SUVYD B.V.

Registered under the laws of Curaçao with registration number 164492 and registered address at Abraham Mendez Chumaceiro Boulevard 03, P.O. Box 4750, Curaçao.

ANTI-MONEY LAUNDERING (AML) AND COUNTER-TERRORIST FINANCING (CTF) POLICY

General Definitions

“Beneficial Owner” – the individual(s) who ultimately owns or controls the Client and/or the individual on whose behalf a transaction or activity is carried out.

“Business Relationship” – a professional relationship established between the Client and the Company in connection with its core business activities.

“Client” – any individual intending to establish a business relationship or conduct a transaction with the Company. Counterparties are considered Clients only when the Company executes a Client order by entering into a payment processing or money transmission transaction with them directly.

“Company” – SUVYD B.V., incorporated under the laws of Curaçao, with registration number 164492 and registered address at Abraham Mendez Chumaceiro Boulevard 03, P.O. Box 4750, Curaçao.

“FIU/MOT” or “Financial Intelligence Unit” – the national authority responsible for collecting, analyzing, and disseminating financial intelligence to the appropriate bodies, particularly concerning suspected criminal activity or terrorism financing. The Dutch acronym “MOT” refers to "Meldpunt Ongebruikelijke Transacties."

“Regulator” – the Central Bank of Curaçao and Sint Maarten.

“Payment Processing and Money Transmission Services” – the core services provided by the Company, licensed by the Regulator, involving the handling of payments and fund transfers.

“Manual” – this document, outlining internal risk management and AML/CFT procedures in accordance with applicable law and regulation.

“Money Laundering and Terrorist Financing” – defined by the Central Bank of Curaçao and Sint Maarten as per its September 2013 “Provisions and Guidelines on the Detection and Deterrence of Money Laundering and Terrorist Financing for Company (Trust) Service Providers.”

Money laundering typically includes activities designed to disguise the origin of illicitly obtained funds and may involve the following three stages:

Placement – Introduction of illegal funds into the financial system (e.g., bank deposits).
Layering – Concealing the source of the funds through complex layers of transactions.
Integration – The laundered funds re-enter the economy, appearing as legitimate business earnings.

Terrorist Financing refers to handling funds or property knowing they are intended to support terrorism or terrorist organizations, regardless of whether the assets originate from legal or illegal sources.

“Occasional Transaction” – a transaction carried out by a person outside an established Business Relationship.

“Politically Exposed Persons (PEPs)” – individuals holding or having held high-ranking public positions, along with their immediate family members and close associates. Examples include heads of state, government ministers, military generals, members of parliament, ambassadors, judges, and directors of state-owned enterprises.

“Prohibited Jurisdictions” – countries or territories subject to international economic sanctions or restrictions issued by the United Nations (UN), European Union (EU), United States Department of the Treasury (OFAC), or other relevant authorities. Individuals or entities resident in or associated with such jurisdictions are prohibited from opening or maintaining an account with the Company. These restrictions apply regardless of the nationality or citizenship of the individual if they are located in or operating from a Prohibited Jurisdiction.

“Regulations” – the Money Laundering (Prevention) Regulations in force within Curaçao.

This Manual establishes the basis for internal Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) controls while providing services to Clients.

The Manual is periodically reviewed and updated by the Company’s appointed Compliance Officer (CO) and must be approved by the Board of Directors. It is the responsibility of the Board and the CO to ensure that all employees engaged in payment processing and transmission are familiar with its contents.

It is essential to recognize that this Manual outlines procedures for predictable scenarios. However, due to the evolving nature of criminal tactics, employees must apply professional judgment beyond the framework of this Manual.

For transactions exceeding EUR 10,000, a Declaration of Source of Funds must be completed and supporting evidence documented internally.

This Manual applies to all payment processing and money transmission services offered by the Company through the orobet.com platform.

The appendices and case examples previously referenced have been removed for clarity and to align this document with a streamlined, principle-based compliance model. All forms and templates (e.g., for internal suspicion reporting or source of funds) are maintained separately by the Compliance Officer and are available upon request internally.

