AML Policy

1. Company Business Model

SoftSwiss N.V. ("%Domain%" or the "Company") is a company incorporated under Curaçao Law that was established in 2018 and operates the online casino www.%domain%. %Domain% is licensed by the Curaçao Gaming Authority under license number OGL/2024/475/1939. %Domain% presently supports users in more than 169 countries globally. As part of its global operations, %Domain% has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

2. Company Policy Statement

%Domain% is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism ("AML/CFT") applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, %Domain% expressly prohibits and rejects the use of %Domain% products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering ("AML") laws, regulations and norms. %Domain%'s intention is to follow global best practices in guarding against %Domain% products being used to facilitate such activities. Those best practices include: Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations; Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls; Provision of related education and training to relevant personnel; and Independent reviews, monitoring and maintenance of the policy, procedures and controls.

3. Definitions

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration. Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues. Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler's checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets. Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use. Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes. Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions.

4. Governance and Oversight

%Domain% has appointed a Chief Compliance Officer ("CCO") that is responsible for coordinating the implementation of the AML Policy and policy program. The Chief Compliance Officer's duties also include developing AML initiatives, work with other stakeholders to revising the AML policy, assessing new regulatory requirements and investigate potentially suspicious or unusual activity. %Domain% also provides AML training to all of its employees on a regular basis.

5. Know Your Customer and Transaction Monitoring

%Domain% will apply appropriate user due diligence and ongoing monitoring measures required by law. %Domain% will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity. %Domain% uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.

5.1. Know Your Customer

A. Customer Due Diligence. %Domain% has adopted a risk based CDD to enable %Domain% to understand the nature and purpose of the user relationship to the %Domain% platform in order to develop a customer risk profile. In order to do so, %Domain% collects certain documentary and non-documentary information at account-opening commensurate with the nature of the type account and services that %Domain% offers. The CIP consists of procedures for: Collecting baseline (e.g., wallet address, email address) information at account creation; Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user's account; Maintaining records of the information used to identify the user; and Determining if a user appears on any list of known or suspected terrorists or terrorist organisations. B. Enhanced Due Diligence and Ongoing Monitoring %Domain% performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. Whenever one of those red flags is triggered, the user account will be suspended and %Domain% will pursue enhanced due diligence. C. Acceptance Policy %Domain% will not accept and will block the users that: Do not provide the identification information requested; Provide fake identification documents; Try to use different means to deceive about their location; Are from restricted or prohibited jurisdictions; Are subjected to United States, European Union, or other global sanctions or watch lists; Are gambling addicted or have mental health issues; Its source of funds are originated or exchanges in restricted jurisdictions.

5.2. Transactions Monitoring

%Domain% is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose %Domain% established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring. %Domain% will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review user history and patterns of activity to detect and report any unusual activity as required. %Domain% implemented procedures addressing: identification of unusual activity through methods of identification may include employee and customer identification, law enforcement inquiries, other referrals, or transaction and surveillance monitoring system reports; and alert management that focuses on processes used to investigate, evaluate and document identified unusual or potentially suspicious activity.

6. Education and Training

%Domain%, with the assistance of its legal counsel and under the oversight of its CCO, may provide employees AML, anti-terrorist financing and trade sanctions compliance training on a periodic basis, as deemed appropriate.

7. Reporting

%Domain% is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity to the regulator.