Cryptocurrency Acceptance Policy

The adoption of cryptocurrencies in the gaming industry represents a significant innovation, offering customers an alternative payment method that is decentralized, secure, and convenient. However, cryptocurrencies also introduce unique risks that require comprehensive oversight.

This policy is designed to regulate the acceptance, use, and monitoring of cryptocurrencies within the company's gaming operations. It ensures compliance with the Tobique Gaming Commission's guidelines, addresses critical risks such as money laundering, fraud, and underage gambling, and promotes responsible gaming practices.

Key objectives of the Policy:

• Ensure compliance with regulatory requirements for cryptocurrency transactions.
• Prevent underage gaming and ensure robust identity verification processes.
• Prohibit the exchange of cryptocurrencies for FIAT currency through company platforms.
• Align cryptocurrency operations with the company's AML & KYC and Payment Policies.

For the purposes of this policy, the following terms are defined:

“Cryptocurrency” means digital or virtual currency secured by cryptography and operating on blockchain technology, enabling secure, decentralized transactions.

“FIAT” means traditional government-issued currency recognized as legal tender, such as USD, EUR, or GBP.

“AML”, “CFT” Anti-Money Laundering and Counter Terrorist Financing procedures designed to prevent the illegal use of financial systems for activities such as money laundering and terrorism financing.

“KYC” Know Your Customer procedures implemented to verify the identity and intent of customers, ensuring compliance and mitigating risk.

3.1 Permissible Use of Cryptocurrencies

Cryptocurrencies are accepted exclusively as a payment method for deposits used to place wagers within the company's platform. Customers are prohibited from using the company's platform to exchange cryptocurrencies for FIAT or vice versa. Withdrawals must be processed in the same cryptocurrency used for deposits, with no intermediate conversion into FIAT.

3.2 Transparency and Limits

Customers must be informed of any fees, processing times, and transaction limits related to the use of cryptocurrencies. The company will set clear limits on maximum and minimum deposits and withdrawals in cryptocurrency to mitigate risks.

3.3 Risk-Based Monitoring

Transactions involving cryptocurrencies must be continuously monitored to identify unusual patterns or high-risk activities as provided in AML & KYC Policy, such as:

• Large or frequent deposits and withdrawals.
• Suspicious geographical locations or IP inconsistencies.

4.1 Alignment with AML & KYC Standards

All cryptocurrency transactions must comply with the company's AML Policy and applicable regulations to prevent money laundering and other illicit activities. The company will utilize advanced transaction monitoring tools to identify and report suspicious activities to relevant authorities. Cryptocurrency wallets used for deposits must be verified to confirm ownership and legitimacy before use. Customers engaging in cryptocurrency transactions must comply with KYC requirements.

4.2 Standardization of Payment Processes

Cryptocurrency payments are subject to the same procedural standards outlined in the company's Payment Policy, including transaction authorization, data security, and reconciliation.

4.3 Wallet Verification

Cryptocurrency wallet ownership must be verified as part of the payment process to ensure the legitimacy of transactions.

4.4 Transparency and Customer Communication

Customers must receive clear and transparent information regarding:

• Transaction fees applicable to cryptocurrency deposits and withdrawals.
• Minimum and maximum limits for cryptocurrency transactions.
• Estimated processing times for deposits and withdrawals.

4.5 Alignment with Withdrawal Rules

No withdrawals from cryptocurrency-based wagers are permitted unless:

• The customer's age and identity have been fully verified.
• Any flagged activities have been resolved and cleared.

5.1 Registration and Age Verification

The company strictly enforces age verification measures to prevent individuals under 18 from using cryptocurrency for deposits, wagers, or withdrawals. This policy ensures compliance with regulatory requirements and supports responsible gaming practices.

Customers wishing to use cryptocurrency must:

• Confirm they are over 18 by checking an age affirmation box and providing their date of birth during registration.
• Submit valid identity documents, such as a passport or driver's license, to verify their age and identity if required.

Verification must be completed within 30 days of registration or before:

• Cumulative deposits in cryptocurrency exceed EUR 2,000 (or equivalent).
• The first withdrawal is processed.

5.2 Restrictions During Age Verification

Until verification is complete customers may deposit cryptocurrency and participate in gaming but cannot withdraw funds or winnings. If the customer is found to be underage, all deposits will be refunded, and any winnings forfeited to the relevant authority. The account will be suspended immediately. Cryptocurrency features are carefully designed to align with this requirement.

