KYC

KNOW YOUR CUSTOMER (KYC) POLICY

1. Introduction

The Know Your Customer (KYC) Policy establishes the principles, standards and guidelines that Ana Gaming adopts to identify and verify the identity of players and users of the platform, aiming at compliance with applicable laws and prevention of illicit activities, such as money laundering and terrorist financing.

2. Purpose

The main purpose of this policy is to prevent illegal activities from occurring in our online gambling environment, in compliance with legal, sectoral and ethical requirements, guided by the following principles:

● Regulatory Compliance: Ensure that all advertising communications comply with gambling and betting regulations, specifically the Law on the Prevention of Money Laundering and Financing of Terrorism (PLD/FT – Law No. 9,613/1998), Laws No. 13,756/2018 and 14,790/2023, which regulate the lottery modality called fixed-odds bets, the regulatory ordinances issued by the Ministry of Finance and Normative Instruction No. 1/2020 of COAF.

3. Scope

This policy applies to all Ana Gaming employees and departments that are involved in interacting with players, including, but not limited to, registration, customer service, operational areas, and player and transaction monitoring.

4. Definitions

Know Your Client (KYC):e, “Know Your Client” is a process used to identify and verify the identity of its customers in order to prevent fraud, money laundering, and other illicit activities.

5. KYC Process Guidelines

5.1 Player Registration

When registering, the player or user must provide the following information:

5.1.1 Required Basic Information

· Full name;

· Date of birth;

· Nationality;

· Full residential address;

· Identification number (ID, passport, or equivalent document);

· Contact information (telephone and email);

· Geolocation.

5.1.2 Banking Information:

Account number or Card Number

5.1.3 Required Documents:

· Copy of an identity document with photo; and

· Recent proof of address (electricity or water bill).

5.2 Verification of Player or User and Validation of Documents

All information provided is verified through the documents previously provided, which in turn are verified for authenticity through specific tools. Ana Gaming reserves the right to request additional documents, if necessary.

5.3 Cross-referencing of data

Ana Gaming cross-referencing the data provided by players and users with third-party databases to identify the following information:

· Politically exposed persons (PEPs) or relationships with PEPs (up to 2nd degree of relationship);

· Sports-exposed persons (PEDs) or relationships with PEDs (up to 2nd degree of relationship);

· Existence of a corporate or employment relationship with other operating agents;

· Presence on national and international restrictive lists (FBI, Interpol, OFAC, etc.);

· History of employment relationship with regulatory agencies (MF, SPA, COAF, etc.);

· History of legal actions;

· History of criminal records;

· History of gambling addiction;

· Exposure and profile in the media;

· Among others.

Based on the results of the cross-referencing, Ana Gaming must adopt criteria to restrict the acceptance of high-risk players or those located in certain jurisdictions where the Risk of Money Laundering and Financing of Terrorism and Proliferation of Weapons of Mass Destruction is greater.

Player portrait

· Under 18 years of age;

· Owner, administrator, director, person with significant influence, manager or employee of the operating agent;

· Public agent with duties directly related to the regulation, control, and supervision of the activity within the scope of the federative entity in whose staff they exercise their powers;

· Person who has or may have access to computerized fixed-odds lottery betting systems;

· Person exposed in sporting terms – Person who has or may have any influence on the outcome of a real sporting event that is the subject of a fixed-odds betting lottery, including: o Person who holds the position of sports director, sports coach, trainer and member of a technical committee;

o Referee of a sports modality, assistant referee of a sports modality, or equivalent, sports entrepreneur, agent or attorney for athletes and coaches, coach or member of a technical committee;

o Member of the administrative or supervisory body of an entity managing the organization of a competition or sports event;

the Athlete participating in competitions organized by entities that are part of the National Sports System.

· Person diagnosed with gambling addiction, by report from a qualified mental health professional; and · Persons who are located or have bank accounts located in jurisdictions with a high risk of money laundering;

· Other persons provided for in the regulations of the Ministry of Finance, 5.4 Risk Classification Based on the information provided by the player or user, they are classified based on the level of risk they represent, so that Ana Gaming can apply appropriate control measures for each level of risk. The main risk profiles of players and users are detailed in the AML-FTP policy.

5.5 Continuous Monitoring

Ana Gaming will perform continuous monitoring of accounts to identify suspicious activity. This includes:

· Regular review of transactions;

· Analysis of betting patterns;

· Checking for possible signs of fraud or illicit activity;

· Checking registrations to identify potential players or users who are prohibited from playing;

· Checking for potential changes in the risk levels of players or users.

5.6 Data Storage

Ana Gaming must maintain records and documents related to compliance with the provisions of this Ordinance for at least 5 (five) years, without prejudice to other duties provided for in the legislation.

All information collected will be stored securely and in compliance with applicable data protection laws. Access to information is restricted to authorized employees.

6. Responsibilities

● Registration Area: Responsible for managing player or user registrations;

● Governance and Compliance Area: Responsible for implementing, reviewing and updating this policy, as necessary, ensuring compliance with industry regulatory requirements.

● Risk Area: Responsible for managing this policy, ensuring compliance with local and international regulations;

7. Policy Audit and Review

Ana Gaming will conduct periodic internal audits to ensure compliance with this KYC Policy and applicable regulations that establish standards for preventing illicit activities, such as money laundering and terrorist financing.

8. Training and Qualification

The company conducts regular training for all employees, especially those directly involved in the processes of registering, verifying, storing and monitoring player or user data. They receive regular training on the KYC policy and best compliance practices.

· Training helps employees involved in the processes in question to identify any discrepancies and inconsistencies in the information recorded and documents provided by players or users at the time of registration;

· The training will include guidance and analysis of situations and examples of money laundering attempts in online casinos and gambling.

9. Penalties for Non-Compliance

Any violation of this KYC Policy will be treated with due seriousness by Ana Gaming. Penalties may include:

· Formal warnings;

· Mandatory corrective training;

· Disciplinary actions, which may range from suspension to termination, depending on the severity of the violation.

10. Contact

For any questions about this policy, please contact the Governance and Compliance area.

Approval:

Compliance Director