ANTI-MONEY LAUNDERING

(last updated 01.08.2025)

1. INTRODUCTION

Limitex Ltd. follows international AML regulations, especially regulations issued by the Tobique Gaming Commission.

The policies set forth herein (the “Policies”) are intended to satisfy the statutory requirements of the relevant legislation and to provide direction to Limitex Ltd. (or the “Company”) in complying with its obligations at law by taking all reasonable steps and exercising all due diligence to avoid the commission of an offence of money laundering or funding of terrorism.

The Company is aware that criminals and terrorists may attempt to use the Company’s services to channel funds from illegal activities through our services.

2. SCOPE OF THIS POLICY

The scope of this policy is to establish policies and procedures on internal control, risk assessment, risk management and compliance in relation to AML/CFT.

Users of this and related policies should also refer, where relevant, to the “AML Code of Practice for Remote Gaming License Holders” issued by the Tobique Gaming Commission. This AML Code of Practice was enacted on April 5, 2024, pursuant to Section 22 of the TOBIQUE GAMING ACT 2023.

Unless the context requires otherwise, words and expressions used in the Policy shall have the same meaning as that set out in the applicable laws and regulations.

The Company is determined and committed to preventing financial activities through its systems that may be related to AML/CFT. This is carried out by sufficient resources devoted to the development of documentation and training for the Limitex Ltd. employees, together with appointing a suitable MLRO to ensure the Policies and Procedures in place are being followed.

The Company shall comply with its legal obligations by establishing the necessary and relevant processes to prevent AML/CFT and ensure that any suspicious activities are escalated to the relevant authorities.

The company aims to avoid penalties and repercussions that arise from noncompliance. Therefore, it is in the interest of the MLRO, together with the Compliance team, to make sure the company is following all regulations set out by the Belize Authorities and Tobique Gaming Commission.

The Limitex Ltd. Policies outline the general and minimum standards of internal anti-money laundering and combating funding of terrorism (AML/CFT) that Limitex Ltd. management and employees should adhere to. Partner companies must also be made aware of this policy.

3. OVERVIEW OF AML /CFT

“Money laundering” is generally defined as “engaging in acts designed to conceal or disguise the nature, control, or true origin of criminally derived proceeds so that those proceeds appear to have been derived from legitimate activities or origins or otherwise constitute legitimate assets.”

The Proceeds of Crime are funds derived from illicit sources from which a benefit or enjoyment may be obtained. Although the aim is not to launder the funds or to fund terrorism, it is still considered to be an illegal activity, and subject persons should be aware of such activity and report it as if it were ML/FT.

4. MONEY LAUNDERING REPORTING OFFICER

The MLRO will own the AML/CFT Risk Assessment, Controls, Policies, and Procedures, report to the Board of Directors, and liaise with the Regulatory Authorities.

The implementation or operation of Limitex Ltd. AML/CFT compliance program will be carried out by the appointed MLRO.

The MLRO appointed should possess professional experience, training and resources to carry out his/her appointment as per PMLA, PMLFTR and FIAU regulations.

The MLRO responsibilities shall include but are not limited to:

• Risk assessment and management
• Ensuring customer due diligence measures and ongoing monitoring
• Reporting
• Record-keeping
• Promoting internal control
• Perform internal auditing of AML/CFT processes (unless an Internal Auditing function is available)
• The monitoring and management of compliance with, and the internal communication of, such policies and procedures
• Monitoring of relevant staff and agent screening
• Liaison with Law Enforcement Authorities
• Manage Investigation Order requests received from the Authorities

5. RISK ASSESSMENT

Business ML/FT Risk

The Company is to carry out a yearly business risk assessment, which is a separate document together with a risk matrix which gives a complete overview of the following:

• Identify ML/FT Vulnerabilities
• Identify ML/FT Threats
• Identify any new requirements

Based on the results of the Risk Assessment and if deemed necessary, to minimize any new risks identified or existing risks being re-classified, the following controls would need to be revisited and amended accordingly:

• Measures
• Policies
• Controls
• Procedures

The risk assessment should also be updated whenever substantial changes to the Company’s systems, processes and overall operations are affected.