1. Board of Directors – Statement and Responsibilities

The Board of Directors of SUVYD B.V. affirms that maintaining corporate integrity—defined as a consistent adherence to ethical business standards—is essential to customer trust and business stability.

As such, it is the Company’s policy to adopt and implement robust anti-money laundering and counter-terrorist financing measures, as outlined in this Manual. This includes detection and reporting of any suspicious activities.

The responsibilities of the Board include:

Defining and approving the Company’s AML/CFT policies.
Appointing a Compliance Officer (CO) and supporting the CO’s responsibilities.
Approving this Manual and ensuring it is accessible to relevant staff.
Ensuring compliance with applicable legislation and regulations.
Granting the CO full access to customer data and transaction information for monitoring purposes.
Ensuring staff are informed of the CO and understand their responsibilities to report suspicious activity.
Implementing a clear internal reporting structure.
Providing the CO with sufficient resources and authority to fulfill their duties.
Maintaining a clear and auditable communication path for AML-related concerns.
Overseeing the internal audit function for AML compliance.

2. Anti-money Laundering Compliance Officer (CO)

To meet AML/CFT requirements, the Company has appointed a qualified Compliance Officer (CO). The CO reports directly to senior management and is supported by the Board of Directors.

The CO is responsible for:

Developing and updating the Client Acceptance Policy.
Proposing updates to this Manual and submitting them to the Board for approval.
Notifying the Board upon filing a Suspicious Transaction Report (STR).
Receiving and reviewing Internal Suspicion Reports from Company employees.
Preparing Internal Evaluation Reports for review by the Board.
Acting as the primary liaison with regulatory and enforcement authorities (e.g., FIU/MOT).
Organizing AML training sessions for staff.
Conducting annual AML risk assessments for new and existing clients.
Reviewing the due diligence procedures of any third parties relied upon for client onboarding.
Keeping the Board informed of legal and regulatory updates.
Identifying training needs for staff and implementing regular training programs.
Preparing and submitting the Annual Report on AML compliance.
Responding to requests from the FIU/MOT or the Central Bank of Curaçao and Sint Maarten.
Implementing audit findings and remediation plans where required.
Ensuring all decisions are made fairly, legally, and in line with AML obligations.

3. Annual Independent Assessment of the AML Program

An independent assessment of the Company’s AML program must be conducted annually by a qualified external party. This party must have a strong working knowledge of Curaçao's AML/CTF legal framework, including the requirements of the Financial Intelligence Unit (FIU/MOT).

The scope of the annual assessment includes:

Evaluating changes or updates to applicable laws and regulations.
Reviewing significant deficiencies identified in the Company’s AML policies, procedures, controls, and practices.
Assessing the effectiveness and adequacy of AML policies and alignment with FIU/MOT expectations.
Verifying the accuracy and completeness of the Company’s Player Risk Assessments.
Reviewing communication practices with staff regarding AML/CFT compliance.
Reviewing how the Company handles high-risk clients, including risk mitigation strategies and country-of-origin profiling.
Analyzing ongoing monitoring systems and controls for client transactions and behavior.
Evaluating training activities, including:

Number and content of AML training sessions.
Staff attendance records and trainer credentials.
Internal or external development of the training materials.

Assessing staff understanding and application of AML procedures in practice.
Confirming that PEP-related due diligence procedures are in place and consistently applied.
Ensuring ongoing monitoring of transactions and client activity for all client risk categories.
Confirming record-keeping systems meet legal retention and retrieval requirements.

The results of this assessment, including any identified deficiencies and recommendations for improvements, must be submitted to senior management and the Board of Directors for review and implementation.

4. Client Acceptance Policy (CAP)

The Client Acceptance Policy (CAP) defines the criteria for onboarding new clients and classifying them according to risk. These standards ensure that only eligible and properly verified clients may establish a business relationship with the Company.

4.1. General Principles

Clients must be classified into distinct risk categories: Low, Normal, or High.
No client account may be opened without proper due diligence.
Anonymous or fictitious names are not permitted.
All required documents and information must be collected before onboarding.
Final approval must be granted by the General Manager and/or Compliance Officer.

