Anti-Money Laundering Policy

2.Regulatory Framework

PolyWager's AML program is designed to comply with a comprehensive framework of international, regional, and industry-specific regulations. Our compliance program is built upon the following regulatory foundations:

International Standards

• Financial Action Task Force (FATF) Recommendations -- We adhere to the FATF 40 Recommendations, including the updated guidance on virtual assets and virtual asset service providers (VASPs). This includes implementation of the Travel Rule for cryptocurrency transactions exceeding applicable thresholds.
• Wolfsberg Group Principles -- Our compliance framework incorporates the Wolfsberg Group Anti-Money Laundering Principles for correspondent banking and private banking, adapted for the digital asset context.
• United Nations Conventions -- Compliance with the UN Convention against Transnational Organized Crime and the UN International Convention for the Suppression of the Financing of Terrorism.

European Union Regulations

• Sixth Anti-Money Laundering Directive (6AMLD) -- Full compliance with the EU's 6AMLD, including expanded predicate offenses, extended criminal liability, and enhanced penalties for non-compliance. We recognize aiding, abetting, and attempting money laundering as criminal offenses.
• EU Anti-Money Laundering Regulation (AMLR) -- Alignment with the EU's directly applicable AML regulation, including enhanced due diligence requirements and beneficial ownership transparency measures.
• Markets in Crypto-Assets Regulation (MiCA) -- Adherence to MiCA requirements for crypto-asset service providers, including capital requirements, governance standards, and consumer protection obligations.

Gaming Regulations

• Curacao eGaming Authority -- PolyWager operates under the regulatory oversight of the Curacao eGaming Authority. We comply with all AML/CTF requirements set forth by the Curacao licensing framework, including customer identification, transaction monitoring, and suspicious activity reporting obligations.
• International Gaming Standards -- Implementation of responsible gaming AML controls, including monitoring for unusual gambling patterns that may indicate money laundering through gaming services.

3.Know Your Customer (KYC) Procedures

PolyWager implements a tiered Know Your Customer (KYC) framework that applies proportionate verification requirements based on the customer's activity level and risk profile. All customers must complete at least Tier 1 verification before using the Platform. Higher transaction volumes and risk indicators trigger enhanced verification requirements.

Document Requirements

All identification documents submitted to PolyWager must meet the following standards:

• Documents must be original (no photocopies) and submitted in color
• Government-issued IDs must be valid (not expired) at the time of submission
• All four corners of the document must be visible in the uploaded image
• Documents must be in Latin script or accompanied by a certified translation
• Proof of address documents must be dated within the last three (3) months
• Selfie images must clearly show the applicant's face alongside the submitted ID document
• Documents must not be digitally altered, edited, or manipulated in any way

Verification Process & Timelines

PolyWager utilizes a combination of automated identity verification technology and manual review by trained compliance personnel. Our verification process operates as follows:

• Automated Verification: Document authenticity checks, facial recognition matching, and database validation are performed automatically upon submission. Most Tier 2 verifications are completed within minutes through our automated systems.
• Manual Review: Cases flagged by the automated system, Tier 3 applications, and high-risk customers undergo manual review by our compliance team. Manual reviews are typically completed within 1-3 business days.
• Escalation: Complex cases or those requiring additional documentation are escalated to the Chief Compliance Officer. Customers are notified promptly if additional information is required.
• Rejection & Appeal: If verification is declined, customers are informed of the reason (where legally permissible) and may resubmit with corrected documentation. Repeated failed verifications may trigger enhanced scrutiny.

4.Customer Due Diligence (CDD)

Customer Due Diligence is a cornerstone of our AML program. PolyWager applies a risk-based approach to CDD, implementing standard, simplified, and enhanced measures depending on the assessed risk level of each customer relationship.