The Risk assessment and related measures, policies, controls, and procedures are to be stored and readily available for review by the FIAU and other interested authorities at any time.

Customer Risk

Upon registration, customers go through an introductory assessment in which the following is assessed:

• Customer type
• Products used (e.g. sportsbook)
• Services (e.g. poker, bingo, betting exchange)

Once the customer reaches the €2,000.00 threshold, a more in-depth assessment is carried out where a customer is assigned a risk rating based on more information the Company has in place:

• Transactions/payment systems
• Delivery channels
• Geographical origin of the customer and/or payment method used

After registration, a customer’s activity should undergo ongoing monitoring to reconsider risk level depending on changes in customer’s activity and to establish point of reaching the relevant due diligence thresholds.

6. PEP / SANCTION LIST CHECKS

Customers upon registration are checked to confirm whether the customer is himself, or is a family member of, or known associate to, a person that is considered a PEP, and Sanction List screening is carried out upon registration.

The following databases are being used to screen the individuals:

• SEON – https://seon.io/
• Smartsearch – https://www.smartsearch.com/

In case a customer is a match to being a PEP, the Board of Directors are to be informed and take the decision whether to accept the PEP or not. If the business relationship continues, then the customer is automatically considered a high-risk profile and appropriate measures must be taken to ensure that the business activity with them is not of an ML/FT nature.

For any customer who matches the Sanction List screening, the MLRO is to report the customer to the Sanction Monitoring Board within 72 hours of identification, and the customer will be banned from onboarding with the company.

Refer to the PEP / Sanction List Procedure and Customer Acceptance Policy for more information on the above.

7. CUSTOMER DUE DILIGENCE

Customer Due Diligence (CDD) Measures include:

• Collection of identification details
• Verifying the identity of the customer
• Defining the type of intended business relationship with the customer
• Conducting ongoing monitoring of the business relationship, to ensure transactions are consistent with what the business knows about the customer and the risk assessment; retaining records of these checks and updating them when there are changes
• Obtaining Source of Wealth / Source of Funds information once a customer becomes a risk rating higher than low

The Customer Due Diligence Procedure defines the steps used to carry out CDD, including timeframes when it will be triggered and the situations in which Enhanced Due Diligence will need to be performed.

Definition of Money Laundering

Money Laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or company’s action;
• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to above.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for the Website

In accordance with AML legislation, the Website has appointed the “highest level” for the prevention of money laundering: The full management of Limitex Ltd. is in charge.

Furthermore, an MLRO (Money Laundering Reporting Officer) is in charge of the enforcement of the AML policy and procedures within the system.

The MLRO is placed under the direct responsibility of the general management.

AML Policy Changes and Implementation Requirements

Each major change of the Website AML policy is subject to approval by the general management of Limitex Ltd. and the Anti-Money Laundering Compliance Officer.

Three-Step Verification

Step One Verification

Step one verification must be done by every user and customer in order to withdraw, regardless of the choice of payment, payment amount, withdrawal amount, withdrawal method, or the nationality of the user/customer.

Step one verification is a form that must be filled out by the user/customer personally. The following information must be provided:

• First name
• Second name
• Date of birth
• Country of usual residence
• Gender
• Full address

Step Two Verification

Step two verification must be done by every user who deposits over €2,000 or withdraws any amount. Until step two verification is complete, the withdrawal, tip, or deposit will be on hold.

The user/customer will be directed to a subpage where they must upload a photo of their official ID along with a visible paperclip containing a six-digit randomly generated number.

An electronic check will verify whether the data from step one matches the information on the ID, using two databases. If this check fails or cannot be completed, the user/customer will be required to provide proof of current residence (e.g., certificate of registration issued by the government or a similar document).

Step Three Verification

Step three verification must be done by any user who:

• Deposits over €5,000
• Withdraws over €5,000
• Sends another user over €3,000

Until step three verification is complete, the withdrawal, tip, or deposit will be on hold. The user/customer will be required to submit proof of source of wealth.