(ENGLISH VERSION)

4 - Anti-Money Laundering (AML) Policies and Procedures

4.1 - Introduction

BetNacional is licensed and regulated by the Government of Curaçao, to offer remote (online)
games over the internet, under the Remote Gaming Regulations. Under the license conditions
issued by Curacao Authorities, BetNacional is required to have in place adequate measures to
prevent its systems from being used for the purposes of money laundering, terrorist financing or
any other criminal activity. BetNacional is therefore obliged to follow the provisions contained
in the legal framework namely Proceeds of Crime Act 2002 (Part 7), and The Money Laundering,
Terrorist Financing and Transfer of Funds (information on the payer) Regulation no. 692 of 26 of
June of 2017 and any guidance notes issued by the relevant Authorities.

4.2 - Objective of the Policy

BetNacional is fully committed to be constantly vigilant to prevent money laundering and combat
the financing of terrorism in order to minimize and manage risks such as the risks to its
reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent
serious crime and not to allow its systems to be abused in furtherance of these crimes. The
company will endeavor to keep itself updated with developments both at national and
international level on any initiatives to prevent money laundering and the financing of terrorism.
It commits itself to protect, at all times, the organization and its operations and safeguards its
reputation and all from the threat of money laundering, the funding of terrorist and other criminal
activities.

4.3 - Money laundering guidelines and disclosure requirements

a. The user identification is a requirement for using the services. Anonymous use of the Services
is prohibited and therefore discarded.

b. For the initial verification of the player account it is necessary to send of such documentation
- Proof of identity (RG, CNH or Passport)
- Proof of residence (water, electricity, gas or telephone bill)
- Selfie of the account holder having in hand and legibly: the identification document (the
same one that was sent separately) and a sheet with the name of the website and the date
of submission of the image.
- Submitting all of these items is mandatory for the account validation process to take
place.

c. At any time, without any reasoning required, BetNacional may request proof of your
identification, and may also request proof of your residence and bank details. Finally, BetNacional
may require a copy of such documents to be stored in the respective database.

d. If the mandatory identification required by BetNacional is not fulfilled, BetNacional has the
right to block the account and only pay the deposited funds after fulfilling the requirements for
the correct identification of the user.

e. If the user's identification does not occur within 90 days from the sending of the request
notification by BetNacional, carried out by e-mail using the last address updated by the user,
BetNacional has the right to retain any deposited amounts and , if necessary, notify the competent
authorities.

f. In order for the user to be able to request withdrawals, he must have wagered 100% of the
amount deposited in cash in his account. If the player has not placed bets that add up to the total
value, the withdrawal will be rejected.

g. This procedure complies with the international rules on money laundering, which are widely
incorporated by BetNacional.

4.4 - Obligations

- BetNacional will indicate a Money Laundering Reporting Officer (MLRO) whose

responsibilities will include the duties required by the laws regulations and guidance notes.
(Contact through the email [email protected] )

- All instances of suspected Money Laundering attempts must be reported to the MLRO, but that
suspicion must not be conveyed to the customer and further actions must await consents. The
MLRO is then responsible for liaising with, submitting Suspicious Activity Reports and seeking
consents from the responsible legal authority in the jurisdiction where the transaction was done,
when appropriate. He will also ensure that appropriate registers are kept for all related reporting.

- Take reasonable steps to establish the identity of any person for whom it is proposed to provide
its service.

- BetNacional will implement a FULL ‘Know Your Customer’ (KYC) policy. This will assist in
tackling not just Money Laundering threats but other fraud threats generally. Customers will be
advised at registration and generally on the supporting non-transactional website that Company
will utilize online verification tools and that in instances where we are not able to satisfy criteria,
ID and address verification documents will be requested.

- Keep at all times a secure online list of all registered Players.

- Retain identification and transactional documentation as defined in the laws regulations and
guidance notes.

- The business will also not have any cash element to it, mitigating risks associated with
counterfeit monies.

- Systems will be operating to record all transactions for an account. These account histories will
be subject to a program of regular and continual checks against fraud and social responsibility
indicators. Where unusual bet patterns and winning patterns are detected, these will also be cross-
referenced to call history to ensure that staff are not colluding with customers or acting illicitly.

