AML Policy

It is 10Sports's policy to actively prevent the company's services from being used to facilitate financial crime, money laundering and terrorist financing.

Strict compliance with all applicable regulations will also protect the company's management and employees, as individuals, from the risks of violations of law, regulations, and oversight requirements and preserve 10Sports's reputation against damage that could be caused by being implicated in money laundering and terrorist financing activities.

To achieve these objectives, it is the policy of this firm that:

• Each employee shall perform his or her duties in accordance with his or her duties and responsibilities;
• Commercial considerations cannot take precedence over 10Sports’s anti-money laundering commitment;
• The company shall appoint a Money Laundering Reporting Officer/Nominated Officer (“MLRO”) and a substitute to cover it in their absence, and they shall receive all assistance and cooperation from all employees in the exercise of their duties and responsibilities. The replacement will be the Chief Executive Officer (CEO).

10Sports will strictly comply with all applicable AML/CFT rules and regulations, with an emphasis on:

• A culture of compliance to be adopted and enacted throughout the company for the prevention of financial crimes;
• Commitment to ensure that the identities of customers are satisfactorily verified within the required limits;
• Commitment to “know your customer” appropriately, both in acceptance and throughout the business relationship, by taking appropriate measures to verify the customer’s identity and monitor their use of 10Sports’s services;
• Commitment to ensure that employees are trained and informed about the law and their obligations under it and to establish procedures to implement these requirements; and
• Recognition of the importance of employees promptly reporting their suspicions internally:

At the heart of our policies, procedures, and controls is a risk-based approach. The risk-based approach means that we focus our resources on the areas of greatest risk.

Our policies, procedures, and internal controls are designed to ensure compliance with all applicable anti-money laundering and anti-terrorist financing regulations and regulatory guidelines and will be reviewed and updated regularly to ensure that appropriate policies, procedures, and internal controls are in place to respond to any changes in regulations and changes in our business.

Money Laundering and Terrorist Financing

Money Laundering means:

1. The conversion or transfer of property, knowing 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 activity to evade the legal consequences of his action;
2. The concealment or disguise of the true nature, source, location, disposition, movement, and rights with respect to or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
3. The acquisition, possession or use of property, knowing, upon receipt, that it comes from a criminal activity or from participation in such an activity;
4. Participation, association to be committed, attempts to commit and assist, complicity, facilitation, and advice to the committee of any of the actions referred to in subparagraphs (a), (b), and (c).

Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Terrorist financing means the provision or collection of funds by any means, directly or indirectly, with the intention that they be used or with the knowledge that they should be used, in whole or in part, to carry out any terrorist act.

AML/CFT function organization

Senior Management

Senior Management is responsible for 10Sports's overall compliance policy and ensures that adequate resources are provided for the proper training of employees and the implementation of risk systems. This includes computer software to help with supervision. The Senior Management is composed of the Board of Directors, the Executive Management and the MLRO.

The Nominated Officer/Money Laundering Reporting Officer

Is responsible for receiving internal disclosures and making reports to the Gaming Control Board, Curacao. First point of contact for all employee compliance issues. Conducts risk assessments of compliance systems. Conducts regular random analysis of transactions, including evaluation of customer-provided documentary evidence. Assists in making any necessary changes to the AML Policy in accordance with the risk assessment. It ensures that everyone is periodically informed of any changes in anti-money laundering or anti-terrorist financing legislation, policies, and procedures, as well as current developments and changes in money laundering schemes or financing of terrorist activities specific to their jobs. Reviews customer identification information to ensure all necessary information has been obtained. Establishes and implements the risk score matrix following regulatory guidelines and for review and approval by Senior Management.

Employees

Responsible for knowing the AML Compliance Policy and understanding responsibilities. Ensure company procedures are adhered to and obtain all documentary evidence as described in the manual. Ensure that all suspicious and unusual activity is reported to the MLRO.

Compliance Program

The Money Laundering Reporting Officer (MLRO)

10Sports has appointed an MLRO with full responsibility for 10Sports's anti-money laundering compliance.

