Anti-Money Laundering (AML) Policy

Last modification date: 24.03.2025

INTRODUCTION

This Anti-Money Laundering Policy (hereinafter the "Policy") is aimed to govern the activities of Udwin B.V against money laundering, terrorist financing, or any other illegal or fraudulent activity.

This Policy outlines the measures implemented by the Company to ensure compliance with relevant AML legislation, international standards, and regulatory requirements. It also explains how these measures affect users of vox.casino (hereinafter referred to as the “Website”).

The Company reserves the right to amend or revise this Policy at any time to reflect changes in legislation, regulatory requirements, or risk assessment procedures. Users are responsible for reviewing the Policy periodically. Continued use of the Website after updates take effect constitutes acceptance of the revised Policy.

1. Implementation of this Policy

To ensure full compliance with AML/CTF obligations, the Company implements the following measures:

• Customer Due Diligence (CDD): Users may be required to complete verification procedures, including identity verification, document submission, and ongoing monitoring, in line with risk-based approaches.

• Risk-Based Approach: The Company applies a risk-based assessment framework based on FATF risk categories, evaluating users for potential money laundering, terrorist financing, and other illicit activities.

• Transaction Monitoring: The Company continuously monitors all transactions conducted through the Website to detect and prevent suspicious activity.

• Employee Training & Awareness: The Company ensures its staff receives ongoing training on AML best practices, evolving financial crime threats, and compliance obligations to enhance the effectiveness of its AML program.

2. Risk Categories

The Company employs a risk-based approach in line with the Financial Action Task Force (FATF) and the Curaçao Gaming Control Board (GCB) to assess the money laundering and terrorist financing (ML/TF) risk associated with each User.

These risk categories are:

2.1 Country/Geographic risk

Upon registration, a User’s place of residence/domicile (hereinafter the "Jurisdiction") must be considered as a matter of priority. The Company follows a multi-layered screening approach, which includes:

• Checking if the jurisdiction appears on the European Commission’s list of high-risk third countries with strategic deficiencies.

• Verifying whether the country is listed under FATF’s "High-Risk Jurisdictions Subject to a Call for Action" or "Jurisdictions Under Increased Monitoring."

Furthermore, the Company conducts its own monitoring of the jurisdictions based on the following parameters:

• Legal environment.

• Political environment.

• A country's economic structure.

• Cultural factors and the nature of civil society.

• Sources, location and concentration of criminal activity (if any).

2.2 User risk

The Company reviews each user's activity on the Site for the presence or absence of one or more factors that could give rise to a "high-risk" user classification. These factors are:

a) High-stakes gamblers whose spending patterns significantly exceed average levels;

b) Unusual activity patterns, such as: suspicious activity, use of several devices to authorize on the Company in a short time-frame, use of one IP address by several Users, use of the User's device by other Website Users;

c) Politically Exposed Persons (PEPs) as defined under EU Directive 2015/849 and other applicable regulatory frameworks.

Users identified as high-risk may be subject to Enhanced Due Diligence (EDD) and additional scrutiny.

2.3 Transaction risk

The Company makes every effort to eliminate any transaction risk(s) identified by FATF:

• Anonymous payment methods are not accepted.

• Fund transfers between user accounts are strictly prohibited.

• Cash deposits are not permitted.

• Only reputable electronic wallets from well-regulated jurisdictions are accepted.

• Users must use payment instruments registered in their own name. Additional accounts and third-party payment methods are not permitted.

2.4 Product Risk

The Company considers the types of products offered and the extent to which their features might be exploited for illicit activities, such as money laundering or financing terrorism. Products with the potential for large, rapid, or anonymous transactions, as well as those prone to manipulation, are identified as higher risk and are subject to enhanced controls.

3. Verification

The Company may require a User Verification in the following circumstances:

a) When the total transaction volume of a user reaches or exceeds a threshold;

b) If a risk assessment determines that the user falls into one or more high-risk categories (see "Risk Categories" section);

c) If suspicious activity is detected, including but not limited to, behavior that suggests potential fraudulent activity, account misuse, or violations of the Website's Terms and Conditions, Privacy Policy, and other applicable rules;

d) In any other circumstances where the Company deems verification necessary, including regulatory compliance requirements, risk mitigation, or enhanced due diligence (EDD) procedures.

As part of the User Verification process, the Company may request the following documents:

• A copy or a photo of the user's identification document;

• A photo of the payment card used or intended to be used in making deposits on the Website. It is important that the name of the cardholder must match the name of the user who passes the verification. CVV code and payment card number (except first six and last four digits) may be hidden or covered. The cardholder's name must not be hidden or covered in any way;

• A photo of the user holding the documents required for the verification process (may be with the requested information, written by hand (the e-mail of the user, used when registering an account; the date of the photo request and the confirmation code);

• If applicable, include a bank statement, a letter from User’s duty station or place of employment, and a tax bill;

• If applicable, User’s address confirmation. It may be a utility bill, a phone bill, or other documents that, in accordance with the jurisdiction's legal and regulatory requirements, are sufficient to confirm the User's address;

• Any other documents or information that the situation may require.

The Company reserves the right to request a video interview with the User in order to confirm the information.

