AML POLICY

Last updated: 23/10/2024

I. Introduction

This AML Policy is meant to provide the information that UniqueGame N. V., a limited liability company registered in Curaçao with company registration number 144499, with registered address at Dr. H. Fergusonweg 1, Curaçao (“Company”), strictly complies with all applicable laws and regulations of anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) policies. Thereby the Company carries out a group of actions aimed at revealing criminally obtained funds and their legalization countermeasures in correspondence with the international requirements. The present AML Policy is renewed every three months.

II. Legal Basis

The infrastructure for anti-money laundering and combating the financing of terrorism (AML/CFT) in Anjouan finds its legal basis in the Gaming Control Anjouan’s AML and KYC code.

III. Tools for Identification

The Company may use one of the following searching tools in order to identify the client/partners and fulfill the PEP, Blacklists and Sanctions controls: SEON, Onfido, Trulioo, Refinitiv, Token of Trust, ComplyAdvantage etc.

1. IDENTIFICATION AND VERIFICATION OF CLIENTS

1.1. According to AML and Know Your Client (“KYC”) policies, the Company identifies the Client / Counterparty and verifies their true identity on the basis of documents and data both at the moment of starting a business relationship with the Client / Counterparty and on ongoing basis.

1.2. The Client (or the Counterparty) provides by email the identification information to the Company including its full name, date of birth, country of residence, mobile number and email (for individuals) and corporate details with precise information on the beneficiaries (for the legal entities).

1.3. After receiving the identification information, the Company should verify the information requesting the appropriate documents.

1.3.1. The appropriate document verifying the Client’s / Counterparty’s identity is a high-resolution scanned copy or a photo of a passport or a driving license or any other national ID (for the individuals) and corporate set not older than three months with full set of identification documents for the beneficiaries (for the legal entities).

1.3.2. The appropriate document verifying proof of address is a high-resolution copy or a photo of a utility bill or a bank reference issued within the last 3 months.

1.4. At the Company’s request the Client is required to provide a scanned copy or a photo of front and back side of the credit/debit card. The front side should show the cardholder’s full name, the expiry date and the first six and the last four digits of the card number. The back side should show the cardholder’s signature, CVC2/CVV2 code must be covered.

1.5. The Company shall monitor the Client’s / Counterparty’s due diligence and accounts on the regular basis in order to determine the level of risk they pose and to reveal whatever changes in information about the Client / Counterparty.

1.6. If the Company believes the business relationship with the Client / Counterparty to pose a potentially high risk of money laundering or terrorism financing, the Company is entitled to ask for whatever additional data and documents that may be deemed necessary in the situation.

1.7. The Client / Counterparty is obliged to inform immediately of any changes in the personal or contact information.

2. KYC PROCEDURE

In order to open an account to use the Website services, you should provide your e-mail address, choose a password and fill in the information required to complete the registration by providing us the personal information, including your name, date of birth and phone number.

We follow the rules of KYC procedures (“Know Your Customer”). Your name on Your Account shall match your true and legal name and identity. To verify your identity, the Company reserves the right to request at any time satisfactory proof of identity (including but not limited to copies of a valid passport / identity card and/or any payment cards used). If you fail to supply the information and documents requested, we shall be entitled to suspend the activity of your account until the provision of the information requested and/or close your account. The Company reserves the right to review the documents within 30 (thirty) calendar days.

You hereby certify and agree that you have provided accurate, complete and true information about yourself upon registration and you shall maintain the accuracy of that information by promptly updating it if there are any changes. Failure to do so may result in account closure, account limitations or voiding transactions (bonus, winnings).

You shall only open a single account at the Website. In all cases, only one account per customer, per address, per shared computer and per shared IP address shall be allowed. Any other account you open on the Website shall be considered as the duplicate account. You shall inform the Company that you wish to create a duplicate account due to the original account access loss or any other important reason and receive a permission from the Company before the creation of the duplicate account. In any other cases all duplicate accounts may be immediately closed by the Company and:

• all transactions made from the duplicate account shall be considered null and void;
• any returns, winnings or bonuses which you have gained or accrued within the use of the duplicate account shall be forfeited from you and a return may be claimed by us. Any funds withdrawn from the duplicate account shall be returned to us on demand;
• the Company shall not compensate any funds from both bonus and real money balances of the duplicate account. The Company reserves the right, at its sole discretion, to claim the return of any lost funds that were used for bets effected via the duplicate account;
• the Company shall not accept any requests on fund returns which have been lost or initially deposited on the duplicate account provided that the duplicate account was created with intention to receive bonuses and other promo offers from the Company, as well as if a number of duplicate accounts was created with a purpose of receiving a return of the first deposits made on previously created duplicate accounts, which is considered to be an abuse. If the Company at its sole discretion assumes that the duplicate accounts were created only with a purpose of fraud and/or abuse of hereunder, then the funds deposited on this duplicate account shall not be returned to the player.

