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AML Policy

1. COMPANY POLICY

It is the policy of Netgame Entertainment 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 legislations in force in the jurisdictions of the European Union members in which the Company operates, pursuant to the Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing and the forthcoming Fourth Directive on Money laundering.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations.

Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

 

2. OBJECTIVE OF THE POLICY

2.1 The Company is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

2.2 The Company will endeavor to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organization and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.

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 (hereinafter “Players”). For this purpose the process for the registration of Players provided for under the General Terms and Conditions of the Company provides for the due diligence process that must be carried out before the opening of a user account.

3.2 The Company will keep at all times a secure online 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 required will include at least:

a. Player’s date of birth (showing that the player is over eighteen (18) years of age);

b. Player's first and last name;

c. Player's place of residence;

d. Player's valid email address;

e. Player's valid phone number.

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 and prior to any payment in excess of  300 EUR per occasion or when payments to the account are made in excess of 300 EUR. These documents shall include, to the extent permitted under the relevant data protection regulations:

a. A copy of a valid identity card or passport;

b. Proof of address;

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

a. 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 source;

b. Checking references with financial institutions; or

c. Obtaining a financial statement.

3.6 The Company will inform relevant Players that the Company may seek identification information to verify their identity, and will compare Player identification information with government or international -provided lists of suspected terrorists or sanction lists for example through the European Union or FATF on a monthly basis.

3.7 If a Player appears on a list of (suspected terrorists or otherwise sanctioned individuals the Company will take the appropriate steps to immediately freeze and or lose the account of the Player.

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

 

4. CONTINUOUS TRANSACTION DUE 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 Parameters that signal possible money laundering or terrorist financing include, but are not limited to:

a. Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent reason.

b. Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately withdrawn or wired out.

c. Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent specific purpose.

4.3 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 respective regulators.

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

4.5 Transfers of funds between Players accounts shall prohibited.

4.6 To the extent the Company utilizes a third party to process and record payments to and from Player and accounts, the Company will 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.

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