«AML & KYC POLICY»

ANTI-MONEY LAUNDERING (AML) PROGRAM

1. COMPANY POLICY

1.1 It is the policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

1.2 Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.

1.3 Unlike money laundering, terrorist financing is typically motivated by ideological, rather than profit-seeking concerns, and often may not involve the proceeds of criminal conduct. Money laundering is frequently an important component of terrorist financing, and the methods used are often similar or identical to those used by money launderers. Large sums are not necessarily involved, and the original funds may well be legitimate rather than illegally obtained. The goal of terrorist financing is to establish flexible and mobile sources of funding for the purchase of products and services that will be used to further or commit terrorist acts.

2. OBJECTIVE OF THE POLICY

2.1 The Company is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risks such as the risks to its reputation, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

2.2 The Company’s policies, procedures and internal controls are designed to ensure compliance with all applicable laws, rules, directives and regulations relevant to the Company’s operations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place.

3. AML COMPLIANCE OFFICER

3.1 The Compliance Officer, or any of his or her authorized employees, is responsible for ensuring:

1. Company’s ongoing compliance with all state AML laws, including monitoring compliance by the Company’s employees with their obligations under Company’s AML program;
2. That Company’s AML Program is updated as necessary; and
3. That all non-construction employees receive training on AML requirements before conducting business on behalf of the Company and, thereafter, on an ongoing basis as needed.

4. PLAYER IDENTIFICATION PROGRAM

4.1 The Company will take reasonable steps to establish the identity of any person for whom it is proposed to provide its service (hereinafter “Players”). For this purpose the process for the registration of Players provided for under the General Terms and Conditions of the Company provides for the due diligence process that must be carried out before the opening of a user account.

4.2 The Company will keep at all times a secure online list of all registered Players and information and documents will be retained in accordance with the applicable data protection obligations.

4.3 The Company will collect certain minimum Player identification information from each Player who opens an account. The Company will not accept to open anonymous accounts or accounts in fictitious names such that the true beneficial owner is not known. The information required will include at least:

1. Player’s date of birth (showing that the player is over eighteen (18) years of age);
2. Player’s first and last name;
3. Citizenship;
4. Player’s credit card or banking information;
5. Player’s valid email address; and
6. Player’s username and a password.

4.4.Documents to verify the identity information received will be requested from the Player if and when there is considered to be risk or uncertainty about the information provided and prior to any payment in excess of EUR 2,000 per occasion or when payments to the account are made in excess of EUR 2,000 and to all payment out. These documents shall include, to the extent permitted under the relevant data protection regulations:

1. A copy of a valid identity card or passport;
2. Proof of address;

4.5 Any employee of the Company who becomes aware of an uncertainty in relation to the accuracy and truthfulness of the Player information provided shall immediately notify the AML Compliance Officer, who will review the materials and determine whether further identification is required and or so that it may be determined whether a report is to be sent to the relevant authorities.

4.6 The Company will perform a search regarding a Player in the government sanctions lists, politically exposed person lists, anti-terrorism watchlists, anti-money laundering watchlists, CIA watchlists, global watchlists, nationals lists maintained by the USA, EU, UK, UN, and other states, organisations, and their bodies (collectively, the “Sanctions Lists”). The Company will take reasonable steps to search for possible relations between a Player and persons included in the Sanctions Lists.

4.7 If any material personal information of a Player changes, verification documents will be requested.

4.8 Records of identification and verification of customers must be kept for a period of five years after the business relationship with the customer has ended, for example where the customer closes their gambling account with the operator or ceases to visit or use the casino.

4.9 Based on the risk, that shall be determined on a case by case basis in accordance risk assessment criteria, and to the extent reasonable, using risk-based procedures to verify and document all and any information received by the Company in regards to a Player, the Company will ensure and make all necessary efforts to form a reasonable belief that the Company (a) knows the true identity of the Player and (b) information and documents provided by the Player are accurate and true. The Company will analyze all the information and documents received and/or collected from a Player in order to verify whether such information and/or documents are sufficient to form a reasonable belief that the Company knows the true identity of a Player. Players’ identity may be verified through documentary and/or non-documentary (including, electronically) means. The Company may use any appropriate verify method based on each case risk.

5. PLAYERS WHO REFUSE TO PROVIDE INFORMATION

5.1 If a potential or existing Player either refuses to provide the information described above in sections 4.3 and 4.4 when requested, or appears to have intentionally provided misleading information, the Company will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, the AML Compliance Officer will be notified so that it may be determined whether a report is to be sent to the relevant authorities.

6. CONTINUOUS TRANSACTION DUE DILIGENCE

6.1 The Company will monitor account activity with special attention, and to the extent possible, the background and purpose of any more complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.

6.2 Monitoring will be conducted through the following methods:

Transactions will be automatically monitored and a report will be generated daily that show all transactions above 2000 EUR along with all the details of the users making those transactions. An additional report will be generated daily per user if: a) the user made a transaction above 2000 EUR ; or b) the user requires the withdrawal of any sum The report will consist of the user’s detailed collected ID documents, collected personal details, and their entire account transaction history.

6.3 The AML Compliance Officer will be responsible for this monitoring, will review any activity that the monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the relevant authorities.

6.4 Parameters that signal possible money laundering or terrorist financing («Red Flags») include, but are not limited to:

1. Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent reason.
2. Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately withdrawn or wired out.
3. Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent specific purpose.

6.5 When an employee of the Company detects any activity that may be suspicious, he or she will notify the AML Compliance Officer. AML Compliance Officer will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or filing a report.

6.6 To the extent the Company utilizes a third party to process and record payments to and from Player and accounts, the Company will ensure the services provider has transaction monitoring systems in place which will allow for screening of the transactions pursuant to these provisions and in accordance with the applicable legislation. The AML Compliance Officer shall be responsible to review the relevant service agreement with the service provider to ensure the adequacy of the agreement.

6.7 Records relating to the financial transactions shall be maintained in accordance with the data protection and retention requirements in the applicable jurisdiction of Curaçao.

7. SUSPICIOUS TRANSACTIONS AND REPORTING

The AML Compliance Officer will report any suspicious transactions (including deposits and transfers) conducted or attempted by, at or through a Player account involving 2000 EUR or more of funds (either individually or in the aggregate) where the AML Compliance Officer knows, suspects or has reason to suspect: a. The Player is included on any list of individuals assumed associated with terrorism or on a sanctions list;

1. The transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade laws or regulations or to avoid any transaction reporting requirement under law or regulation;
2. The transaction has no ordinary lawful purpose or is not the sort in which the Player would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or
3. The transaction involves the use of the Company to facilitate criminal activity.

8. TRAINING PROGRAMS

8.1 The Company will develop ongoing employee training under the leadership of the AML Compliance Officer and senior management. The training will occur on at least an annual basis. It will be based on the Company’s size, its Player base, and its resources and be updated as necessary to reflect any new developments in the law.

8.2 The training will include, at a minimum:

1. How to identify red flags of money laundering that arise during the course of the employees’ duties;
2. What to do once the risk is identified (including how, when and to whom to escalate unusual Player activity or other red flags for analysis);
3. What employees’ roles are in the Company’s compliance efforts and how to perform them;
4. The Company’s record retention policy; and
5. The disciplinary consequences for non-compliance with legislation.