JLCludo (Company, We, Us) is committed to carrying on business in accordance with the highest ethical and business standards. This includes complying with all applicable laws and regulations aimed at combating money laundering and related illegal activities.

As an integral part of its business operations, the Company has instituted compliance measures commensurate with its Services, and to deter any potential illicit activity on its Platform. These measures may include, without limitation, onboarding and ongoing customer screening, and transaction-based controls.

This Anti Money Laundering Policy (AML Policy) describes the Company’s measures to detect and deter illicit activity on its Platform. It must be read in conjunction with our Terms of Use and Privacy Policy and is binding on all users.

User Identification Protocol

1. The Company takes reasonable measures to establish the identity of any person to whom it provides Services.

2. The Company collects certain minimum player identification details from each User who registers an account with Us.

3. Registered Users who wish to withdraw funds from their account may be required to first have their accounts officially confirmed by the Company. For this, valid photo identification and address proof documents may be required. Failure to provide these may result in the forfeiture of amounts sought to be withdrawn.

4. Withdrawals may be permitted subject to submission of a User’s PAN, Aadhaar, geolocation verification, and withdrawal bank details.

5. The Company may also request further KYC documents or additional personal information in accordance with applicable laws.

User Obligations

1. Users accept they must comply with this AML Policy and confirm they are not using the Platform to commit any offences.

2. Users must ensure they submit accurate and up-to-date personal information that belongs to them.

Transaction Monitoring

1. We monitor activity on the Platform, through manual and automated means, using rule-based systems to detect unusual or suspicious behaviour. Payments can only be made through integrated electronic gateways. Cash transactions are not allowed.

2. If we detect suspicious behaviour, we may:

• Request more information/documents
• Mandate additional KYC
• Restrict, suspend, or terminate accounts
• Disallow withdrawals
• Report suspicious transactions to law enforcement

Suspicious transactions may include unusually complex transactions, transactions lacking economic basis, or transactions potentially involving proceeds of offences listed under the Prevention of Money Laundering Act, 2002.

We maintain transaction records for the required timelines under applicable laws. For compliance, we may contact you from time to time.

Changes to AML Policy

The Company may revise this AML Policy from time to time without prior notice. Updates will be made available on our official website: https://www.jlcludo.in or you may contact us at: contact@jlcludo.in.