4.2. Client Risk Categories

Low Risk Clients

Clients subject to public oversight or regulation, such as:

Regulated financial institutions in EEA countries or equivalent jurisdictions
Listed companies on regulated markets
Public authorities of EEA countries

Simplified due diligence may be applied to low-risk clients.

Normal Risk Clients

Clients that do not fall into either the Low or High risk category.
Standard due diligence procedures apply.

High Risk Clients

Require enhanced due diligence.
Include, but are not limited to:

Clients not physically present for identification
Clients with bearer shares
Trusts and nominee accounts
Politically Exposed Persons (PEPs)
Clients from countries with weak AML/CFT systems
Clients involved in online gambling activities

Unacceptable Clients

Clients from prohibited jurisdictions (e.g., residents of the Netherlands Antilles)
Clients who fail or refuse to provide sufficient verification data
Clients listed on AML blacklists
Underaged persons or residents of jurisdictions where gambling is illegal
Clients involved in illegal activities or presenting significant AML risk

4.3. Assignment and Documentation

The Compliance Officer is responsible for assigning the appropriate risk category to each client, based on the collected and verified information.

All client classification decisions must be documented and retained.
Clients may be reclassified based on changes in activity, status, or new information.

4.4. Sanction Screening and Restricted Jurisdictions

The Company performs automated and manual screening of all prospective and existing Clients against global sanctions and watchlists, including:

United Nations Sanctions Lists
European Union Consolidated Sanctions List
Office of Foreign Assets Control (OFAC) Sanctions Lists
Curaçao Gaming Control Board internal restricted jurisdictions list

If a Client is identified as residing in or transacting from a Prohibited Jurisdiction, or if they are identified on any applicable sanctions list, their account shall be immediately suspended or denied, and reported to the relevant authority where appropriate.

The Company does not onboard or maintain accounts for Clients residing in or having any beneficial connection to the following jurisdictions (including but not limited to):
United States, Netherlands, France, Curaçao, Netherlands Antilles, North Korea, Iran, Syria, Belarus, Russia and other jurisdictions classified as high-risk and non-cooperative by FATF.

5. Client Due Diligence and Identification Procedures

The Company implements due diligence and identification procedures to ensure compliance with AML/CTF obligations. These procedures apply to the onboarding of new clients and to the ongoing monitoring of existing clients.

5.1. When Due Diligence Is Required

Due diligence and identification must be conducted:

Before establishing a business relationship or executing a transaction.
Upon reaching or exceeding the €2,000 threshold.
When there are doubts about the adequacy or accuracy of previously obtained identification data.
When there is suspicion of money laundering or terrorist financing.

5.2. Personal Profile Construction and Identification Principles

Client profiles must include:

Full legal name and aliases
Date and place of birth
Residential and business address
Nationality and identification number
Contact information (email, telephone)

Verification must be based on independent and reliable documents such as passports, national ID cards, or driver’s licenses. Utility bills or bank statements (not older than 6 months) may be used to verify the client’s address. All records must be securely retained and regularly updated.

5.3. Simplified Due Diligence Applies to clients deemed low risk.

Measures include:

Confirming client identity
Identifying ultimate beneficial owners
Assessing transaction purpose and legitimacy
Monitoring for deviations from the expected activity

5.4. Enhanced Due Diligence Applied to high-risk clients.

Measures include:

Obtaining additional identifying documents and background checks
Verifying the source of funds and wealth
Enhanced monitoring of transactions
Additional senior management approval for onboarding

5.5. Politically Exposed Persons (PEPs)

For clients identified as PEPs:

Enhanced due diligence must be performed
The CO must obtain senior management approval to onboard or continue a business relationship
The client’s source of funds and wealth must be verified
Annual reviews must be performed and documented

5.6. High-Risk and Non-Compliant Countries

Clients from countries identified as high-risk for AML/CTF purposes must undergo enhanced scrutiny. The Company assesses FATF compliance, Transparency International rankings, and other indicators of systemic weakness.

