Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1. Introduction

Ventures Lab Malta Limited (the "Company", "we", "our", or "us") is committed to protecting its gaming platform from being used for money laundering, terrorist financing, fraud, or other unlawful financial activities.

As the holder of a Business-to-Consumer Gaming Service Licence issued by the Malta Gaming Authority ("MGA"), the Company is required to comply with the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta), the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR), and all applicable guidance issued by the Financial Intelligence Analysis Unit ("FIAU") and the MGA.

To meet these obligations, the Company maintains a comprehensive AML and KYC framework based on a risk-based approach that applies throughout the customer lifecycle.

This Policy applies to every individual who registers for, or maintains, an account with the Company.

2. Compliance Principles

The Company's AML and KYC programme is designed to:

• establish and verify the identity of customers;
• understand the purpose of the customer relationship;
• identify and assess money laundering and terrorist financing risks;
• monitor customer activity on an ongoing basis;
• identify suspicious behaviour and report it where required;
• maintain appropriate records to demonstrate regulatory compliance; and
• ensure that employees understand their legal and regulatory responsibilities.

Compliance measures are proportionate to the level of risk presented by each customer.

3. Customer Identification Measures

The Company requires customers to complete identity verification whenever required under applicable legislation or internal compliance procedures.

Verification may be completed before account activation, during the customer relationship, or prior to specific transactions.

Information requested may include:

• full legal name;
• residential address;
• date of birth;
• nationality;
• government-issued identification;
• proof of address;
• ownership of payment instruments; and
• any additional documentation reasonably required to satisfy legal obligations.

Verification may be carried out through secure electronic verification services, documentary review, or other reliable independent sources.

Where the Company cannot satisfactorily verify a customer's identity, it may refuse registration, suspend account activity, restrict transactions, or terminate the business relationship.

4. Enhanced Due Diligence

Certain customers or transactions require additional scrutiny because they present a higher risk of financial crime.

Enhanced Due Diligence ("EDD") may be applied where:

• the customer is identified as a Politically Exposed Person ("PEP");
• sanctions screening identifies a potential match;
• the customer is connected with a high-risk jurisdiction;
• transaction values or behaviour exceed the Company's risk appetite;
• unusual or complex transaction patterns are detected; or
• the source of funds cannot readily be established.

Enhanced verification measures may include:

• obtaining supplementary identity documentation;
• requesting evidence of source of funds or source of wealth;
• conducting additional independent verification;
• increased transaction monitoring; and
• approval by senior compliance management before continuing the relationship.

5. Source of Funds Verification

Where appropriate, the Company may request evidence demonstrating the lawful origin of funds used within the customer's account.

Depending on the circumstances, documentation requested may include:

• recent bank statements;
• employment or salary documentation;
• tax records;
• business ownership documentation;
• investment portfolios;
• inheritance records;
• property sale agreements; or
• other documentation reasonably demonstrating legitimate ownership of funds.

Until satisfactory information has been provided, the Company may restrict account functionality or delay transactions.

6. Ongoing Monitoring

The Company performs continuous monitoring throughout the duration of the customer relationship.

Monitoring procedures are designed to identify activity including:

• unusually large or frequent deposits;
• rapid deposits followed by immediate withdrawals;
• betting activity inconsistent with customer behaviour;
• structuring of transactions;
• use of multiple payment instruments;
• transactions inconsistent with known customer information; and
• other indicators of potential financial crime.

Where monitoring identifies unusual activity, the Company may conduct additional compliance reviews before permitting further transactions.

7. Withdrawal Verification Requirements

To comply with applicable AML, CTF, fraud prevention, and regulatory obligations, the Company may require additional verification before processing withdrawal requests.

Identity verification will ordinarily be required where a customer's cumulative deposits exceed €2,000.

For this purpose, cumulative deposits may be calculated either:

• on a daily cumulative basis, taking into account every deposit made since the business relationship commenced; or
• by aggregating deposits made during a rolling period of one hundred and eighty (180) days.

Where enhanced verification becomes necessary, withdrawal requests may remain pending until all requested documentation has been received and successfully reviewed.

The Company may additionally require customers to verify ownership of payment methods, provide supporting evidence regarding the origin of deposited funds, or submit further documentation where considered necessary for compliance purposes.

8. Sanctions and PEP Screening

The Company screens customers against recognised sanctions and Politically Exposed Person databases during onboarding and throughout the customer relationship.

Screening includes, where applicable:

• European Union sanctions lists;
• United Nations sanctions lists;
• domestic sanctions registers;
• PEP databases; and
• other recognised compliance screening systems.

