Anti-Money Laundering Policy

1. Purpose and application

Our Anti-Money Laundering Policy is dated 20 April 2026. It explains how we approach the detection and prevention of money laundering and terrorist financing across registration, account activity and payments. The policy applies to our employees and internal divisions, with customer checks forming one part of a wider control framework.

We treat money laundering as activity that can conceal the origin, ownership, location or movement of money or other assets. Terrorist financing concerns providing or collecting funds for terrorist acts or organisations, including attempted collection or provision. Our controls also cover internal training, audits, risk indicators, record protection and communication with competent authorities.

2. Risk-based customer due diligence

Customer due diligence, or CDD, is applied using a risk-based approach. The information and depth of review can vary with the risk level assigned to a customer. We collect registration details relating to identity, address, contact information, residence and payments, and we require those details to be current and accurate. Email confirmation forms part of the registration checks.

A review is not limited to a single transaction value. We may check a customer when the relationship begins, at the first payment request, when earlier information appears unreliable, or whenever a payment or customer raises suspicion of money laundering or terrorist financing. Registration checks also include review of the IP address location for jurisdictional eligibility.

• Account opening and registration checks.
• Review at the first payment request.
• Fresh checks when existing customer information is doubted.
• Checks triggered by suspicion, regardless of transaction size.

3. Enhanced checks and financial provenance

Enhanced Due Diligence, or EDD, may be used for a payment request or before one when fraudulent payments, conduct affecting game outcomes or automatically identified suspicious payments are suspected. EDD can include source of funds and source of wealth reviews, credit checks and third-party database checks. These measures help us examine how an account is funded rather than relying only on basic identity details.

Supporting evidence can include a statement for the bank account used to deposit, images of both sides of the card used, and an identity document. Card images must leave only the first six and last four digits visible. Embossing visible on the reverse and the CVV2 code must be covered. We may also request proof of card ownership, a utility bill or a video call when further identity confirmation is required.

4. Sanctions, PEPs and jurisdiction controls

Sanctions screening is part of the compliance review required before a withdrawal. We also use risk profiles, CDD information and internal research to assess whether a customer is a politically exposed person, or PEP. These assessments sit within the same risk-based framework as other customer reviews.

Our jurisdiction provisions refer to restricted territories, the FATF blacklist and financial sanctions imposed by the EU, UN or OFAC. The AML policy and Terms list Australia among restricted locations, while the payments page presents an Australian payment table. We keep those statements separate: the table is not treated as confirmation that a person physically present in Australia may register or play.

5. Ongoing transaction monitoring

Monitoring compares account conduct and transactions with the expected purpose of a gaming account, previously collected information and the customer's usual activity. Customer records and documents may be reviewed or updated over time. This means an initial review does not prevent later questions about payments or funding.

Potential concerns include fraud, collusion, coordination with other players, unlawful activity, prohibited programs or equipment, and using deposits and withdrawals to pass money through the account. We assess concerns individually. Suspicious matters can be escalated to the Money Laundering Reporting Officer, who considers further investigation and whether disclosure to a competent authority is required.

6. Withdrawal and refund controls

A withdrawal requires successful KYC verification and completion of compliance checks, including sanctions screening. Withdrawal requests must be submitted through the website, not by telephone or email. Processing begins only after applicable due diligence requirements and verification thresholds have been met, and a request cannot exceed the available account balance.

Payouts and refunds are directed to the account used for the initial transfer. We do not accept cash deposits, and we do not pay winnings in cash. The Terms also allow a payout to be split between several deposit methods where more than one method was used, subject to the applicable payment and AML rules.

7. Duplicate accounts and account restrictions

We use account information such as names, addresses, telephone numbers and IP addresses to identify possible duplicate accounts. Access may be restricted where a duplicate is found, and KYC documents can be required before funds are withdrawn. Accounts are for natural persons acting for themselves, not companies, corporate accounts or third parties.

If requested information is not supplied, an account may be suspended while the review remains outstanding. Inability to provide required evidence can lead to closure. Where money laundering, terrorist financing or fraud is suspected, the policy permits restrictions on account access and funds as required by the applicable rules, together with notification of relevant authorities.

8. Document integrity and review responsibilities

Documents are examined separately for signs of alteration. For card reviews, the policy describes checks against a BIN database to confirm the issuing bank and compare the card's country with the address shown on a utility bill. We may use additional procedures or tools when needed to assess compliance with the AML and counter-terrorist financing controls.

Employees escalate suspected activity through internal channels rather than conducting independent investigations after referral. Reports can include customer details, the basis for suspicion and transaction information. The MLRO determines the next steps, including possible referral to an authority. Customers are not notified about a suspected money laundering investigation where doing so could disclose protected information.