ANTI-MONEY LAUNDERING
POLICY AND PROCEDURES

1. Introduction

1.1 Money laundering
Money laundering is the process of creating the appearance of funds obtained from criminal activity, such as drug trafficking or terrorist activity being originated from a legitimate source. Criminals attempt to launder money by disguising the source and/or changing the form of the funds, or moving then to a place where they are less likely to attract attention.

1.2 Anti-Money Laundering
Anti-money laundering is a financial/legal term used to describe the legal controls that require financial institutions and other regulated entities to prevent, detect and report ML activities.
An effective AML program requires a jurisdiction to:

• To have criminalized money laundering
• To have given the relevant regulators and police the powers and tools to investigate it
• To have its financial institutions identify their customers, establish risk-based controls, keep records and report suspicious activities
• To be able to share information with other jurisdictions as appropriate

2. Regulation
Employees working in the remote gaming industry are required to make report in respect of information that comes to them in the course of their business:

• When they know
• When they suspect
• When they have reasonable grounds for knowing or suspecting that a person is engaged in money laundering or terrorist financing, including criminal spending.

These obligations are collectively referred to as grounds for knowledge or suspicion. What the authorities are looking for is that we are able to demonstrate with supporting evidence that a risk assessment is and has been undertaken prior to entering into business relationships with customers and that adequate customer due diligence is conducted in order to ensure that customers transactions are consistent with the level of risk presented.
World Star Betting must be able to demonstrate that the extent of the ongoing monitoring undertaken is conducted on a risk-sensitive basis and that all the records are retained by us to reflect this, with risk profiles being properly maintained.
In this document, we have identified additional measures that are being applied in order to carry out risk monitoring and the need of where we would require a declaration of the source of funds from the customers in situations which present a high risk and potentially money laundering.

2.1 Specific Regulations
World Star Betting is committed to ensuring that compliance is embedded in all aspects of our business which is licensed by the gaming authorities in each country we are licensed in.

3. Crime & Disorder and AML policy
AML policy is based on principles and practices:

• We will develop systems and controls that ae appropriate for our businesses and comply with legal and regulatory requirements.
• We will assess the AML risk inherent in our business at least annually: we will then adopt a risk- based approach that is flexible, effective, proportionate and cost effective.
• We will have full commitment for this from, and responsibility resting with, senior management.
• We will regularly assess the adequacy of our systems and controls.
• We will maintain where necessary, records of transactions that meet the needs of law enforcement investigations tackling money laundering and terrorist financing.
• We will provide initial ongoing training f or all relevant employees
• We will support the nominated officer with resources and authority to operate objectively and independently.

4. Risk Management
We have policies and procedures in relation to risk assessment and management as required under the Anti-money Laundering Act. The risk-based approached involves a number of discrete steps in assessing the most proportionate way to manage and mitigate the money laundering and terrorist financing risks we face:

• Identify the money laundering and terrorist financing risks that are relevant to us
• Design and implement policies and procedures to manage and mitigate these assessed risks
• Monitor and improve the effective operations of these controls
• Record what has to be done and why

This risk-based approach focuses on the effort where it is needed and will have most impact. It has the full commitment and support of our senior management and the active co-operation of all employees. We have conducted an assessment of our business risk exposure to money laundering, which considers the threat and its impact

5. Suspicious Activity
Suspicious activity in this case is being referred to as suspicious transaction, extreme player profiles, when deposits are not matching up amongst other elements. Other concrete examples of how we identify players who require our team to undertake a risk monitoring approach of our customers and when to specifically carry out enhanced due diligence checks on the Player Profiles can be further required.

• Passport or ID card
• Utility bill
• Bank statement
• Other proof of identity

The enhanced due diligence checks are subject to players, profile and the amount of risk they pose to us. Only when we determine some of the above points or a combination of a few, will we flag the customer/customers in question and conduct risk monitoring. This will include checks of where the customer lives and checks to see whether the value of the house is logical compared to the customer spending.

5.1 Suspicious Activity Reports SARs
Within that framework, suspicious activity (SARs) are an imposed requirement. World Star Betting will ensure that any employee reports to the risk team where they have grounds for knowledge or suspicion that a person or customer is engaged in ML or terrorist financing. Any employee failing to do so is open to criminal prosecution.
Escalations of SARs should be done in a confidential, discreet manner in handwritten form and not via email so as to ensure maximum anonymity.
An employee must not under any circumstances disclose or discuss any AML concern with the person or persons subject to investigation or any other person for that matter. Disclosure (also known as tipping off) is strictly prohibited and carries with it very serious legal penalties.
Furthermore, in order to keep ourselves protected as much as possible, no remark should ever be left on an account that would give any indication that ML is suspected, a player being entitled at any point in time to request the full notes/remarks on their account.

5.2 Working Procedure
World Star Betting will review player spending and game play to check for suspicious activity. Before any withdrawal is processed, the following procedures will be carried out.

• The customers deposit history is reviewed to confirm that no suspicious payment has been made to the customer's account. The frequency of deposits and the sum of deposits are reviewed to ensure they are within normal range for the customers based on his depositing history and the general depositing range throughout our network.
• The customer's turnover is reviewed to ensure that they have played on our platform and are not using World Star Betting as a method to move money.
• When possible, funds must always be refunded back to the original payment method used by the player to make a deposit.