Potential matches are reviewed by the Compliance function before any decision affecting the customer relationship is made.

9. Suspicious Activity Reporting

Where knowledge, suspicion, or reasonable grounds for suspicion of money laundering, terrorist financing, or related criminal conduct exist, the Company will submit a Suspicious Activity Report ("SAR") to the Financial Intelligence Analysis Unit ("FIAU") in accordance with Maltese law.

Employees are prohibited from informing customers that a report has been submitted or that an investigation is taking place.

The Company will cooperate fully with the FIAU, the Malta Gaming Authority, law enforcement agencies, and any other competent authority acting within its legal powers.

10. Customer Responsibilities

Customers are responsible for:

• providing accurate and complete registration information;
• maintaining current personal details throughout the business relationship;
• supplying verification documents upon request;
• responding promptly to compliance enquiries; and
• ensuring that documentation submitted is authentic and valid.

Failure to comply with these obligations may result in restrictions on account activity, suspension of services, delayed transactions, or closure of the customer account.

11. Governance and Internal Controls

The Company's AML framework is supported through appropriate governance arrangements, including:

• appointment of a Money Laundering Reporting Officer (MLRO);
• documented AML and CTF policies;
• internal escalation and reporting procedures;
• periodic enterprise-wide risk assessments;
• compliance monitoring activities;
• independent internal reviews where appropriate; and
• regular AML and financial crime awareness training for employees.

These measures are reviewed periodically to ensure their effectiveness and ongoing compliance with regulatory expectations.

12. Record Keeping and Confidentiality

The Company maintains records relating to customer due diligence, verification, monitoring activities, transactions, risk assessments, and regulatory reporting as required under applicable legislation.

Records are retained for a minimum period of five (5) years following the termination of the business relationship or the completion of the relevant transaction, unless a longer retention period is required by law.

All personal information collected under this Policy is processed securely and confidentially in accordance with the General Data Protection Regulation (GDPR) and the Company's internal information security procedures.

13. Policy Administration

This Policy forms part of the Company's compliance management framework and is subject to periodic review by the Compliance function and Senior Management.

The Company may amend this Policy whenever necessary to reflect legislative developments, regulatory guidance, operational changes, or enhancements to its financial crime prevention framework. The latest approved version will be made available through the Company's official channels.

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1. Introduction

Ventures Lab Malta Limited (the "Company", "we", "our", or "us") is committed to protecting its gaming platform from being used for money laundering, terrorist financing, fraud, or other unlawful financial activities.

As the holder of a Business-to-Consumer Gaming Service Licence issued by the Malta Gaming Authority ("MGA"), the Company is required to comply with the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta), the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR), and all applicable guidance issued by the Financial Intelligence Analysis Unit ("FIAU") and the MGA.

To meet these obligations, the Company maintains a comprehensive AML and KYC framework based on a risk-based approach that applies throughout the customer lifecycle.

This Policy applies to every individual who registers for, or maintains, an account with the Company.

2. Compliance Principles

The Company's AML and KYC programme is designed to:

• establish and verify the identity of customers;
• understand the purpose of the customer relationship;
• identify and assess money laundering and terrorist financing risks;
• monitor customer activity on an ongoing basis;
• identify suspicious behaviour and report it where required;
• maintain appropriate records to demonstrate regulatory compliance; and
• ensure that employees understand their legal and regulatory responsibilities.

Compliance measures are proportionate to the level of risk presented by each customer.

3. Customer Identification Measures

The Company requires customers to complete identity verification whenever required under applicable legislation or internal compliance procedures.

Verification may be completed before account activation, during the customer relationship, or prior to specific transactions.

Information requested may include:

• full legal name;
• residential address;
• date of birth;
• nationality;
• government-issued identification;
• proof of address;
• ownership of payment instruments; and
• any additional documentation reasonably required to satisfy legal obligations.

Verification may be carried out through secure electronic verification services, documentary review, or other reliable independent sources.

Where the Company cannot satisfactorily verify a customer's identity, it may refuse registration, suspend account activity, restrict transactions, or terminate the business relationship.

4. Enhanced Due Diligence

Certain customers or transactions require additional scrutiny because they present a higher risk of financial crime.

Enhanced Due Diligence ("EDD") may be applied where:

• the customer is identified as a Politically Exposed Person ("PEP");
• sanctions screening identifies a potential match;
• the customer is connected with a high-risk jurisdiction;
• transaction values or behaviour exceed the Company's risk appetite;
• unusual or complex transaction patterns are detected; or
• the source of funds cannot readily be established.

