AML Policy

Last Updated: 20 November, 2025

I) Introduction:

Novatrix SRL (“Company”) is an entity that organises special games of chance through the means of electronic communication.

Being licensed by Tobique Gaming Commission, Company is committed to full compliance with legal and regulatory requirements in order to detect and prevent money laundering and other crimes through its services.

Company reports directly to Tobique Gaming Commission in regard to the activity that may be connected to money laundering or predicate offences.

This policy provides an overview of the AML procedures and controls Company adheres to.

II) Company risk profile

Based on our business profile, the risk of money laundering and terrorist financing is minimal, especially compared to financial institutions.

The main reason is that cash is not accepted and only credit cards, e-wallets and other licensed instruments can be used to effect deposits and withdrawals.

Additionally, the average transaction is of a relatively small value. Since only RNG games are offered, the products offered by Company cannot really be used as a tool to launder money. The only money laundering stage that could be of a risk potential for the Company is the layering stage, which is mitigated by various daily screening measures described below.

III) Customer onboarding:

1. In order to register with Company a customer needs to provide the following mandatory details:

First name
Last name
Address
City and postal code
Country
Email address
Date of birth
Password (will be encrypted)
Confirmation of password
Account currency
Mobile phone number

2. Players who are not registered are unable and not allowed to play for real money. Any online transaction, may it be payin or payout, will not be accepted or processed in cash.

3. Once the registration process has been accomplished, customers will receive a welcome email with a link to access their accounts. This procedure aims at verifying the customer’s email address.

4. Customers will not be able to register with a country of residence from the following list:

The Bahamas
Botswana
Cambodia
Ethiopia
Pakistan
Panama
Sri Lanka
Syria
Trinidad and Tobago
Tunisia
Yemen
Saudi Arabia
USA
North Korea
Iran
Hong Kong
China
Panama
Saudi Arabia
From other restricted / sanctioned countries in respect of FATF / UN guidance and regulations.

5. Customers under the age of 18 will be denied to register an account.

IV) Customer Due Diligence:

1. Customer due diligence procedure includes collection and verification of the following documents:

Proof of Identity (“POI”)
Proof of Address (“POA”)
Proof of Payment Account (“POPA”)
Source of Wealth declaration (“SOWD”)

2. Customer due diligence is to be applied to the customer upon the following events:

In case of transactions amounting to USD 10,000 or more, irrespective of whether it is a single transaction or more than one interrelated transaction.
Customer performs small deposits accompanied by unusually large deposits and CDD was not yet carried out.
Customer is observed to attempt to create multiple accounts and CDD was not yet carried out.
Customer account has been inactive for the period over 6 months, is now back active and customer’s IP and transactional activity differ from previously observed activity.

3. Additional due diligence measures may be applied to the customer per sole decision of Company staff, that include:

selfie
selfie with POI
selfie with a special note (example: Hello 'casino name') and/or other special conditions (blinking eye, head/hand turning etc.)
video verification
liveness check
biometrics check

4. Verification document acceptance criterion:

POI: all data (name, date of birth, citizenship) should completely coincide with the data in the Player's details tab. The document should be valid, the photo of the holder, date of birth, date of issue/expiration are a must.
POA: all data (name, address) should completely coincide with the data in the Player's details tab. At the moment of verification, the document should not be older than 90 days from the date of issuance.
POPA: all data should completely coincide with the data in the Payment systems debts tab.

Scanned copies of the documents are not to be accepted for verification purposes.

V) Enhanced Due Diligence and monitoring:

1. Enhanced Due Diligence is applied when additional steps of examination are needed to confirm that customer activities are carried out with legitimate funds.

2. Enhanced Due Diligence procedure includes collection and verification of the following documents:

Source of Wealth
Source of Funds

3. Enhanced Due Diligence is to be triggered at the following events:

Customer is classified as high risk as per Customer Risk Assessment and SOW/SOF are not yet obtained and verified
Customer determined to be a PEP or a relative or a close associate of a PEP

Salary income
Mandatory:
- Bank statement(s) showing receipt of salary (3 months’ minimum)
Additional evidence if required:
- Original or certified copy of a payslip (or bonus payment)
- Letter from employer confirming salary on company letterhead
- Copy of tax return annual statement
Company profits
Mandatory:
- Distribution of dividends certificate
- Certificate of incumbency (if two documents can be uploaded)
Additional evidence if required:
- Latest audited accounts and company bank statement for the past 6 months
- Declaration from a certified accountant confirming dividend, share capital, profits, and beneficial ownership
- Certificate of incumbency
- Copy of invoices showing trading activities of sales and purchases
Sales of shares / investments / liquidation / bonds
Mandatory:
- Bank statement (6 months) showing receipt of funds and investment company name or bond interest
Additional evidence if required:
- Certified investment/savings certificates, contract notes or cash-in statements
Sale of property
Mandatory:
- Copy of contract of sale
- Bank statement showing proceeds of the sale (if two documents can be uploaded)
Additional evidence if required:
- Bank statement showing proceeds of the sale
- Letter from a licensed solicitor or regulated accountant stating property address, date of sale, proceeds received and purchaser’s name
Sale of company
Mandatory:
- Letter detailing company sale signed by a licensed solicitor or regulated accountant
Additional evidence if required:
- Copies of media coverage (if applicable)
Inheritance
Mandatory:
- Copy of the deceased's will
Additional evidence if required:
- Signed letter from a licensed solicitor or estate trustees
- Grant of probate with estate value
Loan
Mandatory:
- Copy of the loan agreement
Additional evidence if required:
- Identification documents of the individual(s) granting the loan
Gift (2 mandatory documents)
Mandatory:
- Letter from donor explaining the reason for the gift and donor’s source of wealth
- Certified identification documents from donor
Additional evidence if required:
- Passport or national ID document
- Bank statement showing origin of the gift
- Selfie of donor holding their ID
Fixed deposit / Savings
Mandatory:
- Savings statement
Additional evidence if required:
- Evidence of account start (letter or first statement)
- Evidence showing origin of the savings
Gambling / gaming winnings (2 documents)
- Receipt of winnings
- Bank statement (6 months) showing origin of initially deposited funds
Pension
Mandatory:
- Bank statement (6 months) showing pension payments and name of pension fund
Additional evidence if required:
- Pension statement confirming release of pension
Mining
Mandatory:
- Ledger of cryptocurrency mined
- Wallet address and transaction hash for delivery of mined crypto