Standard Due Diligence

Standard CDD measures are applied to all customers during onboarding and include:

• Identification and verification of the customer's identity using reliable, independent source documents or data
• Identification of beneficial owners (where applicable) and taking reasonable measures to verify their identity
• Understanding the purpose and intended nature of the business relationship
• Assessment of the customer's risk profile based on available information
• Screening against sanctions lists, PEP databases, and adverse media sources

Simplified Due Diligence (SDD)

In cases where the risk of money laundering or terrorist financing is assessed as low, PolyWager may apply simplified due diligence measures. SDD may include reduced frequency of customer identification updates and reduced ongoing monitoring intensity. SDD is never applied to customers from high-risk jurisdictions or those displaying unusual transaction patterns.

Enhanced Due Diligence (EDD)

Enhanced Due Diligence is mandatory for the following categories:

• Customers identified as Politically Exposed Persons (PEPs) or their family members and close associates
• Customers from countries identified as high-risk by the FATF or the EU list of high-risk third countries
• Customers with complex or unusually large transactions that have no apparent economic or lawful purpose
• Customers whose transaction volumes exceed the thresholds established for Tier 3 verification
• Business relationships where there is a higher risk of money laundering or terrorist financing
• Customers flagged by our transaction monitoring systems for suspicious patterns

EDD measures include, but are not limited to: obtaining additional identification documents, establishing the source of funds and source of wealth, enhanced ongoing monitoring, senior management approval for establishing or continuing the business relationship, and more frequent reviews of the customer relationship.

Ongoing Monitoring

Customer due diligence is not a one-time activity. PolyWager conducts ongoing monitoring of all customer relationships to ensure that transactions are consistent with the customer's known risk profile, business activities, and source of funds. This includes:

• Periodic review and update of customer identification information and risk assessments
• Continuous transaction monitoring against established thresholds and behavioral patterns
• Regular rescreening against updated sanctions lists and PEP databases
• Event-driven reviews triggered by material changes in customer behavior or risk factors
• Annual comprehensive reviews for high-risk customer relationships

5.Transaction Monitoring

PolyWager deploys sophisticated, multi-layered transaction monitoring systems designed to detect, flag, and investigate suspicious activities in real time. Our monitoring infrastructure combines rule-based detection, behavioral analytics, and blockchain intelligence tools.

Automated Monitoring Systems

Our automated transaction monitoring systems continuously analyze all customer transactions for indicators of money laundering, terrorist financing, and other financial crime. These systems operate 24/7 and include:

• Rule-Based Detection: Pre-configured rules that flag transactions exceeding defined thresholds, structuring patterns (smurfing), rapid movement of funds, and other known typologies
• Behavioral Analytics: Machine learning models that establish baseline transaction behavior for each customer and flag deviations that may indicate suspicious activity
• Blockchain Analytics: Integration with industry-leading blockchain analytics providers to trace the origin and destination of cryptocurrency transactions, identify high-risk wallet addresses, and detect connections to illicit activities
• Network Analysis: Identification of suspicious relationships between accounts, including linked wallets, shared IP addresses, and coordinated transaction patterns

Monitored Patterns & Red Flags

The following non-exhaustive list of patterns and behaviors are monitored and may trigger enhanced scrutiny or a suspicious activity investigation:

Thresholds

PolyWager maintains defined transaction thresholds that trigger enhanced monitoring and potential reporting obligations. While specific threshold values are maintained as confidential to preserve the effectiveness of our monitoring systems, the following general framework applies:

• All single transactions or aggregated daily transactions exceeding applicable regulatory reporting thresholds are automatically flagged for review
• Cumulative transaction volumes are monitored over rolling 24-hour, 7-day, and 30-day periods
• Threshold values are calibrated to the customer's verified tier and risk profile
• Thresholds are reviewed and adjusted periodically based on regulatory changes and emerging risk indicators

6.Suspicious Activity Reporting

PolyWager is obligated to report suspicious activities to the relevant Financial Intelligence Unit (FIU) in accordance with applicable laws. Suspicious Activity Reports (SARs) are a critical component of our AML compliance program.

