AML / KYC Policy of SGG Software Limitada

For Cash Deposits and Cash Withdraws.

(AMLI Anti-Money-Laundering policy of www.wwcd26.com.)

Introduction: www.wwcd26.com is operated by SGG Software Limitada having its office at Provincia de Puntarenas 06, Canton 11, Garabito, Jaco, 61101, Costa Rica. Company Registration number 3-102-913283. www.wwcd26.com is licensed by the Anjouan Gaming Authority with license no. ALSI-202410017-FI1.

Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on www.wwcd26.com for that a three-step account verification is done in order to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.

www.wwcd26.com and SGG Software Limitada expressly prohibit and disallow the use of www.wwcd26.com and all its products for any form of illicit activities, including but not limited to, Money Laundering, Terrorist Financing, Sanctions Violations, all these in line with national AML and other Laws, Regulations, International Norms and Best Practices. For this reason, www.wwcd26.com puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means, and is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes. www.wwcd26.com is and will be regularly monitoring updates and will initiate all necessary actions as deemed appropriate to reflect in its policies, systems, programs and operation any and all future amendments in AML Laws and Regulations.

The AML program of www.wwcd26.com is designed to be compliant with :

• EU : 5th EU Anti-Money Laundering Directive (Directive (EU) 2018/843);
• EU : 4th AML Directive (Directive (EU) 2015/849);
• EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”;
• EU : “Regulation 2015/847 on information accompanying transfers of funds”;
• EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods;
• EU : General Data Protection Regulation (GDPR), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data;
• BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash;
• Any other Local Laws and Regulations in each Country and/or State www.wwcd26.com operates and is available in.

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 companies 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 in points before.

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 www.wwcd26.com:

In accordance with the AML legislation, www.wwcd26.com has appointed the “highest level” for the prevention of ML: The full management of SGG Software Limitada are in charge, and has implemented in its operations specialized software and technologies in order to better monitor, track, detect, assess risks, and combat any form of illicit activities, including but not limited to, Money Laundering, Terrorist Financing, Sanctions Violations, all these in line with national AML and other Laws, Regulations, International Norms and Best Practices.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is appointed and is in charge of the enforcement of the AML policy and procedures within the System. The Anti Money Laundering Compliance Officer’s duties also consist of the following, amongst other duties:

• Developing AML initiatives;
• Revising AML policies;
• Assessing new regulatory requirements;
• Overseeing compliance with AML regulations;
• Monitoring and Investigating suspicious and/or unusual activities;
• Assessment of Risks.

The AMLCO and SGG Software Limitada conduct on a regular basis training programs, by which all employees, including employees of www.wwcd26.com and SGG Software Limitada, are trained on KYC procedures, including amongst others:

• Identifying fraudulent documentation;
• Recognizing red flags for ML/TF activities;
• Reporting obligations to the relevant authorities.

The AMLCO is placed under the direct responsibility of the general Management.

AML Policy Changes and Implementation Requirements:

Each major change of www.wwcd26.com AML policy is subject to be approval by the general management of SGG Software Limitada and the Anti money laundering compliance officer.

Customer Identification and Verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture, to secure their privacy.

Please note that all four corners of the ID have to be visible in the same image and all details have to be clearly readable besides the named above. We might ask for all details if necessary.

An employee and/or the AMLCO may do additional checks, if necessary, based on the situation.

Proof of Address:

Proof of address will be done via two different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to submit proof manually.

A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proofs your state of residence.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible, and all text is readable.

For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.

An employee and/or the AMLCO may do additional checks, if necessary, based on the situation.

Source of Funds

If a user/customer deposits over five thousand euro and/or the user/customer was classified based on risk assessment as a high-risk user/customer, either due to geographic location, user activity or user type (Politically Exposed Persons or individuals with adverse media mentions), there is a process of understandings the source of wealth (SOW) and source of funds (SOF) of the user/customer.

Examples of SOW are:

• Ownership of business
• Employment
• Inheritance
• Investment
• Family

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee and/or the AMLCO may ask for additional documents or proof.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this, and if the user is classified as high-risk. An email will be sent to them manually to go through the above and see more information on the website itself.

www.wwcd26.com also asks for a bank wire/credit card to further ensure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

Basic Document for Step One:

The basic document will be accessible via the setting page on www.wwcd26.com. Every user has to fill out the following information’s:

• First Name
• Last Name
• Date to Birth (to confirm minimum legal age)
• Nationality
• Country of Usual Residence
• Full Residential Address
• Contact Information (Email and Phone Number)
• Payment Information (E.g. bank account or e-wallet details)

The document will be saved and created by an AI, an employee and/or the AMLCO may do additional checks if necessary based on the situation.