5.3 Withdrawal Procedure
When reviewing a customer's account prior to withdrawal, the agent must answer the following questions in the AML segment in the risk entry

• Did the player wager?
• Does the payment method belong to the player and has the player used it to deposit?
• Are the customers' transactions in line with expectations for the player?

5.4 Escalation Process
Following the AML policies in place and the escalation of any suspicious activity as previously described, are crucial to the company as they protect it from financial losses and ensure that it remains complaint within the different jurisdictions which govern it.
Any activity which appears suspicious, even only slightly, has to be escalated. Not escalating a suspicion of money laundering can lead to criminal prosecution.

6. Employees

6.1 Senior Management
Senior management is fully committed to and responsible for the implementation of this policy. Senior management will be made aware of their individual personal liability for consenting to, or conniving in, the commission of offences under the regulations, or where such offence is attributable to any neglect on his part.

6.2 Money Laundering Reporting Officer (MLRO)
A designated money laundering reporting officer will take responsibility for SARs in respect of the prevention and detect ion of money laundering (AML) and counter terrorist financing and our obligations under the Proceeds of Crime Act.
The nominated (MLRO) will have responsibility for:

• Making reports to senior management on anti-laundering (AML) and countering terrorist financing (CTF).
• Receiving disclosures from employees under the Proceeds of Crime Act.
• And if appropriate make such external reports

The MLRO has the authority to act independently in carrying out their responsibilities and has access to sufficient resources to carry out their duties.

6.3 Staff Training
All staff will receive training on their obligations in respect of money laundering reporting and are aware of the procedures in place for escalation in any suspected incidents to the MLRO. As part of this process, staff are made aware that personal disregard for the legal requirements, for example, turning a blind eye to a customer spending criminal proceeds, may result in criminal or regulatory action.

• Relevant employees will receive training on how to follow house policies and procedures for:
• Client Due Diligence (CDD), including enhanced requirements for high risk clients.
• Reporting suspicious activity to the nominated officer where necessary, seeking appropriate consent to allow participation in gaming and to conduct gaming and other business transactions.

6.4 Record Keeping
We will ensure that there is an audit trail to assist in financial investigation by a law enforcement body. Our record keeping policy and procedure covers records in the following areas.

• Details of how compliance has been monitored by the nominated officer
• Delegation of AML/CTF tasks by the nominated officer
• The nominated officer reports to senior management
• Information not acted upon by the nominated officer, with reasons why    no further action was taken
• Customer identification and verification information
• Supporting records in respect of business relationships or occasional transactions
• Employee training records
• Internal and external SARs
• Contact between the nominated officer and the law enforcement or Financial Intelligence Office (FIC) including records connected to appropriate consent

7. Offences
All employees will be made aware of their risk of committing the following related offences:

• Where an employee fails to comply with the obligations to make disclosures to the nominated officer to FIC, as soon as practicable after the information giving rise to the knowledge or suspicion comes to that person, they are open to criminal prosecution
• They may also commit an offence under the proceeds of  crime act if they fail to disclose information that a Suspicious Activity Report (SAR) has been submitted that is likely to prejudice any investigation or disclose information that an investigation into allegations that an offence under the Proceeds of Crime Act has been committed, that is likely to prejudice the investigation
• They also commit an offence if they know that an appropriate officer is acting (or proposing to act) in connection with a relevant investigation which is being or is about to be conducted and they falsify, conceal, destroy or dispose of documents which are relevant to the investigation

8. Vetting of New Employees
World Star Betting will undertake a number of vetting procedures when staff are employed. We will ensure that the employee is not a minor through proper identification and credentials of the employee through at least two independent references. We will also look to verify any further background information.

9. Protecting Our Equipment from Internal Crime and Criminal Activity
World Star Betting is very aware that a key way to combat fraud is to first identify where the company's most valuable assets are. Processes and controls have been built into the routine business of the company to minimise the chances of any of the key assets being misused.

10 Compliance and Risk Committee
We intend to establish this to review executive risk. Both the MLRO and compliance officer will be members as will another non-executive director. These will meet no less than quarterly or as required.

11. Ensuring That Companies We Deal With Are Trustworthy and Reputable
World Star Betting promotes strong principles of business and professional ethics at every level when selecting suppliers. There are a number of criteria we consider:

• Financial strength (for long term sustainability)
• Legal and regulatory compliance
• Commitment to wider corporate responsibility program
• Desire and ability to deliver quality and value

All new suppliers must go through a rigorous approval process where all information put forward by them is verified.
This information is then assessed internally to consider the risks associated with the supplier, taking into account all the above criteria. World Star Betting will ensure that all organisations we contract with understand the compliance obligations under the relevant player jurisdiction.

12. Our Responsibility Under The Proceeds of Crime Act (POCA)
World Star Betting is fully aware of the procedures and policies required by the proceeds of Crime Act and have policies in place related to this Act.
The below key principles ensure our compliance with laws and regulations.

13. Internal Record Keeping

• Records on all customer transactions- regardless of their relation to payments or plays- will be kept for at least 6 years after the relationship with the transaction.
• Records on customer details, regardless of their value state or open/blocked status, will be kept for at least 6 years after the relationship with the customer was terminated.
• Records on money laundering investigations and suspicious activity reports will be kept for 6 years after the investigation is completed.

14. Prevention of Collusion and Data Protection Compliance
World Star Betting’s terms and conditions makes it clear that cheating will not be tolerated and that customer accounts will be closed if cheating occurs.