AML/KYC Policy

1. Definitions and Abbreviations  3

2. AML/CFT Policy  4

   1. Policy  4

   2. Objective  4

   3. Scope  4

3. Regulatory Framework  5

   1. National regulations  5

   2. International regulations  5

4. Procedures  6

   1. Know Your Client Procedure  6

   2. The Monitoring of Account Holder activities  7

   3. Risk Management  8

   4. Reporting of unusual transactions  8

   5. Recordkeeping  8

1. Definitions and Abbreviations

   
   

   Account Holder: an individual who applied and was granted an account held

   at the internet gateway operated by the Company for the use of the provided Services, as a Player.

   AML: Anti Money Laundering. All efforts focused on the prevention of transforming proceeds obtained from criminal activities into funds which appear to be obtained from legal activities.

   
   

   CFT: Combating the Finance of Terrorism. All efforts focused on the prevention of providing funds at the disposal of terrorists to be used for committing terrorist attacks.

   VOUCHERWAVE LIMITED, a limited liability company duly organized Under United Kingdom law and The Company registered in United Kingdom under number 14765800.

   
   

   FATF: On registration, a geographical location check is carried out on the applicant’s computer IP to ensure that person is in a permitted jurisdiction. If the applicant is not in a permitted jurisdiction, he/she will not be allowed to continue the registration process. Financial Action Task

   

   Force (www.fatf-gafi.org)

   FIU: Financial Intelligence Unit of Curaçao.

   KYC: Know Your Client

   
   

   MLRO: Money Laundering Reporting Officer

   
   

   Player: Individual who has registered with the Company for the purpose of making use of the Services offered on the Website and for which an account has been opened providing him/her with a unique code.

   Player Account: an account granted to an individual after registration.

   
   

   Service: the gaming and betting offers provided by the internet gateway operated by the Company to the Account Holder,  3

   through the Website.

   System: the games offered on the Website

   Website:  the online gaming platform offering online gaming

   services operated by the Company.

   
   

2. AML/CFT Policy

   
   

   1. Policy

      Money laundering and the financing of terrorism are some of the ever-growing threats for national and international economies throughout the world, forcing all vulnerable sectors to have measures in place for the prevention of their misuse for these purposes.

      VOUCHERWAVE LIMITED is committed to have procedures in place for the prevention of the misuse of its Services provided to Account Holders for money laundering, terrorism financing or other criminal purposes such as fraud.

      
      

   2. Objective

      The Company is a limited liability company, duly incorporated and registered in accordance with the laws of UNITED KINGDOM This policy is written based on the national legislation on AML, CFT and the penalization of predicate crimes of Curaçao and applicable international standards set by the FATF. Combined these regulations provide a solid, internationally accepted standard for the procedures maintained for the prevention of the misuse of the Services provided by the Company.

      Proper Identification of Account Holders, verification of the identity, monitoring of Player activities and reporting of unusual activities are part of the measures the company has in place in an effort to mitigate industry related risks.

      
      

   3. Scope

      The company is committed to the highest national and international AML and CFT standards when providing its Services and requires management and employees to follow these standards.

3. Regulatory Framework

   
   

   1. National regulations

      Pursuant to the National Ordinance of Money Laundering (1993), money laundering is a criminal offence in Curaçao. Further main national regulations relating to money laundering and terrorist financing are amongst others:

      
      

      1. The Code of Criminal Law (Penal Code) (N.G. 2011, no. 48);

      2. The National Ordinance on the Reporting of Unusual Transactions (N.G. 1996, no. 21) as lastly amended by N.G. 2009, no. 65 (N.G. 2010, no. 41) (NORUT) together will all amendments thereto and all related National Decrees containing general measures and Ministerial Decrees with general operations;

      3. The National Ordinance on Identification of Clients when Rendering Services (N.G. 1996, no. 23) as lastly amended by N.G. 2009, no. 66 (N.G. 2010, no. 40) (NOIS) together with all amendments thereto and all related National Decrees containing general measures and Ministerial Decrees with general operations;

      4. The National Decree containing general measures on the execution of articles 9, paragraph 2, and 9a, paragraph 2, of the National Ordinance on Identification of Clients when rendering Services. (National Decree containing general measures on Penalties and Administrative Fines for Service Providers) (N.G. 2010, no. 70);

      5. Sanctions national decree Al-Qaida c.s., the Taliban of Afghanistan c.s. Osama bin Laden c.s., and terrorist to be designated locally (N.G. 2010, no. 93);

      6. National Ordinance on the Obligation to report Cross-border Money Transportation

      N.G. 2002, no. 74) together with all amendments thereto and all related National Decrees containing general measures and Ministerial Decrees with general operations;

      
      

      These laws and decrees serve as the basis for the procedures maintained by the financial sector of Curaçao to detect and deter industry related risks for money laundering, the financing of terrorism or other criminal activities.

      
      

   2. International regulations

      

      As a member of the Financial Action Task Force (www.fatf-gafi.org) and of the Caribbean Financial Action Task Force (www.cfatf-gafic.org), Curaçao is meeting International standards by regularly implementing these standards in its national legislation.

      
      

      On international level, the FATF plays a very important role in the combating of money laundering and the financing of terrorism and proliferation of weapons of mass destruction.

      The FATF monitors the progress of its members in implementing necessary measures, reviews money laundering and terrorist financing techniques and counter-measures, and promotes the adoption and implementation of appropriate measures globally.

      
      

      In performing these activities, the FATF collaborates with other international bodies involved in combating money laundering and the financing of terrorism. In total 34 countries are direct members of the FATF and through regional organizations over 180 countries are connected to the FATF.

