monitor account and transaction activity on an ongoing basis to identify behaviour that may be inconsistent with a customer’s expected profile or may indicate financial crime risk.

Monitoring may consider factors such as transaction frequency and value, payment methods, account relationships, withdrawal requests, unusual activity, repeated failed verification attempts, and other relevant risk indicators.

Where monitoring identifies activity requiring further investigation, we may request additional information, apply enhanced due diligence, restrict activity, or escalate the matter to the AML Compliance Officer or another appropriate authority within the organization.

Depending on the circumstances, activity that may warrant additional review for money laundering, terrorist financing, fraud, or related financial crime risk can include:

• Transaction activity that appears inconsistent with the customer’s known or expected profile.
• Rapid movement of funds without a clear economic or legitimate purpose.
• Third-party funding, withdrawals, or payment arrangements that cannot be reasonably explained.
• Multiple accounts, payment instruments, or wallets apparently controlled by related persons for the purpose of moving or concealing funds.
• Repeated attempts to structure transactions to avoid applicable monitoring or reporting requirements.
• False, inconsistent, or suspicious identity information.
• Attempts to bypass KYC, transaction monitoring, payment, or security controls.
• Information suggesting that funds may be connected to criminal activity, terrorism, proliferation financing, sanctions violations, or fraud.

The presence of an indicator does not by itself establish that criminal activity has occurred. It may instead trigger additional review, information requests, monitoring, or escalation.

Where applicable law establishes a threshold or reporting requirement for cash transactions, LotterySpy will record and report qualifying transactions in accordance with the applicable legal and regulatory requirements.

The applicable reporting threshold may change when Ghanaian law, regulations, directives, or competent-authority requirements change. LotterySpy therefore applies the threshold and reporting requirements legally applicable at the relevant time rather than publishing an outdated figure in this Policy.

Transactions may also be subject to monitoring or reporting where they are considered suspicious, regardless of whether the transaction amount is below a particular threshold.

Where activity gives rise to a legally reportable suspicion of money laundering, terrorist financing, proliferation financing, or another relevant offence, the matter will be escalated through our internal compliance procedures.

The AML Compliance Officer or another appropriately designated person is responsible for assessing relevant information and determining whether a Suspicious Transaction Report (“STR”) or other report is required under applicable law.

Where an STR is required, it will be submitted to Ghana’s Financial Intelligence Centre or another competent authority within the period and through the process prescribed by applicable law.

We maintain appropriate records of relevant internal assessments, decisions, and reports in accordance with our legal and regulatory obligations.

LotterySpy maintains appropriate records required for the administration of its AML and counter-terrorist financing controls. Depending on the circumstances, these records may include:

• Customer identification and KYC information;
• Transaction and payment records;
• Risk assessments and Enhanced Due Diligence records;
• Internal suspicious activity assessments;
• STR-related records and reports; and
• Other compliance records required by applicable law or regulatory requirements.

Records are retained for the period required by applicable law and may be made available to the Financial Intelligence Centre or another competent authority where there is a lawful basis for requesting them.

Record retention is also subject to our Privacy Policy and applicable data-protection requirements.

LotterySpy may restrict, suspend, or close an account where we reasonably believe that the account or activity presents a significant financial crime, fraud, sanctions, identity, security, legal, or regulatory risk.

We may also delay or restrict a transaction while completing identity verification, Enhanced Due Diligence, transaction review, or another compliance process.

Where an account is restricted or closed because of suspected unlawful activity, we may take any additional action required or permitted by applicable law, including reporting relevant information to a competent authority.

We will not automatically treat a blocked account balance as forfeited solely because an account has been restricted. The handling of funds will depend on the circumstances, applicable law, the outcome of any investigation, and any instructions or requirements imposed by a competent authority.

LotterySpy takes reasonable steps to identify and manage applicable sanctions risks. Where appropriate, screening may be conducted against relevant United Nations, Ghanaian, and other applicable sanctions or designated-person lists.

Where a customer, transaction, or other activity is identified as potentially subject to applicable sanctions restrictions, we may suspend or restrict the relevant activity while the matter is reviewed.

Where required by law, we may close or restrict an account and report relevant information to a competent authority.

Sky Margins Limited maintains an AML compliance function responsible for overseeing the implementation and ongoing operation of this Policy.

The AML compliance function is responsible for activities including reviewing suspicious activity referrals, overseeing applicable customer due diligence measures, maintaining required compliance records, coordinating relevant internal escalation, supporting regulatory reporting, and acting as an appropriate liaison with competent authorities.

Employees and contractors whose responsibilities involve customers, payments, transactions, or platform operations are expected to understand and follow applicable AML and counter-terrorist financing procedures.

Relevant personnel may receive periodic training on identifying, preventing, escalating, and documenting financial crime risks.

Information relating to suspicious activity reviews, regulatory reports, investigations, and other confidential compliance matters is handled with appropriate confidentiality.

Where applicable law prohibits disclosure, LotterySpy will not inform a customer or another unauthorized person that a Suspicious Transaction Report has been submitted or that a related investigation is underway.

Employees, contractors, and other persons involved in the compliance process are expected to follow applicable confidentiality and anti-tipping-off requirements.

Nothing in this section prevents LotterySpy from providing information where disclosure is legally required or otherwise lawfully permitted.

LotterySpy cooperates with Ghana’s Financial Intelligence Centre, law enforcement agencies, regulators, and other competent authorities in accordance with applicable law.

Where legally required or permitted, we may provide customer information, transaction records, compliance records, suspicious activity information, or other relevant information in response to a valid request, court order, regulatory requirement, or other lawful process.

We may also take appropriate action to preserve records or protect the integrity of an investigation where legally required or reasonably necessary.

This Policy is reviewed periodically and may be updated to reflect changes in applicable law, regulatory guidance, financial crime risks, our business operations, technology, payment arrangements, or internal controls.

Material changes will be reflected by an updated “Last updated” date at the top of this page.

Where appropriate, we may also provide additional notice of material changes through the Site or other suitable communication channels.

We encourage users, employees, Forecasters, and other relevant stakeholders to review this Policy periodically.

If you have questions about this Anti-Money Laundering and Counter-Terrorist Financing Policy, or wish to report information concerning suspected financial crime involving the LotterySpy platform, you may contact us using the details below:

LotterySpy · Sky Margins Limited
Email: info@lotteryspy.com

Please provide enough information for us to understand the concern and investigate it appropriately. Do not include passwords, payment-card numbers, or other unnecessary sensitive information in an initial email.

Where appropriate, matters may also be reported directly to Ghana’s Financial Intelligence Centre or another competent authority.