Anti-Money Laundering (AML) Program and Know Your Client (KYC) Procedures

Policy Statement:

Cetus Technology N.V. (hereinafter referred to as the "Company") and its employees are fully committed to implementing measures to prevent Money Laundering and Combat Terrorism Financing. We are dedicated to our social responsibility in preventing our systems from being used as a tool for criminal activities. We will strive to stay updated with developments in prevention measures to protect the organization, its operations, and reputation. Our policies and procedures have been established and continue to be updated to comply with the laws relevant to our operations.

Purpose:

The purpose of this policy is to ensure that the Company adheres to the obligations and requirements outlined by Curacao legislation, regulations, and rules concerning the prevention, identification, and reporting of money laundering or terrorist financing. This includes ensuring that we have adequate systems and controls in place to mitigate risks posed to the Company and its clients, including the verification of, and due diligence checks on customers and their transactions. This policy provides guidance for our employees to ensure that their knowledge and understanding of financial crime regulations are exemplary and outlines our expectations and their responsibilities under the regulations and our objectives.

The Company will do everything possible to protect its employees and clients from exposure to money laundering and terrorist financing and ensure a company-wide risk-based approach for the prevention of financial crime. Any actual or suspected acts of money laundering will be reported to the Curacao Financial Intelligence Unit (FIU) or other relevant governing authorities.

Relevant Acts and Regulations:

This Policy is designed to be compliant with the following Curacao Ordinances and Decrees:

The National Ordinance on the amendment of the Penal Code (penalization of terrorism, terrorist financing, and money laundering) (N.G. 2008, no. 46).

The National Ordinance on the Reporting of Unusual Transactions (N.G. 1996, no. 21), as lastly amended by N.G. 2009, no 65 (NORUT) (N.G. 2010, no 41).

The National Ordinance on Identification of Clients when rendering Services (N.G. 1996, no. 23), as lastly amended by N.G. 2009, no 66 (NOIS) (N.G. 2010 no. 40).

The National Decree containing general measures on the execution of articles 22a, paragraph 2, and 22b, paragraph 2, of the National Ordinance on the Reporting of Unusual Transactions (National Decree penalties and administrative fines for reporters of unusual transactions (N.G. 2010 no. 70)).

Ministerial Decree with general operation of May 21, 2010, laying down the indicators, as mentioned in article 10 of the National Ordinance on the Reporting of Unusual Transactions (Decree Indicators Unusual Transactions) (N.G. 2010, no. 27).

Supervisory Authority

Organizations subject to Money Laundering Regulations must be monitored by a supervisory authority. Curaçao participates in the Financial Action Task Force (FATF) as part of the Dutch Kingdom and has an established Financial Intelligence Unit (FIU) to which the Company reports unusual transactions. The Company's Supervisory Gaming Authority is the Curacao Gaming Control Board.

Objectives

To prevent financial crime and money laundering within our organization, the Company aims to meet the following objectives:

* Establish and maintain policies, controls, and procedures to mitigate and effectively manage the risks of money laundering and terrorist financing.

* Report and detect suspected money laundering to FIU Curacao.

* Train all staff to remain vigilant for the signs of money laundering.

* Follow due diligence and client identification procedures by all staff.

* Maintain controls and procedures to detect and report any suspicious activity.

* Conduct frequent risk assessments of all AML and terrorist financing controls and systems.

* Review and maintain customer verification and due diligence procedures.

* Implement procedures to enable the reporting of suspicions of money laundering.

* Abide by Acts, legislation, regulations, and supervisory authority guidance for preventing financial crime, terrorist financing, and money laundering.

Due Diligence

The Company adheres to and complies with the principles of KYC, which aim to prevent financial crime and money laundering through client identification and due diligence. We take a risk-based approach and perform due diligence checks and ongoing monitoring of all clients, customers, and transactions.

We will apply due diligence checks as part of our customer registration procedures, verifying age, name, residential address, nationality, PEP, and a sanctions check. At any time that a customer's risk profile changes based upon any number of 'red flags', we will conduct enhanced due diligence.

As per the money laundering regulations, we utilize 3 tiers of due diligence checks, dependent on the risk, transactions, and customer type:

* SDD – Simplified Due Diligence is used in instances of extremely low-risk transactions that do not meet the required thresholds.

* CDD - Customer Due Diligence is the standard for due diligence checks, used in most cases for verification and identification.

* EDD - Enhanced Due Diligence is used for high-risk customers, large transactions, or special cases.

