Anti-Money Laundering and Terrorist Financing Policy

Section 1.1 AfriSlots (the “Company”) is committed to continuously improve its governance practices and hereby adopts this Anti-Money Laundering and Terrorist Financing Policy AMLTF (the “Policy”).

Section 1.2 The following definitions shall apply to the foregoing:

• “Appropriate Government Agency” (“AGA”) – refers to Tobique Gaming Commission, the Company governing body;
• “Gaming Operators” – refers to a business authorized by the appropriate government agency to engage in gaming operations;
• “Suspicious Transaction” – refers to transactions with covered persons, regardless of the amounts involved, where any of the following exist:

• a. There is no underlying legal or trade obligation, purpose or economic justification;
• b. The client is not properly identified;
• c. The amount involved is not commensurate with the business or financial capacity of the client;
• d. Taking into account all known circumstances, it may be perceived that the client's transaction is structured in order to avoid being the subject of reporting requirements under the AMLTF Policy;
• e. Any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client's past transactions with the covered person;
• f. The transaction is in any way related to an unlawful activity or any money laundering activity or offense that is about to be committed, is being committed or has been committed; or
• g. Any transaction that is similar, analogous or identical to any of the foregoing.

Section 2.1 Money Laundering is a process intended to mask the benefits derived from serious offenses or criminal conduct that they appear to have originated from a legitimate source.

Section 2.2 Generally, the process of money laundering comprises three stages, during which there may be numerous transactions that could alert the Company to the money laundering activity.

• a. Placement – the physical disposal of cash proceeds derived from illegal activity.
• b. Layering – separating illicit proceeds from their source by creating complex layers of financial transaction designed to disguise the audit trail and provide anonymity.
• c. Integration – the provision of apparent legitimacy to criminally derived wealth. If the layering process has succeeded, integration schemes place the laundered proceeds back into the economy in such a way that they re-enter the financial system appearing to be a normal business funds.

Due diligence must, therefore, be exercised to prevent the use of the Company as instrument for money laundering. The Company shall apply enhanced due diligence measures to customer/s who present high or elevated risk for money laundering or terrorist financing.

Enhanced Due Diligence includes:

• a. Taking reasonable measures to establish the customer's source of revenue and funds;
• b. Ascertaining and confirming risk factors of the customers;
• c. Identifying patrons who should be escalated to the AML Committee to decide whether to establish or continue (for existing patrons) such business relationships; and
• d. Identifying patrons who should be subject to enhanced monitoring of the business relationship.

Section 3.1 The Company seeks to combat money laundering by requiring its employees to apply the following principles:

I. Know your customer: The Company is responsible for knowing its customers and aims to ensure the integrity and veracity of any sensitive data it obtains. When a customer enters contract or player registered with the Company, it shall be required to submit and disclose Company's information for due diligence. The company reserves the right to immediately suspend its service if it appears that customer is engaged or is trying to engage in suspicious transactions and/or criminal activities.

II. Compliance with laws: The Company shall ensure that business is conducted in conformity with high ethical standards, that laws and regulations are adhered to and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.

III. Cooperation with law enforcement agencies: Should there be reasonable grounds for suspecting money laundering, the Company shall cooperate fully with law enforcement agencies as may be required under pertinent laws.

IV. Dissemination of Policies and Procedures: Policies and procedures to prevent and detect possible money laundering activities are properly disseminated to the officers and staff of the Company.

Section 4.A. General

Section 4.A.1 The Company shall obtain satisfactory evidence of the true and full identity of its customers through the use of documents such as, but not limited to:

• Certified copies of the passports
• Certified copies of the other government issued IDs and
• Certified copies of the utility bills (dated within the last 6 months);
• Other pertinent and reasonable documents as may be deemed necessary under the prevailing circumstances.

Section 4.B. Customers

Section 4.B.1 The Company shall endeavor to obtain from its customer the following information:

• Name and/or alias names used;
• Date and place of birthday;
• Registered address;
• Contact number;
• Nature of Business;
• Sources of funds;
• Bank account details.

Section 5.1 The Company shall prepare and maintain documentation on their customer relationships and transactions such that:

• I. Any transaction effected via the Company can be reconstructed and from which appropriate government agency will be able to compile an audit trail for suspected money laundering, when such a report is made to it;
• II. The Company can satisfy within a reasonable time any inquiry or order from the appropriate government agency to disclosure of information, including without limited whether a particular person is the customer or beneficial owner of transaction conducted through the Company.

Section 5.2 The following document retention periods shall be followed:

• I. All KYC documents, such as the Due Diligence Documentation Forms as may be applicable, as well as copies of the customer's identification records shall be maintained and safely stored for five (5) years from the date of transactions.
• II. With respect to inactive customer/s, the records on customer identification, account files and business correspondence, shall be preserved and safely stored for at least five (5) years from the dates when they are account was terminated.

Section 5.3 Transaction documents may be retained as original or copies, on microfilm, or in electronic from, provided that such forms are admissible in court.

Section 5.4 Notwithstanding paragraph 5.2, if the records relate to on-going investigations or transactions that have been the subject of a disclosure, they shall be retained beyond the stipulated retention period until it is confirmed that the case has been closed.

Section 6.2 The Company shall file a Suspicious Transaction Report (STR), regardless of the amount of the transaction where any of the following circumstances exists:

• 1. there is no underlying legal or trade obligation purpose or economic justification;
• 2. the client is not properly identified;
• 3. the amount involved is not commensurate with the business or financial capacity of the customer;
• 4. taking into account all known circumstances, it any be perceived that the customer's transaction is structured in order to avoid being the subject of reporting requirements under the Act;
• 5. any circumstance relating to the transaction which is observed to deviate from the profile of the customer and/or the customer's past transactions with the covered institution;
• 6. the transaction is in any way related to an unlawful activity or any money laundering offense under this Act that is about to be, is being or has been committed; or
• 7. any transaction that is similar or analogous to any of the foregoing.

