Document Information

Subject	Anti-Money Laundering and Countering Financing of Terrorism Policy
Purpose	Policy document containing policies to comply with AML Legislative and Regulatory requirements.
Involvements	All departments Money Laundering ReportingOfficer
Responsibility
Approval	Directors
Review	Annually or earlier as needed
Classification	Company Confidential

Document Information

Date	Ver.	Author	Summary Changes	MLRO
12/02/2025	1.0	Craig John Dinwiddie	New document created as part of AML/CFT Program review	Craig John Dinwiddie

DEFINITIONS:

“Money laundering” means:

a) the conversion or transfer of property, knowing or suspecting that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action.

b) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing or suspecting that such property is derived from criminal activity or from an act of participation in such an activity.

c) the acquisition, possession, retention or use of property, knowing or suspecting, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity.

d) participation in, association to commit, attempts to commit and aiding, abetting, facilitating, and counselling the commission of any of the actions referred to in points (a), (b) and (c).

“Senior management” means an officer or employee with sufficient knowledge of a company’s money laundering and terrorist financing risk exposure and sufficient seniority to take decisions affecting its risk exposure, who does not need, in all cases, to be a member of the board of directors.

“Terrorist financing” means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA of 13 June 2002 on combating terrorism.

“European Economic Area (EEA)” means Member State of the European Union or other contracting state which is a party to the agreement for the European Economic Area signed in Porto on the 2nd of May 1992 and was adjusted by the Protocol signed in Brussels on the 17th of May 1993, as amended.

“EU Directive” means the Directive 2015/849/, EU 847/2015, EC 1781/2006 of the European Parliament and the Council of May 2015 on the prevention of the use of the financial system for Money Laundering and Terrorist Financing.

“Money Laundering and Terrorist Financing” means the money laundering offences and terrorist financing offences defined in the Law.

“Manual” means the Policy on Know Your Customer (KYC) & Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) which has been drafted and adopted according to the EU Directive.

“Occasional Transaction” means any transaction other than a transaction carried out during an established Business Relationship formed by a person acting during financial or other business.

“Clients” means customers utilising valid register account on the betting site services

“Other Business Activities” includes the following trust services and company services to thirdparties:

• Forming companies or other legal persons.
• Acting as or arranging for another person to act as a director or secretary of a company, a partner of a partnership or a similar position in relation to other legal persons.
• Providing a registered office, business address, correspondence or administrative address and other related services for a company, a partnership or any other legal person or arrangement.
• Acting as or arranging for another person to act as a trustee of an express trust or a similar legal arrangement.
• Acting as or arranging for another person to act as a nominee shareholder for another person.

"Politically exposed persons" means natural persons who are or have been entrusted with prominent public functions, other than middle ranking or more junior officials. The definition also covers their immediate family members or persons known to be close associates of such persons.

For the purposes of this definition the term "natural persons who are or have been entrusted with prominent public functions" includes the following both local and foreign :

• Heads of State, Heads of Government, Ministers, Deputy or Assistant Ministers, and Parliamentary Secretaries.
• Members of Parliament or similar legislative bodies.
• Members of the governing bodies of political parties.
• Members of superior, supreme, and constitutional courts or of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances.
• Members of courts of auditors or of the boards of central banks.
• Ambassadors, charges d’affaires and high-ranking officers in the armed forces.
• Members of the administrative, management or supervisory boards of State- owned enterprises.
• Anyone exercising a function equivalent to those set out in paragraphs (a) to (f) within an institution of the European Union or any other international body.
• Family members include the following:
• The spouse, or a person considered to be equivalent to a spouse, of a politically exposed person;
• The children and their spouses, or persons considered to be equivalent to a spouse, of a politically exposed person;
• The parents of a politically exposed person;
• Persons known to be close associates means:
• Natural persons who are known to have joint beneficial ownership of legal entities or legal arrangements, or any other close business relations, with a politically exposed person;
• Natural persons who have sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a politically exposed person.

“Business Relationships” in accordance with the definition provided in the PMLFTR business relationships must comprise three important cumulative elements, which are the following:

• The relationship must be of a business, professional or commercial nature between two or more persons;
• At least one of the persons involved in the relationship must be a subject person (whether undertaking a relevant financial business or a relevant activity);
• The relationship has, or is expected to have at the time when the contact is established, an element of duration.