Know Your Customer / Anti-Money Laundering Policies

A. Customer Due Diligence.

Betswap.gg has a risk based CDD to enable Betswap to understand the nature and purpose of the user relationship to the Betswap.gg platform in order to develop a customer risk profile. In order to do so, Betswap collects certain documentary and non-documentary information at account-opening commensurate with the nature of the type account and services that Betswap offers. Betswap maintains different CDD for different accounts and services.

For instance, the CDD requires users to go through Betswap’s customer identification program (“CIP”).

The CIP consists of procedures for:

• Collecting baseline (e.g., wallet address, email address) information at account creation through

  Betswap’s user onboarding portal;

• Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user’s account;

• Maintaining records of the information used to identify the user; and

• Determining if a user appears on any list of known or suspected terrorists or terrorist organisations provided to the financial institutions based on the above information.

The above steps are operationalised using the following measures:

• Identity and Age Verification. A third-party service provider will support’s Betswap’s ability to determine the legitimacy of the identification information other KYC materials or information provided and will confirm that the user is permissible. The service provider also will confirm that the user does not appear to be located in a comprehensively-sanctioned or otherwise prohibited jurisdiction and will search global sanctions lists to confirm that the user does not appear thereon using onboarding information such as wallet addresses.

• Customer Information. Betswap will collect details on each user to form a reasonable belief that

  Betswap knows the identity of its users commensurate with the user’s risk profile. For instance,

  Betswap may collect such details as the wallet address, name, address, country, date of birth, or postal code (collectively, “KYC Information”). Betswap will collect any of the above KYC

  Information prior to issuing a Betswap funding address (e.g., QR code) to users. Betswap does not presently allow users who are non-natural persons.Betswap may, at its own description, rely on the performance by another institution of some or all of the elements of our CIP.

• Geo-blocking for Prohibited Jurisdictions. Betswap will require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.

• Contractual Prohibitions on Users Onboarding from Prohibited Jurisdictions. Users are notified at onboarding that Betswap does not offer services in restricted jurisdictions. Betswap’s policy on restricting user activity stems from a combination of its risk, fraud prevention, and AML standards, as well as any assessments associated with the permissibility of its services in certain jurisdictions.

B. Enhanced Due Diligence and Ongoing Monitoring

Betswap performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, Betswap has implemented a set of red flag indicators that help it determine such behaviours and require further action from Betswap in assessing the customer information.

Whenever one of those red flags is triggered, the user account will be suspended and Betswap will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of:

• Full legal name;

• Country of citizenship;

• Permanent Address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office or other physical location);

• Identification number (either a taxpayer identification number, or, if unavailable, a passport number and country of issuance, alien identification card number or number and country of issuance of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);

• Identification Document; and

• Source of Funds and Source of Wealth.

Betswap may use third party service provider to verify any of the above information as determined to establish a reasonable basis to know the true identity of the user where the user’s activity warrants such action.

AML Compliance Officer