Section 6.3 A suspicious transaction, as a general principle, relates to any transactions wherein there is a feeling of apprehension or mistrust considering the unusual nature or circumstances of the transaction and the behavioral factors on the persons with whom the transaction may be connected with an unlawful activity. Suspicious transaction is not exhaustive and it is left to the better judgment of the Company to gauge the nature of each and every transaction that they would be involved in.

Section 7.1 The Company shall institute a system for the mandatory reporting suspicious transactions by appointing the Compliance Officer who shall be responsible for reporting to Tobique Gaming Commission.

Section 7.2 The obligation to make the suspicious transaction report shall be on the Compliance Officer. Such reporting must be done within five (5) working days after initial detection of facts that may constitute a basis for filing such reports, unless the appropriate government agency prescribes a different period not exceeding fifteen (15) working days, from the occurrence thereof.

Section 7.3 The Company, its directors, officers and employees shall not warn their customers when information relating to them is being reported appropriate government agency or communicate, directly or indirectly such information to any other person other than appropriate government agency. Any violation of this confidentiality provision shall render them liable for criminal, civil and administrative sanctions under the Act.

Section 7.4

• (a) Where any employee or personnel, director or officer of the Company knows that the customer has engage in any of the predicate crimes, the matter must be promptly reported to the Compliance Officer who, in turn, must immediately report the details to appropriate government agency.
• (b) If there are reasonable grounds to suspect that the customer has engaged in an unlawful activity, the Compliance Officer receiving such a report, must promptly evaluate whether there are reasonable grounds for such belief and must then immediately report the case to Tobique Gaming Commission unless the Compliance Officer considers and records an opinion that such reasonable grounds do not exist.

Section 7.5 The Company shall maintain a complete file on all transactions that have been brought to the attention of the Compliance Officer including transactions that are not reported to Tobique Gaming Commission.

Section 8.1 The Company shall establish and implement control procedures aimed at preventing and impeding money laundering and terrorist financing. Such procedures shall, among other things, ensure that the Company and its employees are aware of the provisions of the law, its implementing rules and regulations, as well as all reportorial and compliance control and procedures that shall be established by Tobique Gaming Commission, the Supervising Authority and the Company.

Section 8.2 Policies and procedures should cover:

• Communications of firm policies relating to money laundering, including timely disclosure of information and internal audits to ensure compliance with policies, procedures and controls relating to money laundering;
• Customer identification, including requirements for proper identification;
• Maintenance of records;
• Compliance with the requirement of appropriate government agency;
• Cooperation relevant Authorities.

Section 8.3 The Company shall establish written internal reporting procedures which shall:

• (a) Enable all its directors, officers, employees, all key staff to know to whom they should report any knowledge or suspicion of money laundering activity;
• (b) Ensure that there is a clear reporting chain under which suspicions of money laundering activity will be passed to the appropriate person(s)/unit, duly identified and designated as the Compliance Officer;
• (c) Require the Compliance Officer to consider any report in the light of all relevant information available to him/her for the purpose of determining whether or not it gives rise to a knowledge or suspicion of money laundering;
• (d) Ensure that the Compliance Officer has reasonable access to any other information which may be of assistance to him/her and which is available to the relevant person;
• (e) Require that the information contained in a report is disclosed promptly where the Compliance Officer knows, suspects, or is made aware of any suspicious transactions;
• (f) Maintain a register of all reports, as well as all reports made by its own staff relative to suspicious transactions. Said register shall contain details of the date on which the report is made, the person who makes the report and information sufficient to identify the relevant papers.

Section 9.1 The Company shall appoint one or more senior persons, or an appropriate unit, to advise its management and staff on the issuing and enforcement of in-house instructions to promote adherence to the Act and its Rules, including personnel training, reporting of suspicious transactions, and generally, all matters relating to the prevention of money laundering and terrorist financing.

Section 9.2 The Company shall appoint a senior officer as the Compliance Officer or set up a designated compliance unit headed by a senior officer. The Compliance Officer shall be different from the Reporting Officer(s)/Unit. A Compliance Officer shall be:

• (a) A senior officer with relevant qualifications and experience to enable him to respond sufficiently well to inquiries relating to the relevant person and the conduct of its business;
• (b) Responsible for establishing and maintaining a manual of compliance procedures in relation to the business of the Company;
• (c) Responsible for ensuring compliance by the staff of the Company with the provisions of the Act and these Rules;
• (d) Act as the liaison between the Company and appropriate government agency in matters relating to compliance with the provisions of the Act and these Rules;
• (e) Prepare and submit to appropriate government agency written reports on the Company's compliance with the provisions of the Act and its Rules, in such form and submitted at such item as the appropriate government agency may determine.

Section 10.1 The Company shall provide education and training for all its staff and personnel, including directors and officers, to ensure that they are fully aware of their personal obligations and responsibilities in combating money laundering and to be familiar with its system for reporting and investigating suspicious matters.

Section 10.2 The Compliance Officer shall oversee an Anti-Money Laundering Training Program which is segmented and risk-based to be appropriate for the level of AML Knowledge required for different groups of employees. All employees or personnel designated by the Compliance Officer to perform AML-related responsibilities shall receive training no less frequently than annually. The Compliance Officer shall maintain records of training completion and escalate non-completion to the relevant line management.