3.1 Additional verification

The Company may implement additional verification processes in the following circumstances:

a) The user meets the definition of a Politically Exposed Person (PEP). A politically exposed person is defined as a natural person who is or has been entrusted with prominent public functions, which include the following: (a) heads of government, heads of state, ministers, and deputy or assistant ministers;(b) members of parliament or similar legislative bodies; (c) members of political party governing bodies; (d) members of supreme courts, constitutional courts, or 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 central bank boards; (f) ambassadors, chargés d'affaires, and high-ranking officers in the armed forces; (g) members of State-owned enterprise administrative, management, or supervisory bodies; and (h) directors, deputy directors, and members of an international organization's board or equivalent function.

b) If the User's country of residence is defined by the European Commission as a "third country with strategic deficiencies" or is on the FATF's list of "high-risk and other monitored jurisdictions";

c) In other cases, when additional verification is required by law or at the request of authorities, financial institutions, etc.

In addition to the standard verification, when applying additional verification, the Company requires to submit the document(s) or data on the source of the user's income in accordance with the jurisdiction's legal and regulatory requirements when using additional verification. In the event of additional verification, the final approval on the verification will be done by Senior management of the Company.

For the purposes of this Policy, the Company reserves the right to collect additional user identification data. Furthermore, if a) a user refuses to pass verification; and/or b) the Company has reasonable grounds to suspect that a user is using the Company for illegal purposes and the user does not provide evidence to the contrary, the Company may inform appropriate government authorities on such case. Additionally, the Company may suspend the User's account until the user passes a verification processes or provides the document(s) or information requested by the Company.

4. Record Keeping period

For a period of 5 (five) years, the Company may keep a record of the verification data of the Website's Users, as well as the transaction data (the history of the transactions and their supporting evidence) in easily accessible form. Please refer to the Privacy Policy for more information on the storage of personal data of Website users.

5. Activity Monitoring

The company constantly monitors all of the users' transactions to ensure that they meet the following requirements:

• In case of a banking transaction or transaction from the banking card, the account/card holder's name must be the same as it was when the account was registered (or, if the name was changed, the actual name displayed on the user's account).

• If a deposit is made from a payment instrument to which funds cannot be withdrawn, the withdrawal may be made to the user's banking account or to another payment instrument if it is reasonably possible to ascertain that this payment instrument truly belongs to the user in question.

• The Company reserves the right to request additional verification documents (e.g., proof of account ownership, source of funds) if inconsistencies, unusual patterns, or potential risks are detected.

The Company constantly monitors all user activity as well as their transactions to ensure that they are free of money laundering methods. These methods are:

Placement.

At this point, the funds are converted into other financial instruments such as banking accounts, checks, money transfers, or used to purchase expensive items that can then be resold. The funds can then be invested in banks and other non-banking institutions (for example, money exchange institutions). To avoid any suspicions from the Company's side, a money-laundering entity may conduct several placements rather than placing the entire sum in one operation. This is known as "smurfing" or "structuring".

Layering.

The funds are moved or transferred to other accounts or financial instruments. This procedure is designed to conceal the source of the funds and prevent the identification of the person who performs various financial operations. The movement of funds and changes in their form complicates the process of monitoring funds.

Integration.

The funds are being returned to the financial system under the guise of lawfully obtained funds, with the ultimate goal of eventual integration into the financial system.

5.1 Suspicious activity prevention

All operations on funds depositing must be checked on so-called "fitting of cards" (the use of several cards through different payment agents recommended by the Company, obtaining a specific error code when making a payment, the use of cards issued by different emitters in different regions), the use of a different payment instrument in a short period of time (cards, banking transactions, electronic wallets), the User opposition or unwillingness to verify any of payment instrument, mismatch of the User key elements of geographic location (citizenship/residency, Internet provider, IP address geolocation, mobile carrier provider, BIN number of the card etc.), principal opposition to make 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, tablet, computer) with the device ID of another account in our system.

6. Training of the staff on current AML procedures

The staff of the financial department, that has the responsibility of the User withdrawal and depositing transactions, and the compliance department, that has the responsibility of document verification, are constantly monitoring the legislation and applicable practices of international organizations for any changes in the legislation; and keeping track of the business environment and practices of our partners and other organizations, engaged in combating money laundering. On regular basis the Company conducts training courses and revisions to internal procedures, considering potential changes in FATF recommendations and "Big Four" practices. Every three months, the Company conducts personnel attestation in order to check the knowledge and competencies required to effectively perform the functions relating to CTF/AML/KYC procedures and applicable practices, as well as to check the knowledge of current legislation in the field.

7. References

Here you can find the source list (but not limited to) for this Policy. Additional legislation or documents may be applied.

1.The Forty Recommendations and Special Recommendations on Terrorism Financing ("FATF Recommendations");

2. Risk-based approach guidance for the casinos (RBA for Casinos), issued by FATF;

3. 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;

4. 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;

5. The Prevention and Suppression of Money Laundering Activities Amending Law 13(Ι) of 2018 of the Republic of Cyprus;

6. Curacao Gaming Control Board, Regulations for the combating of Money Laundering, the Financing of Terrorism and Proliferation of weapons of mass destruction, last update January 2025;

7. FATF list of High-risk and other monitored jurisdictions: http://www.fatf-gafi.org/countries/#high-risk