Enhanced verification measures may include:

• obtaining supplementary identity documentation;
• requesting evidence of source of funds or source of wealth;
• conducting additional independent verification;
• increased transaction monitoring; and
• approval by senior compliance management before continuing the relationship.

5. Source of Funds Verification

Where appropriate, the Company may request evidence demonstrating the lawful origin of funds used within the customer's account.

Depending on the circumstances, documentation requested may include:

• recent bank statements;
• employment or salary documentation;
• tax records;
• business ownership documentation;
• investment portfolios;
• inheritance records;
• property sale agreements; or
• other documentation reasonably demonstrating legitimate ownership of funds.

Until satisfactory information has been provided, the Company may restrict account functionality or delay transactions.

6. Ongoing Monitoring

The Company performs continuous monitoring throughout the duration of the customer relationship.

Monitoring procedures are designed to identify activity including:

• unusually large or frequent deposits;
• rapid deposits followed by immediate withdrawals;
• betting activity inconsistent with customer behaviour;
• structuring of transactions;
• use of multiple payment instruments;
• transactions inconsistent with known customer information; and
• other indicators of potential financial crime.

Where monitoring identifies unusual activity, the Company may conduct additional compliance reviews before permitting further transactions.

7. Withdrawal Verification Requirements

To comply with applicable AML, CTF, fraud prevention, and regulatory obligations, the Company may require additional verification before processing withdrawal requests.

Identity verification will ordinarily be required where a customer's cumulative deposits exceed €2,000.

For this purpose, cumulative deposits may be calculated either:

• on a daily cumulative basis, taking into account every deposit made since the business relationship commenced; or
• by aggregating deposits made during a rolling period of one hundred and eighty (180) days.

Where enhanced verification becomes necessary, withdrawal requests may remain pending until all requested documentation has been received and successfully reviewed.

The Company may additionally require customers to verify ownership of payment methods, provide supporting evidence regarding the origin of deposited funds, or submit further documentation where considered necessary for compliance purposes.

8. Sanctions and PEP Screening

The Company screens customers against recognised sanctions and Politically Exposed Person databases during onboarding and throughout the customer relationship.

Screening includes, where applicable:

• European Union sanctions lists;
• United Nations sanctions lists;
• domestic sanctions registers;
• PEP databases; and
• other recognised compliance screening systems.

Potential matches are reviewed by the Compliance function before any decision affecting the customer relationship is made.

9. Suspicious Activity Reporting

Where knowledge, suspicion, or reasonable grounds for suspicion of money laundering, terrorist financing, or related criminal conduct exist, the Company will submit a Suspicious Activity Report ("SAR") to the Financial Intelligence Analysis Unit ("FIAU") in accordance with Maltese law.

Employees are prohibited from informing customers that a report has been submitted or that an investigation is taking place.

The Company will cooperate fully with the FIAU, the Malta Gaming Authority, law enforcement agencies, and any other competent authority acting within its legal powers.

10. Customer Responsibilities

Customers are responsible for:

• providing accurate and complete registration information;
• maintaining current personal details throughout the business relationship;
• supplying verification documents upon request;
• responding promptly to compliance enquiries; and
• ensuring that documentation submitted is authentic and valid.

Failure to comply with these obligations may result in restrictions on account activity, suspension of services, delayed transactions, or closure of the customer account.

11. Governance and Internal Controls

The Company's AML framework is supported through appropriate governance arrangements, including:

• appointment of a Money Laundering Reporting Officer (MLRO);
• documented AML and CTF policies;
• internal escalation and reporting procedures;
• periodic enterprise-wide risk assessments;
• compliance monitoring activities;
• independent internal reviews where appropriate; and
• regular AML and financial crime awareness training for employees.

These measures are reviewed periodically to ensure their effectiveness and ongoing compliance with regulatory expectations.

12. Record Keeping and Confidentiality

The Company maintains records relating to customer due diligence, verification, monitoring activities, transactions, risk assessments, and regulatory reporting as required under applicable legislation.

Unless otherwise required by law, such records are retained for a minimum period of five (5) years following the termination of the business relationship or the completion of the relevant transaction, unless a longer retention period is required by law.

All personal information collected under this Policy is processed securely and confidentially in accordance with the General Data Protection Regulation (GDPR) and the Company's internal information security procedures.

13. Policy Administration

This Policy forms part of the Company's compliance management framework and is subject to periodic review by the Compliance function and Senior Management.

The Company may amend this Policy whenever necessary to reflect legislative developments, regulatory guidance, operational changes, or enhancements to its financial crime prevention framework. The latest approved version will be made available through the Company's official channels.