Risk Management

In order to deal with the different risks and different states of wealth in different regions on the earth www.wwcd26.com will categorize every nation in three different regions of risk.

Region one: Low risk:

For every nation from the region one the three-step verification is done as described earlier.

Region two: Medium risk:

For every nation from the region two the three-step verification will be done at lower deposit, withdraw and tip amounts. Step one will be done as usually. Step two will be done after depositing 1000$ (one thousand Dollars), withdrawing 1000$ (one thousand Dollars) or tipping another user/customer 500$ (five hundred Dollars.) Step three will be done after depositing 2500$ (two thousand five hundred Dollars), withdrawing 2500$ (two thousand five hundred Dollars) or tipping another user/customer 1000$ (one thousand Dollars). Also, users from a low risk region that change crypto currency in any other currency will be treated like user/customers from a medium risk region.

Region three: High risk:

Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.

Additional Measurements

In addition, an AI which is overseen by the AMLCO will look for any unusual behaviour and report it right away to an employee of www.wwcd26.com and the AMLCO.

According to the results by the AI, physical employees and/or the AMLCO will recheck all results and may proceed with redoing the checks or do additional checks themselves according to the situation.

In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behaviour like: Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account to for Deposit and Withdraw, nationality changes, currency changes, residential address changes, behaviour and activity changes as well as checks, if an account is used by it´s original owner.

Also, a User has to use the same method for Withdrawal as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.

Enterprise-Wide Risk Assessment

As part of its risk-based approach, www.wwcd26.com has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to www.wwcd26.com and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.

The identification of AML risk categories is based on www.wwcd26.com understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.

The EWRA is yearly reassessed.

Ongoing Transaction Monitoring

AMLCO ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

• 1) The first Line of Control:
• www.wwcd26.com works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto www.wwcd26.com from taking place without proper execution of KYC procedures onto the potential customer.
• 2) The second Line of Control:
• www.wwcd26.com makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:
• Requests for the execution of financial transactions on the account;
• Requests in relation to means of payment or services on the account;
• Also, the three-step verification with adjusted risk management should provide all necessary information’s about all costumers of www.wwcd26.com at all time.
• Also, all transactions must be overseen by employees, overwatched by the AMLCO who is overwatched by the general management.
• The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.
• Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.
• These checks will be done by an automated System, while an Employee and/or the AMLCO crosschecks them for additional security.
• The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).
• Any www.wwcd26.com staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.
• 3) The third Line of Control:
• As a last line of defence against AML www.wwcd26.com and/or the AMLCO will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.
• If fraud or Money Laundering is found the authorities will be informed.

Reporting of Suspicious Transactions on www.wwcd26.com

In its internal procedures, www.wwcd26.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, the AML team:

• will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
• will decide whether or not it is necessary to terminate the business relations with the customer.

Procedures

The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of www.wwcd26.com.

Record keeping

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

These data will be safely, encrypted stored offline and online.

All the above is done in light of the www.wwcd26.com's and SGG Software Limitada‘s legal obligations to combat and not allow any form of illicit activities, including but not limited to, Money Laundering, Terrorist Financing, Sanctions Violations, as well as the relevant reporting obligations.

Training:

www.wwcd26.com physical employees will make manual controls on a risk based approve for which they get special training.

The training and awareness program is reflected by its usage:

• A mandatory AML training program in accordance with the latest regulatory evolutions, for all in touch with finances
• Academic AML learning sessions for all new employees
• The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML-specialist working in SGG Software Limitada AML team.

In addition to the above, The AMLCO and SGG Software Limitada conduct on a regular basis training programs, by which all employees, including employees of www.wwcd26.com and SSG Software Limitada, are trained on KYC procedures, including amongst others:

• Identifying fraudulent documentation;
• Recognizing red flags for ML/TF activities;
• Reporting obligations to the relevant authorities.

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security:

All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.

www.wwcd26.com will follow all guidelines and rules of the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.