AML Policy

All capitalized terms used herein and not otherwise defined shall have the meanings assigned to them in the Terms & Conditions.

1. Experience

1.1. The Company’s senior management possesses extensive experience in protecting gaming businesses from criminal abuse and in establishing comprehensive anti-fraud and anti-money laundering frameworks, including procedures and thorough staff training initiatives.

1.2. Future training programs will be supported by in-depth knowledge of the Proceeds of Crime Act and money laundering indicators commonly identified within gaming environments, particularly in Card Not Present transaction settings.

1.3. The director has full awareness of all provisions of the Proceeds of Crime Act and his associated responsibilities, and is well qualified to transfer knowledge regarding Anti-Money Laundering measures and obligations, having successfully safeguarded major remote and non-remote gaming operations in this area.

2. Anti-money laundering and transaction fraud

2.1. Gaming environments are frequently targeted by individuals seeking to launder money. The rapid nature of transactions and the availability of multiple payment processing methods make gaming businesses especially exposed to such risks.

2.2. Consequently, many of the director’s initial operational and procedural decisions are either specifically intended to address this threat or result in enhanced protections as a secondary effect of the overall commercial and trading strategy adopted by the business.

2.3. All staff will receive training on Money Laundering indicators including (but not limited to):

2.3.1. irregular betting behaviors

2.3.2. suspicious deposit and withdrawal activity (including amount and frequency)

2.3.3. accuracy and consistency of provided data

2.3.4. customer verification concerns and identity theft risks

2.3.5. linked accounts or multiple account usage

2.4. Any suspected Money Laundering activity must be reported to the MLRO, and such suspicion must not be disclosed to the customer. No further action may be taken without appropriate consent. The MLRO is responsible for liaising with the relevant authorities, submitting Suspicious Activity Reports, and requesting consent through the goAML system of the Financial Intelligence Unit (FIU) where and when required. He will also ensure that all necessary registers related to reporting are properly maintained.

2.5. The Company will implement a comprehensive ‘Know Your Customer’ policy. This policy will support the mitigation of Money Laundering risks as well as other forms of fraud. Customers will be informed during registration and through the supporting non-transactional website that the Company uses online verification tools and that, where verification criteria cannot be met, identification and address verification documents will be required.

2.6. Additional key procedures designed to strengthen these protections include establishing time-based thresholds and withdrawal velocity limits, mandatory checks and director approval prior to processing card withdrawals and bank transfers exceeding 3000 EUR in a single transaction, a maximum of 3 (three) withdrawals per day, and an overall daily withdrawal limit of 9000 EUR.

2.7. Industry-recognized standards that will automatically trigger Enhanced Due Diligence (requiring additional proof of identity and address) include withdrawals exceeding 3000 EUR within a single 24-hour period and 9000 EUR within a 90-day period. In such cases, basic online verification will not be considered sufficient.

2.8. The business will not operate with any cash component, thereby reducing risks related to counterfeit currency.

2.9. Systems will be in place to record all transactions associated with an account. These account histories will undergo ongoing and regular reviews against fraud and social responsibility indicators. Where abnormal betting or winning patterns are identified, these will be cross-checked against call histories to ensure that no collusion or illicit conduct by staff is taking place.

2.10. The Company will also maintain a register of customers identified as high-risk or politically exposed. Such accounts will be subject to increased monitoring and more frequent reviews.

2.11. In cases where illegal or inappropriate conduct by staff is identified, investigative and disciplinary actions will be carried out in accordance with staff contracts, applicable employment law requirements, and the increased use of measures such as suspension where, for example, transactional fraud is suspected and such activities fall within an employee’s normal job responsibilities.

3. Security and monitoring

3.1. The implementation of effective monitoring procedures is critical for any gaming business and must cover premises, equipment, personnel, communications, and transactions. The Company will apply a variety of measures and procedures to ensure security and protection across all of these areas.

3.2. The Company has implemented call recording technology, which provides several key advantages, including:

3.2.1. employee training purposes;

3.2.2. verification of the accuracy of bet placement (including timing and execution) and transaction records;

3.2.3. protection of customers and preservation of brand reputation;

3.2.4. the establishment of strong and frequent monitoring processes designed to prevent and discourage collusion between staff members and customers.

3.3. The protection of data and the overall security of software and hardware are critical considerations for any business conducting transactions and storing data in a Non-Face to Face environment. Accordingly, the Company will apply a general policy of ‘Encrypt whatever can be Encrypted’. Access to Shared Drives will be tightly restricted, monitored, and password protected where appropriate. Data storage and back-up solutions and procedures are in place to ensure that Customer Data remains inaccessible to unauthorized third parties and to effectively prevent data loss.

4. Responsible relationships with customers and businesses

4.1. The Company will publish its Terms and Conditions together with its KYC & AML policies on its website. These documents will specifically address fraudulent conduct, possession of prior knowledge of an event outcome or its likely result, and issues related to match-fixing and suspicious events. They will outline the actions that may be taken where cheating is suspected or confirmed and will describe the extent of cooperation with regulators and sports governing bodies in addressing such matters. This approach will generally ensure transparent communication with customers in such situations.

4.2. Nevertheless, the director recognizes that where serious criminal activity is suspected or identified, it is essential that the individuals concerned are not ‘tipped off’ regarding such suspicions or any subsequent investigations. In certain cases, alternative methods of engagement may therefore be required. Appropriate staff training and clear escalation procedures will be implemented to support this approach.

4.3. The Company will take all necessary steps to ensure the integrity of its relationships with other businesses. This will involve a standardized due diligence process, often supported by Non-Disclosure Agreements where appropriate. Such procedures will require disclosure of ownership and management structures, incorporation information, registered addresses, and contact details. The outcomes of these checks will be documented using standardized templates and maintained in company records.