The Company confirms that anonymous bank accounts are prohibited by AML/CFT rules and the Company observes such prohibition and does not accept the anonymous accounts.

3. PAYMENT POLICY

3.1. In order to minimize the risk of money laundering and terrorism financing the Company neither accepts nor pays off cash money under no circumstances.

3.2. The Company reserves the right to refuse processing a transaction at its any stage, if the Company believes the transaction to be connected in any way with money laundering or criminal activity.

3.3. According to international legislation, the Company is prohibited from informing the Client that they have been reported for suspicious account activity.

3.4. The name of a person making a deposit of funds should be the same as the Client’s name in the Company’s records. Payments from third parties are not accepted.

3.5. The Company requires strict adherence to established deposit/withdrawal procedure. Funds can be withdrawn to the same account and using the same method as when depositing. When withdrawing, a name of a payee should be the same as the Client’s name in the Company’s records. If the deposit has been made via wire transfer, the funds should be withdrawn via the same transfer to the same bank and to the same bank account as when depositing. If the deposit has been made by means of a payment system, the funds can be withdrawn via online transfer to the same payment system and to the same account as when depositing.

3.6. The compliance with the AML policy requires withdrawal of funds to be made in the same currency as when depositing.

3.7. The Company maintains transaction records for a minimum of 5 years after termination of the business relationship with the Client.

4. PERSONNEL TRAINING

4.1. The Company appoints an AML Compliance Officer who is fully responsible for the Company’s compliance with CFT and AML policies, establishing and maintaining the Company’s AML program, AML training employees, receiving, investigating and maintaining internal suspicious activity reports.

4.2. All the employees, managers and directors of the Company are suitably trained while entering into employment.

4.3. Employees who are dealing with clients or are involved in any AML checking, verification or monitoring undergo AML training. Each new employee has to follow an AML training plan. The AML training program includes suspicious transactions identification training as well as training in prevention, detection and reporting of money laundering and terrorism financing crimes.

4.4. Any violation of the AML policy must be reported to the AML compliance officer, unless the violation implicates the AML Compliance Officer, in which case an employee must report the violation to the CEO.

5. HIGH-RISK JURISDICTIONS

The Company considers the following countries to be the high-risk countries: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Democratic People's Republic of Korea (DPRK), Haiti, Iran, Jamaica, Jordan, Mali, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, Uganda, United Arab Emirates, Yemen. The Company performs additional checks, controls on cooperation with these countries. On 7 January 2022, the European Commission adopted a new Delegated Regulation in relation to third countries which have strategic deficiencies in their AML/CFT regimes.

6. RISK ASSESSMENT

A money laundering and terrorist financing risk assessment attempts to identify, analyse and understand money laundering and terrorist financing risks. It serves as the first step in addressing the risks and, ideally, involves making judgments about threats, vulnerabilities and consequences. The Company shall identify the threats (persons, or groups of people, objects or activities with the potential to cause harm, including criminals, terrorist groups and their facilitators, their funds, as well as past, present and future money laundering or terrorist financing activities), vulnerabilities (things that can be exploited by the threat or that may support or facilitate its activities and means focusing on the factors that represent weaknesses in AML or CTF systems or controls or certain features of a country, particular sector, financial product or type of service that make them attractive for money laundering and terrorist financing), consequences (this refers to the impact or harm that money laundering or terrorist financing may cause, including the effect of the underlying criminal and terrorist activity on financial systems and institutions, the economy and society more generally).

The Company adopts an approach that attempts to distinguish the extent of different risks to assist with prioritizing mitigation efforts, rather than being a generic box-ticking exercise. That is why the Company performs the identification (the identification process begins by developing an initial list of potential risks or risk factors when combating money laundering and terrorist financing. Risk factors are the specific threats or vulnerabilities that are the causes, sources or drivers of money laundering and terrorist financing risks), analysis (analysis involves consideration of the nature, sources, likelihood, impact and consequences of the identified risks or risk factors. The aim of this stage is to gain a comprehensive understanding of each of the risks, as a combination of threat, vulnerability and consequence, in order to assign a relative value or importance to each of them. Risk analysis can be undertaken with varying degrees of detail, depending on the type of risk, the purpose of the risk assessment, and the information, data and resources available), evaluation (the evaluation stage involves assessing the risks analysed during the previous stage to determine priorities for addressing them, taking into account the purpose established at the beginning of the assessment process. These priorities can then contribute to development of a strategy for the mitigation of the risks).