- BetNacional will also keep a register of those customers that it identifies as high risk or
politically exposed. Those accounts will be subject to greater scrutiny and frequency of checks.

- In general, where illegal or inappropriate behavior by staff is identified, investigatory and

disciplinary procedures will follow those outlined in staff contracts as required by employment
law directives and the need to use in greater propensity, measures such as suspension when for
example transactional fraud is suspected and those activities form a standard part of an
employee’s job description.
- All transactions carried out on our site may be controlled to avoid money laundering or terrorist
financing activities. Suspicious transactions will be reported to the relevant authority, depending
on the jurisdiction governing the transaction.

- If our risk and fraud department suspects fraud, it may require the player to provide appropriate
documentation. If there is enough evidence of fraudulent behavior (eg bank repudiation, account
operated by third parties, use of forged documents, fraud of means of payment, etc.), the account
will be suspended until the situation is cleared. The suspension shall be communicated to the
relevant authority together with the respective grounds (evidence or evidence collected) within
24 hours and to the authorities responsible for criminal proceedings. Parallel to the suspension,
BetNacional may proceed to the immobilization, as a precautionary measure, of the balance of
the player account, until the decision of the competent authorities.

- Provide initial and ongoing training to all relevant staff, including, but not limited to:

• Staff personal responsibilities;

1. Procedures in respect of identifying Players;
2. Monitoring Player activity;
3. Record-keeping;
4. Reporting any unusual/suspicious transactions;
5. Unusual Betting Patterns;
6. Suspicious deposit and withdrawal patterns (size and frequency);
7. Reliability of Card Data;
8. Customer verification issues and Identity Theft;
9. Account linkage/multiple accounting;
10. High Risk Jurisdictions;
11. Client due diligence (CDD), including enhanced requirements for high risk
clients, which includes PEPs;
§ Ensure that this policy is developed and maintained in line with evolving
statutory and regulatory obligation and advice from the relevant
authorities.
§ Examine with special attention, and to the extent possible, the
background and purpose of any complex or large transactions and any
transactions which are particularly likely, by their nature, to be related to
money laundering or the funding of terrorism.
§ BetNacional may terminate Accounts with immediate effect and retain
all account funds in the event of a credible suspicion of fraudulent
activity including, but not limited to, the supply of fraudulent, forged,
altered or stolen personal data and, still, in the case of multiple account
registration.
§ Report any suspicion or knowledge of money laundering of terrorist
financing to the Financial Intelligence Analysis Unit (FIAU) set up by
law as the Government Agency responsible for the collection, collation,
processing, analysis and dissemination of information with a view to
prevent money laundering and combat the funding of terrorism.
§ Suspicious Activity in this case is being referred to as suspicious
transactions, extreme player profiles, when deposits are not matching up
amongst other elements. Other concrete examples of how we identify
players who require our team to undertake a risk monitoring approach of
our customers and when to specifically carry out enhanced due diligence
checks on the Player Profiles can be further required:
1. Passport or ID card.
2. Utility bill.
3. Bank statement.
4. Other proof of identity.
§ The Enhanced Due Diligence Checks are subject to players’ profile and
the amount of Risk they pose to us. Only when we determine some of
the above points or a combination of a few will we flag the
customer/customers in question and conduct risk monitoring. This will
include checks of where the customer works, value of house, where the
customer lives and checks to see whether the value of the house is logical
compared to the customers spending.
§ Within that framework, Suspicious Activity Reports (SARs) are an
imposed requirement. BetNacional ensures that any employee reports to
the Risk Team where they have grounds for knowledge or suspicion that
a person or customer is engaged in ML or terrorist financing. Any
employee failing to so do is open to criminal prosecution.
§ Escalations of SARs should be done in a confidential, discreet manner,
in a handwritten form and not via email so as to ensure maximum
anonymity.
§ An employee must not, under any circumstances, disclose or discuss any
AML concern with the person or persons subject to an investigation, or
any other person for that matter. Disclosure (also known as "tipping off")
is strictly prohibited and carries with it very serious legal penalties.
§ Furthermore, and in order to keep ourselves protected as much as
possible, no remark should ever be left on an account that would give
any indication that ML is suspected, a player being entitled, at any point
in time, to request the full notes/remarks on their account.
§ Cooperate with all relevant administrative, enforcement and judicial
authorities in their endeavor to prevent and detect criminal activity.
§ Moreover, the company shall:
1. Not accept to open anonymous Accounts or Accounts in
fictitious names such that the true beneficial owner is not known.
2. Not accept cash from Players.
3. Funds may be received from Players only by any of the
following methods: credit cards, debit cards, electronic transfer,
wire transfer, cheques and any other method approved by the
Regulator.
4. Not register a Player who is under eighteen (18) years of age.
5. Only register a single account in the name of a particular person:
multi-account practices are strictly prohibited.
6. Transfer payments of winnings or refunds back to the same route
from where the funds originated, where possible.
7. Not accept a wager unless a User Account has been established
in the name of the Player and there are adequate funds in the
Account to cover the amount of the wager.
8. Not accept a wager unless the funds necessary to cover the
amount of the wager are provided in an approved way.
9. Not accept Players residing or playing from non-reputable
jurisdictions.
10. Not make a payment in excess of two thousand three hundred
EUR (€ 2,300) or cumulative out of a User Account to a Player
until the Player’s identity, age, and place of residence have been
verified.
11. If no transaction has been recorded on a User Account for thirty
months, close the User Account and remit the balance in that
account to the Player, or if the Player cannot be satisfactorily
located, to the regulator.
 12. Where it deems necessary, verify creditworthiness of the Player
with third parties who previously provided any information on
the Player.
13. If it becomes aware that a person has provided false information
when providing due diligence documents, not register such
person. Where that person has already been registered, the
company shall immediately cancel that person’s registration as
a Player with the company.