SAR Filing Procedures

• Detection: Suspicious activity may be identified through automated monitoring systems, manual transaction reviews, employee reports, or information received from external sources, including law enforcement inquiries.
• Investigation: All flagged transactions undergo a thorough internal investigation by the compliance team. The investigation includes review of all available customer information, transaction history, and any relevant contextual data.
• Determination: The Chief Compliance Officer or designated deputy determines whether reasonable grounds exist to suspect money laundering, terrorist financing, or other reportable activity.
• Filing: Where reasonable suspicion is established, a SAR is filed with the appropriate FIU within the timeframes prescribed by applicable law. In urgent cases involving suspected terrorist financing, reports are made immediately.
• Documentation: All SAR decisions -- including decisions not to file -- are fully documented with supporting rationale and retained in accordance with our record-keeping obligations.

Tipping Off Prohibition

All employees, contractors, and agents of PolyWager are bound by confidentiality obligations regarding SAR filings and related investigations. Information about SARs is shared on a strictly need-to-know basis within the compliance function.

7.Politically Exposed Persons (PEPs)

Politically Exposed Persons present a higher risk of involvement in corruption and money laundering due to the positions they hold. PolyWager implements enhanced measures to identify, manage, and monitor PEP relationships in accordance with FATF Recommendations and applicable legislation.

PEP Identification

PolyWager screens all customers against comprehensive PEP databases at onboarding and on an ongoing basis. PEP status encompasses:

• Domestic and Foreign PEPs: Individuals who are or have been entrusted with prominent public functions, including heads of state or government, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials
• Family Members: Spouses, partners, children, and parents of PEPs, as well as the spouses or partners of children of PEPs
• Close Associates: Individuals known to have close business relationships with PEPs, joint beneficial ownership of legal entities or arrangements with PEPs, or sole beneficial ownership of entities known to have been set up for the benefit of a PEP

Enhanced Measures for PEPs

• Senior management approval is required to establish or continue a business relationship with a PEP
• Establishment of the source of wealth and the source of funds involved in the business relationship
• Enhanced ongoing monitoring of the business relationship, with increased frequency and scrutiny of transactions
• Periodic reassessment of PEP status and associated risk factors
• PEP status is considered to continue for a minimum of 12 months after the individual leaves their public function, with risk-based extensions as appropriate

8.Sanctions Screening

PolyWager maintains a comprehensive sanctions compliance program to ensure that no services are provided to sanctioned individuals, entities, or jurisdictions. Our sanctions screening is a fundamental gating control applied to all customer relationships and transactions.

Sanctions Lists Screened

All customers, counterparties, and transactions are screened against the following sanctions lists:

Screening Procedures

• Real-Time Screening: All customers are screened at onboarding, at each verification tier upgrade, and before the processing of each withdrawal transaction. Screening is performed in real time against the most current versions of applicable sanctions lists.
• Batch Rescreening: The entire customer base is rescreened within 24 hours of any update to the applicable sanctions lists. This ensures that newly designated individuals or entities are promptly identified.
• Fuzzy Matching: Our screening systems employ fuzzy matching algorithms to identify potential matches despite variations in name spelling, transliteration differences, and the use of aliases or alternative names.
• Match Resolution: All potential matches are reviewed by trained compliance personnel who determine whether a true positive match exists. Confirmed matches result in immediate blocking of the account and reporting to relevant authorities.

9.Record Keeping

PolyWager maintains comprehensive records of all customer identification, verification, and transaction data as required by applicable law. Thorough record keeping is essential for regulatory examinations, law enforcement investigations, and internal audit purposes.

Retention Periods

• KYC/CDD Records: All customer identification and verification records, including copies of identity documents, verification results, and risk assessment documentation, are retained for a minimum of five (5) years from the date of termination of the business relationship.
• Transaction Records: Complete records of all transactions, including deposits, withdrawals, wagers, and internal transfers, are retained for a minimum of five (5) years from the date of the transaction.
• SAR Records: All records related to suspicious activity reports, including the report itself, supporting documentation, and the internal investigation file, are retained for a minimum of five (5) years from the date of filing.
• Training Records: Records of AML training provided to staff, including attendance records, training materials, and assessment results, are retained for the duration of employment plus five (5) years.