7. ONGOING CUSTOMER DUE DILIGENCE AND TRANSACTION MONITORING

The Company applies enhanced customer due diligence measures and enhanced ongoing monitoring, in addition to the required CDD measures, to manage and mitigate the money laundering or terrorist financing risks arising in the following cases:

• in any case identified by the Company or in information provided to the Company as one where there is a high risk of money laundering or terrorist financing;
• in any business relationship with a customer situated in a high-risk third country;
• if the Company has determined that a customer or potential customer is a PEP, or a family member or known close associate of a PEP;
• in any case where the Company discovers that a customer has provided false or stolen identification documentation or information and the operator proposes to continue to deal with the customer;
• in any case where a transaction is complex or unusually large, or there is an unusual pattern of transactions, or the transaction or transactions have no apparent economic or legal purpose;
• in any other case which, by its nature, can present a higher risk of money laundering or terrorist financing;

In the case of business relationships with customers situated in high-risk third countries or transactions where either of the parties to the transaction are resident in a high-risk third country, the enhanced measures undertaken shall include: obtaining additional information on the customer and on the customer’s beneficial owner, obtaining additional information on the intended nature of the business relationship, obtaining information on the source of funds and source of wealth of the customer and of the customer’s beneficial owner, obtaining information on the reasons for the transactions, obtaining approval of senior management for establishing or continuing the business relationship, conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.

In the case of transactions that are complex or unusually large, or where there is an unusual pattern of transactions, or the transaction or transactions have no apparent economic or legal purpose, the enhanced measures undertaken shall include: as far as reasonably possible, examining the background and purpose of the transaction, increasing the degree and nature of monitoring of the business relationship in which the transaction is made, to determine whether the transaction or relationship appear to be suspicious.

Depending on the requirements of the case, the enhanced measures undertaken in any case listed in enhanced customer due diligence and enhanced ongoing monitoring may also include, among other things: seeking additional independent, reliable sources to verify information provided or made available to the casino operator, taking additional measures to understand better the background, ownership and financial situation of the customer, and other parties to the transaction, taking further steps to be satisfied that the transaction is consistent with the purpose and intended nature of the business relationship, increasing the monitoring of the business relationship, including greater scrutiny of the transactions.

8. CUSTOMER RISK CLASSIFICATION. RISK SCORING SYSTEM

There are four risk levels, and these are:

• Low: Customers whose identity is easily identified.
• Medium: Customers who pose a higher risk than an average customer.
• High: Customers whose financial activities are monitored with Customer Due Diligence.
• Prohibited: Customers who are banned from financial activities due to their involvement in financial crimes.

Risk scoring is part of the KYC pillar of an AML framework of the Company. Risk scoring is a step in the due diligence process that entails looking at a customer's background and behavior to determine their score.

The risk score is calculated using the following factors:

• Customer vetting: it helps the Company to ensure that each customer's commercial transaction is legal within their jurisdiction.
• Demographic check: checking variables such as nationality, occupation, date of birth, length of stay with the Company, residence and mailing addresses, credit score, etc.
• Transactions: the Company examines its customers' sources of income and determine whether they make sense in terms of their occupation or location. This involves determining whether transactions are appropriate in light of the customer's risk profile.
• Operational trends: the Company reviews any fraud notices, suspicious activity reports (SARs), suspicious transaction reports (STRs), or other red flags relating to a customer's behavior.

9. EDD PROCEDURE

The Company follows the following EDD rules’ recommendations:

• The Company scrutinizes customers’ risk profile;
• The Company obtains additional information where necessary;
• The Company conducts extensive background checks and monitors transactions;
• The Company organizes and secures its data in line with compliance standards;
• The Company keeps the data available for regulators.

The Company obtains additional identifying information from a wider variety or more robust sources and using the information to inform the individual customer risk assessment:

• Carrying out additional searches (for example, verifiable adverse media searches) to inform the individual customer risk assessment;
• Commissioning an intelligence report on the customer or beneficial owner to understand better the risk that the customer or beneficial owner may be involved in criminal activity;
• Verifying the source of funds or wealth involved in the business relationship to be satisfied that they do not constitute the proceeds from crime;
• Seeking additional information from the customer about the purpose and intended nature of the business relationship.