5.7. Special Cases

The Company does not onboard residents of the Netherlands Antilles.
Introduced clients must undergo the same due diligence procedures.
Additional verification may be requested where inconsistencies or high-risk indicators are present.

6. On-going Monitoring Process

Following client onboarding, the Company must continuously monitor account activity to ensure consistency with the client's profile and detect any irregular behavior that may indicate money laundering or terrorist financing.

Monitoring Responsibilities The Compliance Officer (CO) is responsible for designing, implementing, and updating monitoring procedures. The CO also oversees the frequency and scope of monitoring activities based on risk classification.

Frequency of Reviews

High-Risk Clients: Reviewed annually
Medium-Risk Clients: Reviewed every two years
Low-Risk Clients: Reviewed every three years

Key Monitoring Activities

Verifying that client activity aligns with the expected business profile
Receiving regular analysis from internal departments (e.g., Back Office) on unusual or suspicious transactions
Recording the results of investigations in the client's file
Ensuring up-to-date and relevant due diligence documentation
Daily monitoring of incoming and outgoing funds

Data Collection and Verification To resolve any suspicions, the Company may request the following:

Government-issued photo ID (passport, national ID, driver's license)
Proof of address (utility bill or bank statement, dated within the past 3 months)
A selfie with an identification document
Any other Know Your Customer (KYC) documents deemed necessary

Documents must be submitted in high-resolution color format, not scanned, and must be entirely visible.

IT Systems The Company employs proportionate and secure information systems to support ongoing transaction monitoring, risk alerts, and data analysis.

7. Recognition and Reporting of Suspicios Activities

The Company must remain vigilant to identify suspicious activities that may relate to money laundering or terrorist financing. Employees must report suspicions to the Compliance Officer (CO) immediately and in writing.

Identifying Suspicious Activity Suspicious transactions may include, but are not limited to:

Unusual or inconsistent transaction patterns
Transactions with no apparent economic or lawful purpose
Reluctance to provide required documentation
Transactions involving third parties without clear justification
Transactions involving countries with weak AML/CFT regimes

Employees are expected to know their clients well enough to detect deviations from normal behavior or expected activity.

Internal Reporting Procedure

Employees submit concerns via an internal written report to the CO
The CO evaluates each report and determines whether the suspicion is justified
If justified, the CO prepares a formal submission to the Financial Intelligence Unit (FIU/MOT)
If the suspicion is not confirmed, the CO records the rationale in the Internal Evaluation Report

Obligations Upon Reporting

No further inquiries should be made to the client once suspicion has been raised
Clients must not be informed about the suspicion or the potential reporting to authorities
All records related to suspicious activity must be retained securely and confidentially

Required Information for Reporting to FIU/MOT In case of formal reporting, the following must be provided:

Identities of the client, beneficial owner(s), and authorized account users
Origin and destination of funds
Type and method of transaction
Any supporting documentation and communication

The CO ensures that all required information is complete, accurate, and promptly shared with the authorities in accordance with legal obligations.

8. Record-keeping

The Company maintains comprehensive records to comply with AML/CTF regulations and ensure transparency in all transactions and client relationships.

8.1. Retention Period

All documents and data are retained for at least five (5) years after:

The execution of a transaction
The termination of a business relationship

If the documents are relevant to an ongoing investigation, they are retained until the Financial Intelligence Unit (FIU/MOT) confirms the case is closed.

8.2. Types of Records Maintained

Customer identification and verification documents (KYC)
Client screening results (e.g., PEP and sanctions checks)
Transaction records (deposits, withdrawals, transfers)
Internal and external reports of suspicious activities
Internal evaluations regarding suspicious transactions
AML/CTF training logs and attendance records

8.3. Format and Accessibility

Documents may be retained electronically provided they are readily accessible and retrievable
Original or certified copies of key documents (e.g., IDs, proof of address) must be maintained in physical form where required
The Company ensures secure storage with restricted access

8.4. Staff Awareness and Compliance

All personal data is processed in line with the Company’s Privacy and Data Management Policy
Staff must be familiar with record retention practices and the importance of secure handling of client data