The MLRO:

• Must monitor the day-to-day operation of 10Sports Trading's AML/CFT policies and will respond to any reasonable request made by the authorities and/or the Gaming Control Board, Curaçao.
• It has the authority to act independently in discharging its responsibilities, which includes direct access to the Gaming Control Board, Curacao, and appropriate authorities, so that any suspicious activity can be reported to the relevant authorities as soon as possible.
• It has the authority and resources necessary to carry out its responsibilities effectively.
• It is at a senior level and has direct access to senior management and the board of directors.
• You may choose to delegate certain functions to other employees, but whenever such delegation is made, the MLRO retains ultimate responsibility for the implementation of the compliance regime.
• At least annually, the MLRO will issue a report (the MLRO Report) to 10Sports's senior management on the operation and effectiveness of money laundering controls. This report will cover improvements, remedial programs, the outcome of any internal audit reviews of AML/CFT processes, and other relevant items.

Compliance policies and procedures

10Sports has policies and procedures to assess risks related to money laundering and terrorist financing. These policies and procedures are:

• Written and maintained by MLRO under the supervision of senior management
• Approved by senior management
• Communications are understood and respected by all who deal with customers or their transactions, including those working in areas related to customer identification, record keeping, and reportable transactions, who need sufficient information to properly process and complete a transaction, as well as to verify the identity of customers and maintain records as needed.
• Policies and procedures that incorporate applicable reporting, record-keeping, customer identification, risk assessment, and risk mitigation requirements.
• While directors and senior officers may not be involved in day-to-day compliance, they need to understand the statutory duties imposed on them, their employees, and 10Sports itself.

With regard to money laundering and terrorist financing, a risk-based approach covers the following:

• The risk assessment of customer relations and business activities;
• Risk mitigation to implement controls to deal with identified risks;
• Keep customer identification, beneficial ownership and business relationship information up-to-date;
• Continuous monitoring of business relationships and transactions.
• Existing regulatory obligations, such as customer identification, are a minimum basic requirement. When enhanced due diligence is appropriate, a principle of the risk-based approach is to focus resources where they are most needed to manage risks within our tolerance level.

Risk mitigation

Risk mitigation is implementing controls to limit the potential money laundering and terrorist financing risks identified in the risk assessment so as to remain within the level of risk tolerance. When the risk assessment determines that the risk is high for money laundering or terrorist financing, we will develop risk mitigation strategies and apply them.

In all situations, risk mitigation controls and measures include:

• Focus on operations (products and services, customers and business relationships, geographic locations and any other relevant factors) that are most vulnerable to abuse by money launderers and criminals;
• Inform senior management about compliance initiatives, identified compliance deficiencies, corrective actions taken and suspicious transaction reports filed;
• Provide continuity of the program despite changes in management, employees or structure;
• Focus on compliance with all regulatory record-keeping and reporting requirements, recommendations for anti-money laundering and anti-terrorist financing compliance, and provide timely updates in response to changing requirements;
• Incorporate anti-money laundering and anti-terrorist financing compliance into job descriptions and performance appraisals of appropriate personnel;
• Provide appropriate supervision and training to employees who handle currency transactions, complete reporting, monitor suspicious transactions, or engage in any other activity that is part of the anti-money laundering and terrorist financing program.
• Increase awareness of high-risk situations across all lines of business;
• Increase the frequency of continuous monitoring of transactions or business relationships;
• Escalate the approval of the establishment of an account or relationship, even if it is not necessary to do so;
• Prevent any transaction with a prospective customer until identification and account opening information have been obtained;
• Implement an appropriate process to approve all relationships identified as high-risk as part of the customer acceptance process or refuse to do business with potential customers because they exceed 10Sports's level of risk tolerance;
• Implement a process to exit an existing high-risk relationship that management considers exceeds 10Sports's level of risk tolerance;

Risk assessment

10Sports is obliged to analyze potential threats and vulnerabilities to money laundering and terrorist financing to which the company may be exposed in a risk assessment.

The risk assessment shall document and consider the following:

• Products, services and delivery channels
• Geographical locations and areas of operation
• Customers

Risk assessment can identify high-risk situations for which risk mitigation controls and monitoring may be required. Risk assessment is not static and will change over time. When a customer is identified as high-risk, they are subject to monitoring and updating of the most frequent continuous customer identification information, as well as any other appropriate additional measures.

10Sports shall conduct an initial risk assessment at the beginning of a new customer relationship and for existing customers on an ongoing basis.