5.3 Enforcement

All employees and providers involved in cryptocurrency transactions are trained to ensure compliance with age verification procedures. Accounts found to belong to underage individuals are suspended, and access to cryptocurrency services is immediately revoked.

6.1 General

The company enforces a rigorous identity verification process to ensure compliance with regulatory standards, mitigate risks such as money laundering and identity fraud, and maintain the integrity of cryptocurrency transactions. This identity verification framework operates in conjunction with the company's AML & KYC Policy, which ensures a unified and detailed approach to assessing customer risk, conducting enhanced due diligence, and reporting suspicious activity.

6.2 Identity Verification Process

At the time of registration, the company begins the process of verifying the identity of every customer. Customers are required to provide accurate registration details, including their full name, date of birth, and address. Wherever possible, the company uses third-party electronic verification services to validate the provided information and identify errors or attempts to provide false data. Verification must be completed within 30 days of registration, before cumulative cryptocurrency deposits exceed EUR 2,000 (or equivalent), or before the first withdrawal is requested, whichever comes first.

In cases where electronic verification services are unavailable or insufficient, the company employs additional methods to validate customer identity. This includes cross-checking technical and financial data, such as IP addresses, payment methods, and device information, to ensure consistency with the submitted details. Customers may also be required to submit government-issued identification documents, such as a passport or driver's license, to complete the process.

If discrepancies, missing information, or inconsistencies are identified, the company takes a risk-based approach to resolve the issues. Accounts with significant discrepancies are flagged for further review, and if deemed high risk, additional enhanced due diligence measures are applied.

6.3 Restrictions During Verification

While the verification process is ongoing, customers can deposit cryptocurrency and participate in gaming but cannot withdraw funds. If significant inconsistencies remain unresolved, account activity may be restricted, and the customer may be required to provide further documentation to verify their identity.

7.1 General

The company is committed to ensuring that the policy is effectively implemented and consistently enforced across all relevant operations. This section provides a detailed framework for embedding the policy into the organization's daily activities, managing compliance, and maintaining high standards of integrity and security in cryptocurrency transactions.

7.2 Policy Implementation

The company ensures that all processes and systems related to cryptocurrency acceptance align with the policy. This involves clear communication, integration into operational workflows, and ongoing evaluation of compliance effectiveness.

The policy is integrated into all relevant systems, including registration, payment processing, and transaction monitoring. Automated controls and checks, such as identity verification and transaction limits, are embedded to ensure adherence to the policy at every stage of customer interaction.

The cryptocurrency policy is maintained as part of the company's core operational policies and made readily accessible to employees. Periodic reviews and updates ensure that the policy remains current with evolving regulatory requirements and industry best practices.

Implementation involves coordination among multiple departments, including compliance, customer service, IT, and finance. Each department has specific responsibilities for upholding the policy, and cross-departmental collaboration ensures comprehensive enforcement.

7.3 Training and Awareness

Training plays a critical role in the successful implementation of the cryptocurrency policy. Employees at all levels are equipped with the knowledge and skills needed to apply the policy effectively.

All new employees, especially those in compliance, customer service, and payment processing roles, receive in-depth training on the cryptocurrency policy as part of their onboarding process. Regular training sessions are conducted to update employees on changes to regulatory requirements, advancements in cryptocurrency technologies, and emerging risks.

Employees in technical and compliance roles receive advanced training on tools and systems used for monitoring cryptocurrency transactions, risk assessment, and reporting to regulatory authorities. Employees may be required to pass assessments to certify their understanding of the policy. Training participation and outcomes are documented to ensure accountability and continuous improvement.

7.4 Enforcement

The company enforces the cryptocurrency policy through a combination of automated systems, manual reviews, and regular audits. This ensures that any breaches or non-compliance are promptly identified and addressed.

Internal and external audits are conducted periodically to evaluate the effectiveness of the policy and its enforcement. These audits include reviewing transaction records, compliance logs, and employee training documentation.

7.5 Continuous Improvement

The company is committed to continuously improving its cryptocurrency policy and enforcement mechanisms. Feedback from employees, regulatory updates, and advancements in technology are used to enhance policy implementation. Regularly scheduled reviews ensure that the policy remains effective, relevant, and aligned with industry best practices.