AML Policy

LUXVERITAS LTD, the operator of the MintBets platform, registered in the Republic of Cyprus under company number HE 491127 ("MintBets", "we", "us" or "our"), is committed to preventing money laundering, terrorist financing, proliferation financing, fraud and the misuse of its services for any unlawful purpose. This Anti-Money Laundering and Counter-Terrorist Financing Policy (the "AML Policy") describes the principles, controls and obligations that govern that commitment.

This AML Policy applies to every person who registers for, accesses or uses the Service in any capacity and forms an integral part of the Terms of Service. By using the Service you accept and undertake to comply with this AML Policy.

Our programme is designed in accordance with the standards set out by the Financial Action Task Force (FATF), the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism, the Cyprus Prevention and Suppression of Money Laundering Activities Law of 2007 (Law 188(I)/2007), as amended, and the European Union Anti-Money Laundering Directives in force from time to time. Where the activities of MintBets fall within the scope of additional national or supranational legislation, we adapt the programme accordingly.

Our AML programme is built around five core principles: (a) a documented enterprise-wide risk assessment that is reviewed at least annually and following any material change in the business or its operating environment; (b) a risk-based customer due-diligence framework calibrated to the risk presented by each customer relationship; (c) ongoing monitoring of customer activity, transactions and behaviour; (d) prompt reporting of suspicious activity to the competent authorities; and (e) a culture of compliance supported by training, independent review and senior-management accountability.

Overall responsibility for the AML programme rests with the Board of Directors of LUXVERITAS LTD. Day-to-day implementation is delegated to a Money Laundering Reporting Officer (MLRO) of sufficient seniority, independence and standing, supported by a dedicated compliance team. The MLRO is the designated contact point for the competent authorities and is responsible for the assessment of internal suspicious-activity reports, the filing of external reports where appropriate, the maintenance of the AML risk assessment, the calibration of monitoring rules, and the annual report to senior management on the operation and effectiveness of the programme.

5.1 Standard due diligence

Before a customer relationship is established and at appropriate intervals thereafter, we identify each customer and verify their identity on the basis of reliable, independent source documents, data or information. Verification typically requires (a) full name, date of birth, nationality and residential address; (b) a government-issued photographic identification document; (c) proof of address dated within the last three months; and (d) a real-time liveness or "selfie" check performed through a trusted verification provider.

5.2 Simplified due diligence

Where a relationship presents a demonstrably low risk of money laundering or terrorist financing and the conditions set out in the applicable legislation are satisfied, the extent of the due-diligence measures may be reduced. Simplified due diligence is never applied where there is a suspicion of money laundering, terrorist financing or proliferation financing.

5.3 Enhanced due diligence

Enhanced due-diligence measures are applied in situations presenting a higher risk, including in respect of (a) politically exposed persons, their family members and known close associates; (b) customers established in jurisdictions identified as high-risk by the FATF or the European Commission; (c) customers exhibiting unusual or large-scale transactional behaviour; (d) deposits or withdrawals involving privacy coins, mixing services, peer-to-peer ramps with elevated risk profiles, or addresses linked by blockchain analytics to illicit activity; and (e) any other circumstance that the MLRO considers warrants additional scrutiny. Enhanced due diligence may include the request of supplementary identification documents, additional information regarding the source of funds and source of wealth, written declarations, and senior-management approval for the continuation of the relationship.

5.4 Source of funds and source of wealth

We may at any time request documentary evidence to substantiate the source of funds used to deposit to your Account and, where relevant, the source of the wealth from which those funds derive. Acceptable evidence includes bank statements, exchange statements, salary slips, tax returns, sale-of-property documents, dividend statements, audited financial statements, inheritance documents or any other document that, in the reasonable view of the MLRO, sufficiently substantiates the origin of the funds.

5.5 Ongoing monitoring

We monitor the business relationship on an ongoing basis. This includes scrutiny of transactions undertaken throughout the course of the relationship to ensure that they are consistent with our knowledge of the customer, the customer's business and risk profile and, where necessary, the source of funds, as well as ensuring that documents, data and information held in respect of the customer are kept up to date.

