AML Policy

1. BACKGROUND

1. The Company has an extensive track record in protecting gaming operations from criminal abuse and applying comprehensive anti-fraud and anti-money laundering frameworks, controls and continuous staff competence programs.
2. Future AML education initiatives will continue to incorporate principles of the Proceeds of Crime Act and recognised Money Laundering red-flags, especially within remote and card-not-present transactional settings common to interactive gaming.
3. The Company’s director maintains full understanding of statutory duties under the Proceeds of Crime Act and is equipped to distribute practical guidance on AML risks and regulatory compliance, based on experience with both remote and land-based gaming enterprises.

2. ANTI-MONEY LAUNDERING AND TRANSACTION FRAUD

1. Online gaming platforms are attractive for those attempting to disguise illicit funds due to rapid payment cycles and diverse processing channels, placing the industry at increased exposure to laundering attempts.
2. The Company therefore aligns operational and commercial decisions with preventive strategies to restrict opportunities for misuse, ensuring protective measures are embedded into standard workflows.
3. Every employee will receive structured AML training covering (not exclusively) the following indicators:
   1. irregular or abnormal wagering behaviour
   2. suspicious patterns of deposits or withdrawals in terms of size or frequency
   3. concerns related to card authenticity and reliability of card data
   4. identity verification complications or possible impersonation
   5. links between multiple customer accounts or unexplained account linkage
4. All suspected laundering activity must be escalated to the MLRO immediately. Staff must not alert the customer involved. The MLRO will evaluate the suspicion, submit Suspicious Activity Reports and maintain dedicated compliance records.
5. The Company enforces a comprehensive Know Your Customer (KYC) procedure to counter laundering and other fraudulent misconduct. Customers will be informed during onboarding and via the relevant website sections that automated verification tools are used and that documentary evidence may be requested when electronic checks are insufficient.
6. Additional protections include transfer velocity limits: withdrawals exceeding 3000 EUR in a single transaction require checks and director or senior management approval before processing. A maximum of three withdrawals per customer per day applies, and no more than 9000 EUR may be withdrawn in a 24 hour period without enhanced approval.
7. Withdrawals above 3000 EUR in 24 hours or 9000 EUR within a rolling 90 day period will trigger Enhanced Due Diligence. Standard online identity checks alone will not be considered adequate for these scenarios, and further documentary proof of identity and address will be obtained.
8. The Company does not handle physical cash at any point, eliminating risks linked to counterfeit currency and untraceable deposits.
9. Transactional activity is recorded and routinely reviewed against AML and social responsibility risk markers. Unusual playing trends or winning patterns will be cross checked with account communications and call records to ensure no collusion exists between personnel and customers.
10. A register of high risk and politically exposed persons (PEPs) will be maintained. These profiles will be reviewed more frequently and with heightened scrutiny.
11. When inappropriate or unlawful conduct by employees is identified, investigatory and disciplinary measures consistent with employment legislation and staff contracts will apply, including potential suspension where transactional fraud involvement is suspected.

3. SECURITY AND MONITORING

1. Effective monitoring practices will be implemented across systems, communications, payments and operational environments to safeguard integrity and customer security. The Company will utilise a range of measures and procedures to ensure an appropriate level of protection in all of these areas.
2. Call recording systems are utilised by the Company. This has multiple benefits, including:
   1. providing material for ongoing staff training and quality assurance
   2. confirming the accuracy of wager instructions, timing and transaction data
   3. protecting both customer interests and the Company’s brand reputation
   4. supporting robust and frequent monitoring procedures to deter collusion between staff and customers
3. Customers must provide all information reasonably required by the Company in order to meet jurisdictional obligations, manage money laundering and terrorist financing risks, and comply with any applicable economic or trade sanctions.
4. The Company may delay, block or refuse to process any transaction and may suspend or terminate an account without incurring liability if it is suspected that a transaction:
   1. may be in breach of AML or CFT laws or regulations in any jurisdiction, or
   2. involves any person who is sanctioned or appears to be connected, directly or indirectly, to any person or entity that is subject to economic or trade sanctions, or may directly or indirectly involve the proceeds of unlawful conduct.
5. Data security and safeguarding of system access are treated with the highest priority. All sensitive data will be encrypted wherever practicable, access to shared resources will be strictly controlled and password protected, and secure storage and backup procedures will ensure that information is not accessible to unauthorised parties and is reliably protected against loss.

4. RESPONSIBLE RELATIONSHIPS WITH CUSTOMERS AND BUSINESSES

1. The Company will publish Terms and Conditions together with KYC and AML policies on its website. These will make specific reference to fraudulent conduct, advance knowledge of results, match fixing concerns and other suspicious events. They will describe the actions the Company may take where cheating is suspected or identified and the degree of cooperation that will be afforded to regulators and sporting authorities. This will support transparent communication with customers in such cases.
2. The director recognises that where serious criminal behaviour is suspected or identified, neither the individuals concerned nor the wider staff group should be alerted to ongoing suspicions or investigative steps. In some circumstances alternative approaches may be required, and appropriate escalation processes and staff training will be maintained.
3. The Company will adopt all necessary measures to ensure the integrity of its relationships with other businesses. This will involve a standardised due diligence approach, which may include Non Disclosure Agreements and the collection of information on ownership and management structures, company incorporation details, addresses and contact data. Records of such checks will be templated and securely retained.