Audit Trails

PolyWager maintains detailed audit trails that log all relevant events, including:

• Customer account creation, modification, and closure events with timestamps
• All KYC verification submissions, decisions, and status changes
• Login activity, IP addresses, device fingerprints, and geolocation data
• All deposit and withdrawal transactions with blockchain transaction hashes
• Risk assessment changes and the rationale for risk re-classifications
• All SAR-related decisions and actions taken by compliance personnel
• System configuration changes and access to sensitive compliance data

All records are stored securely using encryption at rest and in transit. Access to AML records is restricted to authorized compliance personnel and is logged for audit purposes.

10.Risk Assessment

PolyWager conducts a comprehensive, enterprise-wide money laundering and terrorist financing risk assessment. This risk assessment informs the design and calibration of our AML controls and is updated at least annually or upon the occurrence of significant changes to our business model, customer base, or regulatory environment.

Risk Categories

Risk Scoring

Each customer is assigned a composite risk score based on the weighted assessment of all applicable risk factors. Risk scores are categorized as Low, Medium, High, or Prohibited. The risk score determines the level of due diligence applied, the frequency of ongoing monitoring reviews, and the transaction limits applicable to the account.

Risk scores are dynamic and are recalculated upon changes in customer information, the detection of suspicious activity indicators, updates to sanctions lists or PEP databases, or as part of periodic reviews.

11.Staff Training

PolyWager recognizes that the effectiveness of its AML program depends on the competence and vigilance of its staff. We maintain a comprehensive AML training program that ensures all relevant personnel are equipped to identify, prevent, and report potential money laundering and terrorist financing activities.

Training Program

• Onboarding Training: All new employees and contractors with access to customer data or financial systems receive mandatory AML training within their first week of employment. This training covers the fundamentals of money laundering, terrorist financing, relevant legal obligations, and internal procedures.
• Annual Refresher Training: All relevant staff complete annual refresher training that covers regulatory updates, emerging typologies, lessons learned from internal and industry cases, and updates to internal policies and procedures.
• Specialized Training: Compliance team members, customer support staff, and senior management receive specialized training tailored to their specific roles and responsibilities, including SAR preparation, sanctions screening procedures, and cryptocurrency-specific AML typologies.
• Assessment & Certification: All training modules include competency assessments. Staff must achieve a passing score to be certified. Records of all training activities and assessment results are maintained.

Chief Compliance Officer (CCO)

PolyWager has appointed a qualified Chief Compliance Officer who bears primary responsibility for the implementation and oversight of the AML program. The CCO's responsibilities include:

• Overseeing the design, implementation, and effectiveness of the AML compliance program
• Serving as the primary point of contact for regulatory authorities and law enforcement
• Approving the filing of Suspicious Activity Reports
• Providing regular reports to senior management and the Board on AML compliance matters
• Ensuring that AML policies, procedures, and systems remain adequate and up to date
• Managing the AML training program and ensuring adequate staffing of the compliance function

12.Cryptocurrency-Specific Measures

As a platform that transacts in cryptocurrency, PolyWager implements additional AML controls specifically designed to address the unique risks associated with virtual assets. These measures supplement the general AML controls described elsewhere in this policy.

Blockchain Analytics

PolyWager integrates with industry-leading blockchain analytics platforms to perform comprehensive analysis of all incoming and outgoing cryptocurrency transactions. Our blockchain analytics capabilities include:

• Real-time risk scoring of cryptocurrency wallet addresses based on their transaction history and known associations
• Identification of funds originating from or destined for high-risk sources, including darknet marketplaces, ransomware addresses, sanctioned entities, and known scam operations
• Cluster analysis to identify wallet addresses controlled by the same entity and to map the flow of funds across the blockchain
• Counterparty identification for incoming and outgoing transactions where available through VASP identification protocols

Wallet Screening

All wallet addresses associated with deposits to or withdrawals from the Platform are screened against our blockchain analytics databases. Wallets identified as high-risk may be subject to the following actions:

