Customer Due Diligence (KYC)

Upon registration, the player must be identified. The customer must provide the following information:

1. name and surname;

2. permanent residential address;

3. date of birth;

4. an e-mail address or other means of contacting the player by remote means.

Players who are politically exposed persons cannot be registered without approval of senior management. They also apply: adequate measures to establish the source of wealth and source of funds and enhanced ongoing monitoring.

The information provided by the player must be verified in the event of:

● The total amount of deposits has reached or exceeded 2000 EUR / equivalent in other currencies;

● The total amount of payments has reached or exceeded 2000 EUR / equivalent in other currencies;

● The player, his activity raises suspicion of money laundering / fraud / financing of terrorism;

● The player is a politically exposed person (PEP)

The verification procedure must include:

1) ID (a government-issued document containing photographic evidence of the customer’s identity (e.g. passport, identity card, driving licence, etc.)

2) Proof of address (should not be more than six months old)

a. a recent statement or reference letter issued by a recognised credit institution;

b. a recent utility bill for a service installed and provided at a residential property;

c. correspondence from a central or local government authority, department or agency;

d. a record of a visit to the address by the licensee;

e. an official conduct certificate;

f. any other government-issued document not mentioned above; or the mailing of correspondence via registered mail or by means of a

g. courier which allows the subject person to obtain documentary evidence that the correspondence was effectively delivered at the residential address provided by the customer and signed for by the same.

3 Proof of payment

ENHANCED DUE DILIGENCE

If a player from high-risk third countries is a PEP (search on social networks) or is suspicious, then an EDD must be performed. In addition, an EDD must be performed in cases of suspected ML / FT.

The following documents may be requested:

a) Source of funds (confirmation of the origin of funds on a specific payment method)

b) Phone call verifying customer details and information (the call must be fully recorded, the player must be warned at the beginning of the call that the call will be recorded) conducting enhanced monitoring of the business relationship, potentially by increasing the number and timing of controls applied, and identifying patterns of transactions that warrant additional scrutiny.

c) Source of wealth (Annex A)

EDD is considered passed and successful when at least 2 of 3 stages (a, b, c) have been completed.

Annex A