Policies

1. Introduction

AJM Gaming B.V. (“Goated” or the “Company”) is a Curaçao company operating the online casino www.goated.com under gaming license No. 1668/JAZ issued by Curaçao eGaming.

This Anti-Money Laundering Policy ("AML Policy") outlines Goated's strategy for preventing and combating money laundering and terrorist financing risks. This policy considers all current obligations under Curaçao law for Goated and guidance issued by the Curaçao Gaming Control Board, relating to AML and Countering the Financing of Terrorism ("CFT") obligations and has followed best practice guidance for the gaming sector.

2. Objective and Policy Statement

Goated prohibits the use of its products and services for any illegal activity, including money laundering, terrorist financing and sanctions violations. At Goated, we are committed to following global best practices including:

• Developing a written policy and controls that is reasonably designed for AML and CFT
• Reviewing and updating the policy and controls as required
• Providing appropriate education and training on this topic to all relevant company personnel
• Appointing a Compliance Officer to oversee the implementation of said policy and controls

The objective of this AML policy is to define the procedures and controls put in place by Goated to address AML and CFT.

3. Responsibilities

a. Chief Compliance Officer

Goated has a designated Chief Compliance Officer ("CCO"), responsible for overseeing the implementation of the AML policy. The CCO's responsibilities include developing AML initiatives, working with other stakeholders to revise the AML policy as required, assessing new regulatory requirements and investigating potentially suspicious or unusual activity.

b. Employee Responsibilities

Employees at Goated are required to follow the AJM Gaming B.V. policies for customer due diligence and be aware of the need to prevent money laundering and financing of terrorism. Employees must report to the CCO any knowledge or suspicion of criminal conduct for any transactions on the platform. Failure to do so may result in disciplinary action.

As the business grows and the number of employees increases, Goated will continue to take the relevant steps to train its employees to identify and report suspicious activity.

4. Know Your Customer (KYC)

Goated has implemented this policy in order to proportionally manage and mitigate the money laundering and terrorist financing risks faced by Goated. Goated applies appropriate know-your-customer ("KYC") and ongoing monitoring measures as required by law.

a. KYC Measures

Goated incorporates a risk based Customer Due Diligence (CDD) process to develop a customer risk profile. This involves collecting user information at the onboarding stage and monitoring user activity as per below:

• Collecting Customer Information - Goated collects details of each user to form a reasonable belief that it knows the identity of its users. These details may include the user's wallet address, name, date of birth, address, country, which all form the KYC information. A third-party service provider may support Goated to determine the validity of the information provided by its users.
• Geo-blocking for Prohibited or Sanctioned Jurisdictions - Relevant users are notified while onboarding that Goated does not offer services in jurisdictions where such services are not permitted to be offered and requires customers to declare that they are not located in a prohibited jurisdiction. Goated has implemented IP address-based geo-blocking for those jurisdictions. This also extends to jurisdictions subject to United States, European Union, or other global sanctions or watchlists, including Iran, Cuba, North Korea, Syria and the Crimean region of Ukraine, and users have to declare that they are not personally subject to international sanctions.
• Screening for Sanctioned Parties - Goated may screen a user's wallet address against applicable sanctions databases, through third-party blockchain forensics vendors such as Chainalysis.

b. Transactions Monitoring

Goated performs ongoing monitoring of its users in order to detect suspicious behaviour potentially indicative of illicit activity.

• Transaction Monitoring for Prohibited or Sanctioned Jurisdictions & Parties - Goated employs a combination of manual and automated transaction monitoring processes to identify "red flag" behaviour. When such behaviour is detected, Goated may refuse to process any withdrawal attempts or request additional information from the customer. Customers can provide additional information to contest any suspensions as part of Goated's ongoing transaction monitoring and due diligence procedures.
• Transaction Monitoring for Sanctioned Parties - Goated will periodically screen user wallet addresses against applicable sanctions databases.
• Identification of Unusual Activity - Goated will monitor user activity for unusual size, volume, transactions or behaviour, considering any other relevant risk factors.
• Anti-Mixing Measures - Goated does not allow the use of anonymity-enhancing technologies such as mixers, tumblers or certain coins and tokens. Users who choose to connect their wallet to the account can also only connect a singular wallet to the account as an anti-mixing measure. Goated may also take steps to further address suspicious deposit or withdrawal patterns on a case-by-case basis, depending on the perceived level of risk.
• Chainalysis Review - Every crypto deposit and withdrawal will be analysed using Chainalysis to detect signs of fraud or suspicious activity. If potential illicit behaviour is flagged, the user's account will be suspended and reviewed. High-risk accounts may be required to provide adequate proof of wealth. Goated reserves the right to block withdrawals to certain "high-risk" addresses, based on risk assessments conducted in partnership with Chainalysis.
• Withdrawal Threshold KYC - Furthermore, any account's withdrawal function may be suspended once it reaches a withdrawal threshold dependent on the account's risk profile, assessed according to Goated's sole discretion, until adequate due diligence has been carried out.
• Multiple Account Usage Prevention - Goated prohibits users from creating multiple accounts by ensuring that the same email address cannot be used more than once. Additionally, if identical KYC details are detected across accounts, those accounts will be banned.
• Service Provider Management - Goated will periodically evaluate the performance of any third-party service providers to determine if additional services are required, if the service provider is failing to meet its contractual obligations, or if other corrective measures are necessary to ensure compliance with this AML Policy. Goated may request relevant information from any third-party service provider as part of this review process.
• Services Innovation - Goated will continuously evaluate non-documentary compliance mechanisms to determine their feasibility for the Goated platform. Goated may conduct limited trials with these vendors to assess their effectiveness. Blockchain-native compliance tools may include audits, on-chain KYC providers and other tools tailored to the technical features of blockchain platforms.

c. Enhanced Due Diligence

On Goated, if a red flag is triggered, the relevant user's account will be suspended and Goated will perform enhanced due diligence ("EDD") which may include and is not limited to, obtaining user information such as:

• Full legal name;
• Date of birth;
• Country of citizenship;
• Permanent address;
• Identification documents (e.g. a passport); and
• Source of funds

Goated may use third-party providers to verify any of this information.

Goated also prohibits and blocks or suspends users who:

• Do not provide the identification information requested;
• Provide fake identification documents;
• Are from prohibited or sanctioned jurisdictions;
• Are subject to US, European Union or other global sanctions or watchlists; or
• Are addicted to gambling

Goated reserves the right to block and suspend any users for any other reason at its sole discretion.

5. Reporting

If a user is identified to be on a sanctions list or linked to criminal activities, Goated will make an appropriate report to the relevant authority.