Anti-Money Laundering (AML) Program

1. Company Policy

1.1. It is the policy of Afina Interactive N.V. (the “Company”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company strives to comply with all applicable requirements under the legislation in force in the jurisdictions in which the Company operates, to prevent the use of the financial system for the purpose of money laundering and terrorist financing.

1.2. The Company is licensed and regulated by Curacao eGaming to offer remote games over the internet, under the National Decree August 18, 1998 No. 14. Under the license conditions issued by Curaçao, the Company is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.

2. The objective of the Policy

2.1. The Company is fully committed to being constantly vigilant to prevent money laundering and combat the financing of terrorism. It is also committed to its duty not to allow its systems to be abused in furtherance of these crimes.

2.2. The Company will endeavour to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. 2.3 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. Player Identification Program

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

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

3.3. 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 will include at least:

• Player’s date of birth (showing that the player is over eighteen (18) years of age);
• Player’s first and last name;
• Player’s valid phone number;
• Player’s valid email address;
• Player’s username and a password.

3.4. 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. These documents shall include, to the extent permitted under the relevant data protection regulations:

• A copy of a valid identity card or passport;
• Proof of address;

3.5. The Company may supplement the use of documentary evidence by using other means, which may include:

• Independently verifying the Player’s identity through the comparison of information provided by the Player with information obtained from a reporting agency, public database or other sources;
• Checking references with financial institutions; or
• Obtaining a financial statement.

3.6. The Company will inform relevant Players that the Company may seek identification information to verify their identity.

3.7. If a potential or existing Player either refuses to provide the information described above 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.

3.8. If a Player has been identified as attempting or participating in any criminal or unlawful activity, the Company will take the appropriate steps to immediately freeze the account of the Player.

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

4. Continuous transaction due to diligence

4.1. 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.

4.2. Transactions will be automatically monitored for signs of suspicious activity. Documents may be required at the determination of the further investigation.

4.3. The Company will be responsible for this monitoring, will review any activity that the monitoring system detects, will determine whether any additional steps are required, and will report suspicious activities to the relevant authorities.

4.4. Parameters that signal possible money laundering or terrorist financing include, but are not limited to:

• Transaction to/from financial secrecy havens or high-risk geographic locations without an apparent reason.
• Transaction activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent specific purpose.

4.5. The Company will not accept cash or non-electronic payments from Players. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method approved by the Company or respective regulators.

4.6. The Company will only transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.

4.7. To the extent the Company utilizes a third party to process and record payments to and from Player and accounts, the Company will use best efforts to 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.

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

5. Suspicious Transactions and Reporting

The Company will report any suspicious transactions conducted or attempted by, at or through a Player account involving USD 1,000 or more of funds (either individually or in the aggregate) where the Company knows, suspects or has reason to suspect:

5.1. The Player is included on any list of individuals assumed associated with terrorism or on a sanctions list;

5.2. 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;

5.3. 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, the possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction;

5.4. The transaction involves the use of the Company to facilitate criminal activity.