Payout management

Account check
- Company account owner must match bank account/credit card owner
- All account information must be complete and authentic
- Withdrawals made to same source where funds originated (where possible)
Wagering check
- Deposits must be used for stakes
- If not used, payout must be denied
Activity check
- Funds in gaming wallet can only be used for gaming
- Suspicious activity may lead to temporary suspension
Collusion check
- Staff monitors origins of winnings
- If suspected p2p fund transfers via strategic betting, payouts frozen until review

VII) Politically Exposed Persons (PEPs) and sanctioned individuals

A Politically Exposed Person is someone who has been entrusted with a prominent public function, such as a senior political figure. Individuals closely related to this person, such as immediate family members and close associates, are also considered as PEPs.

PEPs are classified as a money laundering risk since they may be exposed to property generated by corruption and bribery because of their position.

Novatrix SRL carries out manual screening of customers through OSINT (open-source intelligence) and the following links are “at minimum” considered for manual screening:
https://dilisense.com
http://everypolitician.org
https://littlesis.org/

Upon learning that the customer might be a PEP, the following measures are applied:

Customer is asked to provide POI, POA and a selfie (if not obtained previously)
Novatrix SRL AML Compliance unit is to conduct a review of the account to determine if customer is a true PEP
If customer is determined to be a true PEP:
- EDD measures are applied
- Approval for continuance of business relationship with the customer is requested from the senior management
- If it’s decided to continue relationship with the customer, monitoring measures are applied

New customers are screened for their PEP status within 30 days from the start of CDD procedure.

Sanctioned individuals are classified as a money laundering risk since they may be exposed to property that has been generated by corruption and bribery because of their position.

Novatrix SRL carries out manual screening of customers through OSINT (open-source intelligence) and the following important links are “at minimum” considered for manual screening:

Consolidated list of EU sanctioned persons, groups and entities:

Should a customer be flagged as potentially being a person listed on a financial sanction list:

The client shall be immediately frozen, and all funds shall be also frozen
Internal Report form is to be immediately sent to the MLRO

New customers are screened for SL status within 30 days from the start of CDD procedure.
Active customers are reviewed on a monthly basis.

Once the appropriate investigation is carried out, and it is confirmed that the customer is likely to be a person subject to financial sanctions, a report will be submitted by the MLRO to the appropriate authority.

VIII) MLRO

The MLRO is the first person to notify when the suspicion of money laundering activities evolves.

The MLRO is appointed by senior management and is trained for money laundering risk factors that the company faces. When appointed, authorities must be notified. The main duties of the MLRO are:

a) Keeping up to date with AML/CTF legislations.

b) Making sure that implementation takes place in line with the internal procedures.

c) Making sure that anti-money laundering training is periodically given to staff.

d) Recording and updating risk assessments.

e) To receive and evaluate internal reports.

f) To advise, guide and assist.

g) To keep statistical data.

h) Filing STRs to the Tobique Gaming Commission.

All incidents involving a suspicious person or transaction in terms of money laundering or funding terrorism need to be reported to the Tobique Gaming Commission by the MLRO within 5 working days.

In the Suspicious Transaction Report, the MLRO must give a clear and complete explanation of the suspicious behaviour including also customer identification and transaction records.

IX) Record keeping

The following records are kept:

Identification Records:
Copy of ID-document;
Copy of bank/credit statement;
References.
Transaction Record Details:
Deposit/withdrawal method used;
ID of person performing the transaction;
Destination of funds;
The authorisation of credit card payments performed by our clearing companies;
Volume of transactions.

The records are kept for 5 years from the end of the business relationship in accordance to the directive.

X) Staff training

Periodical training ensures that the staff is aware and compliant with the anti-money laundering regulatory requirements.

XI) Employee hiring

For all new employees hired by Company, Company will conduct a thorough background check and various due diligence documents will be collected for reference (birth certificate, clear police conduct, etc.). Interviews are carried out and requested references are checked whenever available.

It is a company policy that all new employees are also given training with regards to the anti-money laundering policy and the internal procedures used to mitigate this risk.