Each deposit and withdrawal address used in connection with the Service is screened by reputable blockchain analytics providers. Screening produces a risk score that reflects the address's direct and indirect exposure to sanctioned entities, darknet markets, ransomware operators, scams, fraud, mixers, gambling sites operating without authorisation, and other high-risk counterparties. Where a deposit is associated with a risk score above our internal tolerance, the funds may be frozen pending investigation, returned to the sending address less network fees, retained pending instructions from a competent authority, or, where required by law, reported to the relevant authority. The Service does not accept deposits from addresses known to be associated with sanctioned persons, illicit goods or services or other prohibited categories of activity.

All customers, beneficial owners and counterparties are screened, both at onboarding and on an ongoing basis, against the consolidated sanctions lists published by the United Nations Security Council, the European Union, the United Kingdom HM Treasury Office of Financial Sanctions Implementation, the United States Office of Foreign Assets Control (OFAC), and any other list applicable to our operations. A confirmed match results in the immediate suspension of the relevant relationship pending escalation to the MLRO and, where required, to the competent authority.

All members of staff are required to escalate to the MLRO any activity, transaction or pattern of behaviour that gives rise to a suspicion of money laundering, terrorist financing, fraud or other criminal conduct. The MLRO assesses each internal report independently and, where the threshold for external reporting is met, files a suspicious-activity report ("SAR") with the Cyprus Unit for Combating Money Laundering (MOKAS) or with any other competent authority designated by applicable law. The making of an internal or external suspicious-activity report does not require, and shall not be conditional upon, the consent of the customer. Disclosure to the customer of the existence or content of a SAR, or of the fact that an investigation is being or may be carried out, is prohibited ("tipping-off") and constitutes a criminal offence under applicable law.

The following activities are strictly prohibited and will result in the immediate suspension or closure of the Account, the forfeiture of relevant balances, and, where appropriate, referral to the competent authorities: (a) the deposit of funds derived from any criminal activity or intended to finance terrorism or proliferation; (b) the use of mixers, tumblers, coin-join services or any other instrument designed to obscure the source of funds; (c) the use of payment instruments or wallets not owned and controlled by the registered customer; (d) the operation of multiple Accounts whether in your own name or in the name of another; (e) the layering of transactions through the Account for the purpose of disguising the origin of funds; (f) collusion with one or more other Players to manipulate gameplay or move value between Accounts; (g) the use of the Service by any person resident or located in a Restricted Jurisdiction; and (h) any attempt to provide false, misleading or impersonated information to the verification process.

We retain customer due-diligence records, transaction records and the records of internal and external suspicious-activity reports for a minimum period of five (5) years after the closure of the Account or the completion of the relevant transaction, whichever is later, and for any longer period that may be required by applicable law or by a competent authority. Records are stored securely and made available to competent authorities on lawful request.

All members of staff, contractors and any third party performing functions on our behalf receive AML training appropriate to their role at induction and, thereafter, at least annually. Training is updated to reflect changes in the regulatory environment, the evolution of typologies relevant to the cryptocurrency-gaming sector, and findings from internal monitoring. Completion of training is recorded and reported to senior management.

The design and operation of the AML programme is reviewed periodically by an independent function whose findings are reported directly to the Board of Directors. Remediation of any identified weakness is tracked through to completion. The frequency of independent review is calibrated to the risk presented by the business and is not less than once every two years.

We cooperate fully with all lawful requests from regulators, law-enforcement agencies, financial intelligence units and other competent authorities. Where required by law, we will provide such authorities with access to records, documents and information in our possession and will implement any production order, freezing order, restraint order or other lawful instruction issued in accordance with applicable law.

Enquiries in respect of this AML Policy or in respect of a specific compliance matter may be addressed to the MLRO at LUXVERITAS LTD, Attn: MLRO, Kerkyras & John Kennedy 11, Amaranthe House, Ground Floor, 3107, Limassol, Cyprus, or by email to compliance@mintbets.com.