- The customer declares and expressly guarantees that all the amounts deposited and used to
participate in BetNacional.com come from legitimate sources and are not connected with any
fraudulent activity, money laundering or activities that are considered to be illicit by law such as
money laundering or funding of terrorism. Pursuant to the current law, and regulations which may
be issued at any time by the regulator about the prevention of money laundering and the funding
of terrorism, BetNacional reserves the right to take any steps is considers necessary to comply
with these requirements. The users cannot use loans to participate in BetNacional website.
BetNacional.com, as the operator, will not grant the user any kind of loan or mechanism that
allows them to take out loans or transfer funds between players, at any time. BetNacional reserves
the right to supervise any transfer of funds that are deposited or withdrawn by any user and to
report any user information to the regulatory or criminal authorities and/or payment service
providers. BetNacional keeps the players' money in an account which is legally separate from
BetNacional’s own funds. And also reserves the right to retain all a customer’s funds at its own
criteria if it considers that they derive directly or are related with illicit or fraudulent activities.
After confirmation of the deposit, the customer can use the deposited funds for bets. The deposits
are credited to the player’s account as soon as the bank transfer is successfully validated. Deposits
and withdrawals are only made in United States Dollar (US$), Brazilian real (R$) and Euro (€).
The minimum deposit amount is 10 USD or 30 BRL or 10 EUR. It is the customer’s entire
responsibility to check whether their bank imposes any fees on these transfers. The client declares
that is the holder of the payment account provided to BetNacional and the payment methods used
are associated with that same account, or if not possible, associate it to an account owned by the
client. The total balance of your player account includes Casino Balance, Real Sportsbook
Balance, Casino Bonus Balance and Sportsbook Bonus Balance. The existence of two wallets
(casino and sports betting) does not change the behavior of your player account when making an
withdrawal request. Consequently, making a request of withdraw, regardless the balance to be
withdrawn is transferred from your casino wallet, it may result in the loss or cancellation of sports
betting bonuses. The withdrawals must be made by the same method as that used for the deposits
whenever the method used allows it. If the deposit method does not allow withdrawals, these must
be made by bank transfer to the account given by the user when they registered or to the payment
account they indicated and hold and that is chosen for this purpose. Withdrawals may only be
processed from your Sports Cash Account. Any withdrawals from your Casino Cash Account can
only be made by first transferring your withdrawal amount to your Sports Cash Account and then
requesting the withdrawal be processed from the Sports Cash Account. Please note however that
any transfer of funds from the Casino Cash Account to the Sports Cash Account will be
considered a Withdrawal from the Casino Cash Account and may consequently result in the
forfeiture or voidance of Casino product bonuses and promotions. BetNacional reviews players
spend and game play to check for suspicious activity. Before any withdrawal is processed the
following procedures are carried out:

