Anti Money Laundering

The purposes of this Policy.

When opening the (Website) casino, we, Briantie Limited (Company), understood, that the only way of doing this business is full compliance with the applicable legislation and best practices of its implementation. That is why we created this Anti-Money Laundering and Counter-Terrorist Financing Policy (Policy). The basis of this Policy was: a) FATF Recommendations; b) Risk-based approach guidance for the casinos issued by FATF; c) Directive 2015/849 of the European Union and Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and its implementation into the domestic legislation - The Prevention and Suppression of Money Laundering Activities Amending Law 13(Ι) of 2018 of the Republic of Cyprus; d) Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies.

Methods of implementation of this Policy.

This Policy is implemented in several approaches:

(a) Implementation of the KYC (know-your-customer) approach.

(b) Implementation of risk categories.

(c) Implementation of the measures the Company performs in order to monitor transactions and behaviour of Website users.

Know-your-customer (verification).

The Company applies the KYC approach (know-your-customer) by using a verification. The Company applies verification in the following circumstances:

a) The total amount of the transactions, made through the Company by a user, reaches or exceeds $1,000

b) In the process of the risk assessment is determined, that a user falls within one or more risk categories (see risk-based approach);

c) The behaviour of the user contains one or more factors, that gives the grounds to suspect a user in the usage of the Website in violation of the Rules of the Website (including Terms and Conditions, Privacy Policy and other related);

d) In other cases, when the Staff of the Company considers verification as a necessary measure;

e) When there are doubts about the veracity or adequacy of previously obtained user`s information.

Application of the standard verification. When applying a verification, the Company shall ask a user to submit the following documents or information:

- A copy or a photo of the identification document of the user;

- A photo of the payment card, used or intended to be used in making transactions on the Website. It is important, that the name of the cardholder must be the same that the name of the user, that passes a verification. CVV code, payment card number (except for first 6 and last 4 digits) may be hidden or covered. The cardholder`s name must not be hidden or covered in any manner.

- A photo of the user, bearing the documents that were required to pass the verification process.

- In some situations - user`s address confirmation. It may be utility bill, telephone bill or other documents, which, due to the local legislation, shall be deemed to be enough to confirm the address of the user.

- In some situations - bank statement, the letter from the duty station or place of employment, tax bill.

- Photo of the user, holding a list of paper with hand written text: the e-mail of the user, used when registering an account, the date of the photo request and the confirmation code.

- Other documents or information, that may be required by the situation.

- In some cases, the Company may ask a user to connect with the Website`s Support Team via the call (including the video call).

Additional Verification.

The Company may request the user to provide additional documents or information if the following applies:

- The user falls within the definition of the Politically Exposed Person (PEP). Politically exposed person means a natural person who is or who has been entrusted with prominent public functions and includes the following: (a) heads of State, heads of government, ministers and deputy or assistant ministers; (b) members of parliament or of similar legislative bodies; (c) members of the governing bodies of political parties; (d) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances; (e) members of courts of auditors or of the boards of central banks; (f) ambassadors, chargés d'affaires and high-ranking officers in the armed forces; (g) members of the administrative, management or supervisory bodies of State-owned enterprises; (h) directors, deputy directors and members of the board or equivalent function of an international organisation.

- If the Country of the residence of the user is defined as "Third country with the strategic deficiencies" by the European Commission or is defined as "High-risk" jurisdiction by FATF.

- In other cases, when this kind of verification may be required by the legislation, licensing authority, governmental body, financial institution etc.

In case of the additional verification, in addition to the documents requested under the standard verification, the Company shall require a user to submit the document(s) or data on the source of user`s income in accordance with a country’s legal and regulatory requirements. Additionally, in case of the additional verification, the final approval on the verification shall be done by senior management of the Company.

The Company reserves the right to collect additional identification data of the user for the purposes of this Policy. Additionally, in cases when a) a user refuses to pass verification; and/or b) the Company has ample grounds to suppose, that a user uses the Company for illegal purposes, and the user does not provide evidence to the contrary, the Company may a) inform proper government authorities on this case; and/or b) freeze all the funds of the user pending the investigation and/or until the user perform its obligations under the Policy or applicable legislation.

Record keeping period.

The Company shall keep a record of the verification data of the users of the Website, alongside with the transaction data (the history of the transactions and their supporting evidence) in an easily accessible form for a period of 5 (five) years. To find out more about the storage of the personal data of the users of the Website, please, follow Privacy Policy.

Risk-based approach.