Player Identification Program

1- The Company will take reasonable steps to establish the identity of any person for whom it proposes to provide its services (hereinafter "Players"). The registration process for Players, as outlined in the General Terms and Conditions of the Company, includes the due diligence process that must be carried out before opening a user account.

2- The Company will maintain a secure online list of all registered Players at all times, and information and documents will be retained in accordance with applicable data protection obligations.

3- The Company will collect certain minimum Player identification information from each Player who opens an account. The Company will not accept the opening of anonymous accounts or accounts in fictitious names where the true beneficial owner is unknown. The required information will include at least:

a. Player's date of birth (showing that the player is over eighteen (18) years of age);

b. Player's first and last name;

c. Player's place of residence;

d. Player's credit card or banking information;

e. Player's valid email address; and

f. Player's username and password.

4- If there is considered to be risk or uncertainty about the information provided or prior to any payment in excess of EUR 2,000 per occasion, or when payments to the account exceed EUR 2,000, the Company will request documents from the Player to verify the identity information received. These documents shall include, to the extent permitted under the relevant data protection regulations:

a. A copy of a valid identity card or passport;

b. Proof of address;

5- The Company may supplement the use of documentary evidence by employing other methods, which may include:a. Independently verifying the Player's identity through comparing the information provided by the Player with information obtained from a reporting agency, public database, or other sources;b. Checking references with financial institutions; orc. Obtaining a financial statement.

6- The Company will inform relevant Players that it may seek identification information to verify their identity and will compare Player identification information with government or internationally-provided lists of suspected terrorists or sanction lists, for example, through the European Union or FATF.

7- If a potential or existing Player refuses to provide the requested information described above, or appears to have intentionally provided misleading information, the Company will not open a new account and, after considering the risks involved, may consider closing any existing account. In either case, the AML Compliance Person will be notified to determine whether a report should be sent to the relevant authorities.

8- If a Player appears on a list of suspected terrorists or otherwise sanctioned individuals, the Company will take appropriate steps to immediately freeze or close the Player's account.

9- If any material personal information of a Player changes, verification documents will be requested.

10- When an employee of the Company detects any activity that may be suspicious, they will notify the AML Compliance Person. The AML Compliance Person will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account, and/or filing a report.

11- The Company will not accept cash or non-electronic payments from Players. Funds may be received from Players only through any of the following methods: credit cards, debit cards, electronic transfer, wire transfer, cheques, and any other method approved by the respective regulators.

12- The Company will transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.

13- Transfers of funds between Players' accounts are prohibited.

14- Records relating to financial transactions must be maintained in accordance with data protection and retention requirements in the applicable jurisdiction of Curaçao.

Real-Time Transactions Monitoring

The Company and its staff continuously oversee and monitor ongoing transactions to and from customers to identify any malicious or fraudulent activity. We work closely with our payment gateway providers and third-party services to flag suspicious transactions, and due diligence will be applied according to our AML/KYC policy.

Records Management

All documents, accounts, and transactions associated with clients/customers are retained for a minimum of 5 calendar years from the time of the occasional transaction or activity.

Details of the following records are retained:

Identification and verification records

Due diligence checks

Transaction lists

Conversational history

Reporting

We are obligated to report any unusual or suspicious transactions in accordance with the National Ordinance and as a registered body of the Department of the Financial Intelligence Unit (FIU).

A customer identified as being on a sanctions list, linked to Money Laundering, the Financing of Terrorism, or other criminal activity, may warrant the submission of a formal suspicious activity report to law enforcement.

All documents related to money laundering reporting, business transactions, client identification, and customer due diligence are retained for a minimum of 5 years.

The appointed person will ensure that the following minimums are met concerning the information disclosed in any reports:

* Full details of the people involved.

* Full details of the nature of their/your involvement.

* The types of money laundering activity involved.

* The dates of such activities.

* Whether the transactions have occurred, are ongoing, or are imminent.

* Where they took place.

* How they were undertaken.

* The approximate and/or exact amount/s of money/assets involved.

* What has given rise to the suspicion.

AML Policy Review

The AML Manual is reviewed periodically and, as necessary, updated to reflect changes in legislation, national and international findings, the structure of Cetus Technology N.V., our customers, and the services offered.

AML Risk Factors

An AML risk assessment overview will be maintained to allocate and track the components of the separate risk classifications. Cetus Technology N.V. categorizes overall AML risk into:

Customer risk

Product risk

Interface risk

Geographical risk