1. The customers deposit history is reviewed to confirm that no suspicious payments have
been made to the customer’s account. The frequency of deposits and the sum of deposits
are reviewed to ensure they are within normal range for the customer based on his
depositing history and the general depositing range throughout our network.
2. The customer’s turnover is reviewed to ensure that they have played in the casino and are
not using BetNacional as a method to move money.
 3. When possible, funds must always be refunded back to the original payment method used
by the player to make a deposit.
In order to fulfil the legal requirements your identity must be verified by BetNacional.
For this purpose, at the first time of the withdrawal request you should send us an email
to [email protected] with at least the following documents:
1. Document of your identity with photo and date of birth;
2. Proof of address;
3. Proof of ownership of the account.

- Whenever you pretend to change your payment’s account you must send a new proof of the
ownership of the new account. Without that your payment won’t be processed. Your Player
Account shall not be used or treated as a bank account. In case of deposits or withdrawals without
gaming activity, or activity using reduced proportions of initial deposits, BetNacional. reserves
the right to request explanations before transferring the withdrawal request in question. Your
withdrawal request will be cancelled within 72 hours from the date of your order if you don’t give
to BetNacional.com the necessary information to allow verification of your identity. Any
withdrawal is free.

4.5 - Politically exposed person

- European guidelines regarding “The Prevention of Laundering the Proceeds from Criminal
Activity (Money Laundering) and Terrorism Financing” entered into effect, changing the
definition of politically exposed person. In order to minimize corruption and money laundering
risks, BetNacional. is obliged by law to collect data and identify which of the clients/clients’
beneficiaries should be considered as politically exposed persons, their family members or close
associates. According to the law “On the Prevention of Laundering the Proceeds from Criminal
Activity (Money Laundering) and Terrorism Financing” the following person shall be deemed a
politically exposed person (hereinafter referred to as PEP): a person who holds or has held a
prominent public position in a country of the European Union or European Economic Area or a
third country, including senior-level state official, head of a state administrative unit
(municipality), head of the government, minister (deputy minister or assistant deputy minister if
there is such position in a relevant country), secretary of state or another high level official in the
government or state administrative unit (municipality), member of parliament or similar
legislative body, member of the management body (board) of a political party, judge of
constitutional court, supreme court, or another level court (member of judicial body), member of
the council or board of a supreme audit institution, member of the council or the board of a central
bank, ambassador, charge d’affaires, armed forces higher officer, member of the council or board
of a state capital company, head (director, deputy director) of international organization and
member of the board or a person who holds an equal position at such organization. The following
person shall be deemed a family member of a politically exposed person:

1. a spouse or person considered to be the equivalent to a spouse. A person may be deemed

the equivalent to a spouse only provided that he / she has such status under the laws of
the respective country;
2. a child or a child of a politically exposed person’s spouse or person considered to be the
equivalent to a spouse, his / her spouse or person considered to be the equivalent to a
spouse;
3. a parent, grandparent or grandchild;
4. a brother or sister.

- A close associate of a politically exposed person is an individual publicly known to maintain

business or other close relationship with a politically exposed person, or to be a shareholder in
one and the same commercial company with a PEP, and also an individual who is the sole owner
of such legal entity which is known to be actually established for the benefit of a PEP.

4.6 - Forbidden Countries

- The following countries are restricted from participation with BetNacional.com:

1. United States of America and its territories, French Republic and its territories, United
Kingdom, Netherlands (including Curacao and other countries and territories that form
part of the Kingdom of Netherlands), Portugal, Spain, Germany, Denmark, Slovenia,
Turkey, Poland, Czech Republic, Singapore, Democratic People’s Republic of Korea
(DPRK), Syria, Iran, Pakistan, Iraq, Laos PDR, La Reunion, Martinique, Yemen.