The Company implements a risk-based approach, proposed by FATF in order to assess each user of the Website in the Frame of this Policy.

These factors are:

Country/Geographic risk. The Company checks the Country of the user`s residence by the following criteria (including, but not limited to):

- Whether the country of user`s residence is defined as "high-risk third country with the strategic deficiencies" by the European Commission or is Marked as "High-risk" jurisdiction by FATF.

Customer Risk. The Company checks the customer (user) of the Website by the following criteria (including, but not limited to):

- Whether the user is the Politically Exposed Person;

- Whether the user is wanted by the law enforcement agencies or whether or not a user is under the sanctions of the European Union, United States of America or the United Nations Organization.

- Whether the behaviour of the user is suspicious (including suspicious depositing activity, usage of several devices to authorize on the Website in a short time-frame, usage of the user`s device by other Webiste users, usage of one IP address by several users).

Transaction risk. The Company checks the spenders of the user on whether the spenders of the user are high and/or disproportionate. The Company also applies additional measures if the transaction of the user is suspicious.

Transactions monitoring (withdrawal and deposits).

All the transactions of users on withdrawal and deposits are applicable with the following conditions:

• In case of a banking transaction or transaction from the banking card, the name of the account/card holder shall be the same, that was specified when registering an account on the Website.

• In case if a deposit is made from the payment instrument, withdrawal of funds to which is unavailable, the withdrawal shall be made to the user`s banking account, or to another payment instrument, if it is possible to reliably ascertain that this payment instrument really belongs to the user in question.

• The Company does not accept payments from the anonymous payment instruments (cryptocurrencies, anonymous wallets etc.).

• The Company does not withdraw funds, that were deposited by the user, to the payments instrument of another user.

Prompt response to suspicious behaviour of the user.

The Company constantly monitor all the transaction and activity of the users of the Website with the aim of preventing the following methods, that are widely used for money laundering or terrorist financing activity:

• Placement.

On this stage, the funds are converted into other financial instruments like checks, banking accounts, money transfers, or used to buy expensive items, which can be subsequently resold. The funds can be subsequently invested in banks and other non-banking institutions (for example, money exchange institutions). To avoid any suspects from the Company`s side, an entity, engaged in money laundering, may conduct several placements instead of placing all the sum in one operation. This method is called "smurfing" or "structuring".

• Layering.

The funds are transferred or moved to other accounts or other financial instruments. This procedure is made to conceal the funds` origin and prevent the identification of the person, that conducts several financial operations. The movement of funds and change their form complicates the process of the funds monitoring.

• Integration.

The funds are returning into the financial turnover under the pretence of lawfully obtained funds with the final purpose of subsequent integration in the financial system.

All operations on funds depositing are to be checked on so-called "fitting of cards" (usage of several cards through different payment agents, proposed by the Company, obtaining a specific error code when making a payment, usage of cards, issued by different emitters, that are located in different regions), usage a different payment instrument within a short term (cards, electronic wallets, banking transactions), opposition or unwillingness of the user of verification of any payment instrument, mismatch of the geographic location of user`s key elements (citizenship/residency, mobile carrier provider, IP address geolocation, BIN number of the card etc.), principal opposition to any phone or video call, non-provision by user of his/her photo of him/her with the identification document in hands (upon request), matching of the user`s device ID (telephone, computer, tablet) with the device ID of another account in our system. In case of this activity, the Company may freeze the account of the User pending full verification (see “verification" section). If user disagree to verification or if the Company`s assumptions on money laundering or terrorist financing are confirmed, the Company may direct this issue to the relevant authorities.

Training of the staff on current AML procedures.

The staff of the financial department, that is responsible on withdrawal and depositing transactions of the users, together with the compliance department, that is responsible on verification of the identification documents, are constantly examining the legislation and applicable practices of the international organizations for any changes, and constantly examining the business environment and practices of our partners and other organizations, that are engaged in combating money laundering. The Company periodically conducts training courses and revisions of the internal rules of procedures, having regard the possible changes in the FATF recommendations and "Big Four" practices. Every six month, the Company conduct the attestation of the staff with the purpose to check the knowledge and competencies, that are necessary to effectively perform the functions on the matters, that relates CTF/AML/KYC procedures and applicable practices, and, additionally, with the purpose to check the knowledge current legislation in the field.

Changes and Amendments.

These Policy is subject to change without notice. A current and complete edition of this Policy can be found in the Website. If you do not agree to the changes, that come into the force with the revised version, you should stop using the Website. Please feel free to contact the Support Team with questions or concerns.

DATE: March 15, 2023

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