      
      

      Subsequently the present policy is a combination of the FATF and local AML/CFT rules and regulations. This ensures a solid, internationally accepted basis regarding AML/CFT. In case local laws and regulations require additional compliance duties, the Company is free to develop additional procedures to comply with local regulations.

      
      

4. Procedures

   
   

   In an effort to be compliant with the applicable rules, regulations and international standards, the Company has procedures in place to which it attains itself to when providing Services to Account Holders. These procedures cover the following standards:

   • Know Your Client

   • Monitoring of Player activities

   • Risk management

   • Reporting of unusual transactions

   • Recordkeeping

   
   

   Annual training is provided to all employees in relation to these standards.

   
   

   1. Know Your Client Procedure

      An individual cannot participate in a game for money unless that individual is an Account Holder. To be registered as a Player, an individual must register personally and submit an application for registration. The following information must be provided:

      1. date of birth together with valid identification showing that he/ she is over eighteen

         (18) years of age or the applicable legal age of majority as stipulated in the jurisdiction of your residence. Identification documents which must be submitted include: copy of a valid Passport, copy of other identification paper and a proof of address;

      2. Player’s first and last name;

      3. Player’s full residential address;

      4. Player’s valid email address; and

      5. a username and a password

      
      

      On registration, a geographical location check is carried out on the applicant’s computer IP to ensure that person is in a permitted jurisdiction. If the applicant is not in a permitted jurisdiction, he/she will not be allowed to continue the registration process. The Company reserves the right to request additional documentation and perform additional checks in order to verify the information provided. An account may be suspended until satisfactory information is provided.

      
      

   2. The Monitoring of Account Holder activities

      The company has its own transaction monitoring department in charge with the monitoring of all Player activities together with the related deposits and bets. The Company is constantly investing in the best software of the industry in order to mitigate industry related risks such as money laundering, terrorism financing and other criminal activities such as fraud.

      
      

      1. Prevention of multiple accounts

         The system maintained for the monitoring of the activities comprises of an IP address control uncovering any attempt to register multiple accounts. Whenever an Account Holder requests for a withdrawal of funds from his/ her account, the system will check the presence of multiple accounts and further checks whether the Account Holder has used a false proxy. At the presence of multiple accounts, all the accounts will be closed and the Account Holder will be denied the opening of a new account.

         
         

      2. Unusual activities

         If an Account Holder has unusual deposits and gets flagged by the system, the department manager will contact the Account Holder to get an explanation of the abnormal use. In case no (satisfactory) answer or information is provided, the manager will suspend the account until necessary papers/ explanation are in place. If the Account Holder has not provided satisfying information within 30 days, the account will be closed. The manager will proceed with the reporting of the unusual transaction to the relevant authority.

         
         

      3. Withdrawal or Pay out of funds

         The Company will not deposit withdrawn funds to another source from which it was originated unless sufficient information or documentation is provided substantiating the request. The pay out of prizes or winnings will only be deposited on the bank account of the Account Holder.

         Transfers or Pay outs to a third party account will not be effected unless sufficiently substantiated and to the discretion of the Company.

         The fact that the Company does not have offline betting shops simplifies the monitoring of all deposits and the control of all user activities.

         
         

      4. Collusion

         Upon the suspicion of the multiple registration by Account Holders acting in collusion or as a syndicate, the set up of fictitious accounts or the use of front men, the Company reserves the right to change or terminate any bonus offer, cancel any winnings and close accounts.

         
         

      5. Money Laundering Reporting Officer (MLRO)

         The Company has designated an MLRO who is in charge of the review of KYC information and the monitoring of Player Account activities and is further assisted by designated personnel. The MLRO is in charge of the following:

         • Ensure a proper review of the Player Accounts by the personnel in relation to identification and verification of an Account Holder,

         • Keep a list of registered Account Holders;

         • Monitor the reviews and investigations conducted by the designated personnel performed on the Player Account activities;

         • Provide initial and ongoing training to all relevant staff ensuring awareness of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious

           transactions;

           
           

         • Cooperate with all relevant administrative, enforcement and judicial authorities in their endeavor to prevent and detect criminal activity;

         • Ensure that this policy is adhered to, reviewed and maintained regularly.

           
           

   3. Risk Management

      The Company has designed a customer risk categorisation model which has been incorporated in its AML-CFT System. Based on this model, the customer (for all types of transactions) are categorized into either: ‘High Risk, ‘Medium Risk’, or ‘Low Risk’ categories.

      
      

   4. Reporting of unusual transactions

      Any unusual transactions or circumstances for which the transaction monitoring department has not received sufficient explanation may give rise to its report to the FIU. The department will hold a list of all instances in which it did not consider it necessary to report to the relevant authority. The decision not to report will need to be sufficiently supported.

      
      

   5. Recordkeeping

      The Company maintains a record of all relevant documentation on a separate database for at least five years after ending a business relationship. The company is obliged to retain files in

      a way that enables investigating authorities to identify a satisfactory audit trail for individual transactions including the amounts, currencies and type of transactions.

      
      

      In specific circumstances, if ordered by rule of law and permitted by national law and the relevant authorities, the Company may provide copies of the records maintained.

      
      

   6. Staff Due Diligence

It is imperative that the Company’s employees are of undisputed integrity. To ensure this objective, the Company follows a procedure whereby all applicants must produce a curriculum vitae, at least two references and relevant educational qualification certificates, and/or professional certificates, which are checked and verified by the Company’s human resources department.