10. SANCTIONS SCREENING

The Company has implemented due diligence and sanctions screening procedures. The Company shall screen and identify persons and transactions subject to and/or prohibited by the following: US OFAC SDN List; UK HMT Consolidated List of Persons and Ukraine List of Persons; UN restrictive measures; and the EU Consolidated List. The Company utilizes Thomas Reuters World-Check (World-Check) and Refinitiv to conduct sanctions screening, which allows the Company to screen all relevant sanctions lists using a single search function. The following internal documents should be cross-referenced to effectively carry out sanctions screening: 1) Screening Request Form; 2) Partnership Appraisal Form; 3) Screening Procedures Matrix; 4) Due Diligence and Partnership Appraisal Map; and 5) Thomson Reuters World-Check User Guide.

11. MONITORING RED FLAGS ON THE SUSPICIOUS ACTIVITY

When risk assessing a client, there are some red flag behaviours that would cause further research by the Company within the AML procedure. The Company fully relies on the ML/TF indicators developed by the Financial Action Task Force (FATF). These ML/TF indicators do not cover every possible situation but were developed to provide with a general understanding of what is or could be unusual or suspicious. On its own, a single ML/TF indicator may not appear suspicious. However, observing an ML/TF indicator could lead a Company to conduct an assessment of the transaction(s) to determine whether there are further facts, contextual elements or additional ML/TF indicators that assist in establishing reasonable grounds to suspect the commission or attempted commission of an ML/TF offence, which requires the submission of an STR.

12. INTERNAL SUSPICIOUS ACTIVITY REPORT

A suspicious activity report (SAR) is an essential tool in the fight against financial crimes such as money laundering. The Financial Action Task Force (FATF), a global AML watchdog, recommends that all financial institutions implement a suspicious activity detection and reporting system. The Company implemented the internal system of sending the SAR.

The compliance officer of the Company shall begin the SAR reporting requirement. If the compliance officer or any officer of the financial department notices a suspicious transaction, such as a large, anonymous off-shore money transfer into a usually “quiet” account, he/they would report that activity to the Director. Then the Director of the Company would decide if a suspicious activity report was necessary.

The process for filing a SAR is completely digital.

The SAR should contain the names, addresses, social security numbers, birth dates, driver’s license numbers and other contact and personal information about the potential perpetrators. The SAR forms ask for in-depth information on the incident or incidents as well as a written description of the financial activity. There should be identified the type of suspicious activity and provided any other supporting documentation.

13. ANTI-BRIBERY AND CORRUPTION

The Company confirms that offering, promising and authorising the giving of money, or anything else of value, to a government official in order to secure an improper advantage is strictly prohibited. No employee may offer, give, promise or receive money, or anything else of value, to or from an individual or entity in the private sector in order to obtain an improper advantage. Even the mere act of offering is prohibited, regardless of whether or not the item of value is actually accepted by the intended recipient. The prohibition covers cash payments, benefits and favours. In certain circumstances, it also covers otherwise legitimate business expenditures such as gifts, entertainment, travel, donations, sponsorships or training.

The above-mentioned payments are prohibited regardless of whether or not they are made directly or indirectly through third party intermediaries. Reasonable steps must be taken to verify that any contribution does not constitute an illegal payment to a government body or official or any individual in violation of this policy.

The Company must never enter into any relationship with a third-party intermediary who will have substantive interaction with government officials on behalf of the Company without first inquiring into the third party’s background, qualifications and reputation.

The most important steps the Company can take to protect itself from liability for improper payments made by a third party are to carefully choose its business partners, including agents and consultants, and to be aware of “red flags”, to fulfill all the necessary KYC checks and procedures as per the present AML Policy.

The Company does not allow the use of facilitating payments. Such payments may be considered a customary way of doing business in some countries, but it is important to understand that the anti-bribery laws of many countries prohibit such payments.

14. INTRODUCING CHANGES TO THE AML POLICY

The Company reserves the right to review and/or amend the AML Policy, at its sole discretion. All the Clients / Counterparties are automatically introduced to the new policies, if any changes are made. The AML Policy is reviewed every three months. The present AML Policy is drafted and approved by the AML specialist and finally approved and signed by the Director of the Company.