• Deposits from high-risk wallets may be held pending further investigation and enhanced due diligence
• Withdrawals to high-risk wallets may be blocked and the customer may be required to provide an alternative withdrawal address
• Wallet addresses directly linked to sanctioned entities or illicit activities result in immediate account suspension and reporting to authorities

Travel Rule Compliance

In accordance with FATF Recommendation 16 and applicable regulatory requirements, PolyWager implements Travel Rule procedures for qualifying cryptocurrency transfers. This includes:

• Collection and transmission of required originator and beneficiary information for transfers exceeding applicable thresholds
• Integration with Travel Rule compliance solutions to facilitate the secure exchange of required information with counterparty VASPs
• Verification of received Travel Rule information for incoming transfers and rejection of transfers with incomplete or inconsistent information

Mixer, Tumbler & Privacy Coin Detection

Our monitoring systems are capable of detecting known mixing patterns, including CoinJoin transactions, cross-chain bridges used to obscure the origin of funds, and layered transactions designed to break the chain of traceability.

13.Cooperation with Authorities

PolyWager is committed to full cooperation with law enforcement agencies, regulatory authorities, and Financial Intelligence Units in the prevention and detection of money laundering and terrorist financing. We view this cooperation as a fundamental obligation and a critical component of our role within the broader financial ecosystem.

Law Enforcement Cooperation

• Timely response to lawful requests for information, production orders, and court orders from domestic and international law enforcement agencies
• Proactive reporting of suspected criminal activity through Suspicious Activity Reports filed with the relevant Financial Intelligence Unit
• Preservation of account data and transaction records upon receipt of lawful preservation requests
• Cooperation with asset freezing and seizure orders issued by competent authorities
• Participation in public-private partnership initiatives aimed at combating financial crime

Regulatory Cooperation

• Full cooperation with regulatory examinations, audits, and inquiries related to AML compliance
• Timely submission of all required regulatory reports and filings
• Prompt notification to regulators of material AML compliance deficiencies or incidents
• Participation in industry consultations and regulatory working groups related to AML/CTF in the cryptocurrency and gaming sectors

Information Sharing

Where permitted by applicable law, PolyWager participates in information-sharing arrangements with other financial institutions, VASPs, and industry bodies to enhance the detection and prevention of money laundering and terrorist financing. All information sharing is conducted in compliance with applicable data protection laws and is subject to appropriate confidentiality controls.

14.Non-Compliance Consequences

PolyWager takes a strict approach to non-compliance with this AML Policy. Failure to comply with our AML requirements may result in severe consequences for both customers and employees.

Customer Consequences

Customers who fail to comply with our AML requirements or are suspected of engaging in money laundering, terrorist financing, or other financial crimes may face the following consequences:

• Account Suspension: Immediate suspension of the customer's account pending investigation. During suspension, no deposits, withdrawals, or gaming activity will be permitted.
• Fund Freezing: Freezing of all funds in the customer's account in accordance with applicable legal requirements or where required by a competent authority. Frozen funds remain frozen until the investigation is concluded or a lawful order is received regarding their disposition.
• Account Termination: Permanent closure of the customer's account and prohibition from creating new accounts on the Platform. Remaining funds (if not frozen or seized) will be returned to the customer subject to applicable withdrawal procedures and verification requirements.
• Reporting to Authorities: Filing of a Suspicious Activity Report with the relevant FIU and notification to law enforcement where appropriate. PolyWager will cooperate fully with any subsequent investigation.
• Fund Forfeiture: In cases where funds are determined to be proceeds of crime or where ordered by a competent authority, funds may be permanently forfeited or transferred to the relevant authority.

Employee Consequences

Employees, contractors, or agents who fail to comply with their AML obligations under this policy may face:

• Disciplinary action, up to and including immediate termination of employment
• Reporting to relevant regulatory or law enforcement authorities where criminal conduct is suspected
• Personal criminal liability for facilitation of money laundering, failure to report, or tipping off offenses under applicable law

15.Contact Information

If you have any questions about this AML Policy, need to report suspicious activity, or wish to contact our compliance department, please use the following channels: