1. Preliminary provisions

1.1. This Money Laundering Prevention Policy (hereinafter referred to as the "Policy") describes in more detail the measures, actions and procedures that the Supplier must perform in accordance with the laws of the country of incorporation and the regulatory requirements of the country of incorporation of the Supplier and the countries in which the Supplier operates (hereinafter referred to as the "Rules"), in order to detect and prevent attempts at money laundering and terrorist financing. The Supplier implements the Policy by creating an effective system for the prevention of money laundering and terrorist financing. The basis for the adoption of this Policy is the Rules and Guidelines "Money Laundering: Good Practice Guidelines for the Online Gaming Industry" (hereinafter referred to as the "Recommendations").

1.2. The entities obliged to implement the Policy, and especially the Administration of the Supplier, are obliged to constantly update the Policy in accordance with the Rules and Recommendations and other provisions that regulate the system for the prevention of money laundering and terrorist financing. All employees and divisions of the Supplier are required to implement this Policy.

1.3. "Client" in accordance with this Policy means the following: an individual, a player, a client who has entered all the required information in the registration form and created a gaming account on the Provider's Website https://pandora.casino (hereinafter referred to as the "Website") in order to use the services .

1.4. Money laundering involves the performance of activities that disguise the origin of money or other assets allegedly acquired illegally, including:

1.4.1. Exchange or transfer of money, or any other such property;

1.4.2. Concealment of the true source, location, disposal, movement, ownership or other rights in relation to money or other property;

1.4.3. The acquisition, possession or use of money or other such property.

1.5. Financing of terrorism means the provision or collection of funds, or the attempt to provide or collect funds, legal or illegal, in any way with the intent to use them or in the knowledge that they will be used, in whole or in part, for the commission of terrorist acts by terrorists or terrorist organizations.

1.6. The Provider cooperates with the relevant competent authorities (hereinafter referred to as "Authorities") to help prevent money laundering and terrorist financing. In this Policy, competent authorities means the relevant government authority of the country of incorporation of the Supplier or the authority of the country in which the Supplier provides services, and which is responsible for compliance with the legal and supervisory functions established in the Rules.

2. Regulatory framework

2.1. National regulation

2.1.1. Under the National Anti-Money Laundering Ordinance (1993), money laundering is a criminal offense in Curaçao. Further, other basic national regulations regarding money laundering and terrorist financing are outlined, among others:

a) Criminal Code (Criminal Code) (N.G. 2011, no. 48);
b) National Decree on the provision of information on unusual transactions (N.G. 1996, No. 21) as last amended by N.G. 2009, No. 65 (N.G. 2010, No. 41) (NORUT) collectively all amendments to it and all relevant national decrees containing general measures and regulations of the respective ministries concerning general operations will be made;
c) The National Decree on the Identification of Customers in the Provision of Services (N.G. 1996, No. 23) as last amended by H. 2009, No. 66 (N.G. 2010, No. 40) (NOIS), together with all amendments thereto and all relevant national decrees, containing general measures, and regulations of the respective ministries concerning general operations;
d) National Ordinance containing general measures to implement articles 9, paragraph 2, and 9a, paragraph 2 of the National Ordinance on customer identification in the provision of services. (National Ordinance on General Penalties and Administrative Fines for Service Providers) (N.G. 2010, No. 70);
e) National Decree on Sanctions against Al-Qaeda, the Taliban in Afghanistan, Osama bin Laden, and terrorists to be listed locally (N.G. 2010, No. 93);
f) National Decree on the obligation to report cross-border movements of money N.G. 2002, no. 74) together with all amendments thereto and all relevant national ordinances containing general measures and ministerial ordinances concerning general operations.

2.1.2. These laws and regulations serve as the basis for the procedures supported by the financial sector of Curaçao to detect and prevent the risks of money laundering, terrorist financing or other criminal activity associated with the industry.

2.2. International regulation

2.2.1. As a member of the Financial Action Task Force (www.fatf-gafi.org) and the Caribbean Financial Action Task Force (www.cfatf-gafic.org), Curaçao complies with international standards by regularly implementing these standards into its national legislation.

2.2.2. At the international level, the FATF plays a very important role in combating money laundering, terrorist financing and the proliferation of weapons of mass destruction.

2.2.3. The FATF monitors the progress of its members in implementing the necessary measures, analyzes methods and countermeasures to combat money laundering and terrorist financing, and promotes the adoption and implementation of relevant measures around the world.

2.2.4. In carrying out this activity, the FATF cooperates with other international organizations involved in the fight against money laundering and terrorist financing. A total of 34 countries are direct members of the FATF, and more than 180 countries are connected to the FATF through regional organizations.

3. Measures and actions to prevent money laundering and terrorist financing

3.1. The measures, actions and procedures applied to prevent money laundering and terrorist financing, established by the Policy, provide for:

3.1.1. Assessing the risk of money laundering and terrorist financing;

3.1.2. Implementation of customer due diligence measures;

3.1.3. Appointment of an Anti-Money Laundering Officer (hereinafter “MLRO”);

3.1.4. Regular professional training and education of the Supplier's employees;

3.1.5. Regular internal audits;

3.1.6. Preparation and regular updating of the list of indicators to identify suspicious actions of Clients and suspicious transactions;

3.1.7. Notification and assistance to the authorities on money laundering issues;

3.1.8. Data storage and protection;

3.1.9. Creation of an appropriate information system. Fulfillment of other tasks, obligations in accordance with the Regulations and this Policy.

4. Client Verification Procedure (CDD)

4.1. Supplier checks Customers:
• when establishing business relations with the Client (registration process);
• at the first payment request of the Client;
• if there are doubts about the reliability of previously received data about the Client;
• always, regardless of the size of the transaction, when there are grounds for suspicion of money laundering or terrorist financing in relation to the payment made or the Client.
Registration checks the geographic location of the IP address of the potential Client's computer to ensure that the individual is in an authorized jurisdiction. If the potential Client is not located in the permitted jurisdiction, he/she will not be allowed to proceed with the registration process.

4.2. Client Checks

Client Identification

4.2.1. Collection of mandatory data about the Client.

4.2.1.1. The Client must fill in all required information in the registration form, namely to verify identity, provide address and contact information, including a valid email address, place of residence, relevant payment information. All information must be correct and valid. No person under the age of 18 (eighteen) years may be registered as a Client, and any deposited funds or winnings received by such persons will be transferred to the Authorities.

4.2.1.2. Email confirmation. When the Client registers on the Website, an email is sent to the Client to verify the email address. The Client must click on the link inside the email to verify that this is the Client's real email address.

4.3. Additional check.

4.3.1. The Provider may also conduct additional checks when a Customer is requesting a payout, and sometimes prior to a payout request, if the Provider suspects that the Customer is making any fraudulent payments or that the Customer is engaging in fraudulent activities affecting the outcome of the game, or the payment has been rejected by an automated system to identify suspicious payments.

4.3.2. We ask Clients to send or upload the following documents:
• statement of the bank account from which the funds were deposited;
• photo of the bank card from which the funds were deposited, from both sides. All digits of the number must be covered in the picture, except for the first six and the last four. If the embossing is visible on the back of the card, it must be closed, just like the CVV2 code;
• proof of identity (driver's license/passport/identification code).

4.3.3. The Provider reserves the right to take additional measures and means to verify the identity of Clients when transferring funds to a gaming account on the Website. To verify the Client, the Provider has the right to request proof of identity (including, but not limited to: a copy of the passport / identity card or proof of ownership of payment cards, a utility bill in the name of the Client or a Skype video call). If the Client does not provide or cannot provide such information, the Provider may suspend the gaming account until the Client provides the Provider with this information and / or permanently close the gaming account in case of failure to provide the requested information and / or documents.

4.4. Politically Exposed Person (PEP)

4.4.1. The ability to determine whether a Client is a PEP is entirely dependent on the effective implementation of CDD measures, including the requirements for identification, verification, and ongoing compliance with the requirements set forth in this Policy and Rules, and the effective application of a risk-based approach.

4.4.2. Appropriate risk management systems are used to determine if a potential Client is a PEP. This means that active steps must be taken, such as evaluating Clients based on criteria and risk profiles, checking CDD information, and Supplier's own research to determine if a Client is a PEP.

4.5. Payout

4.5.1. Payments or refunds are made to the same account from which the Client made the initial transfer.

4.6. Cash payments

4.6.1. The Provider may not accept cash payments from Customers and may not pay out winnings in cash. Funds can be received only by one of the methods presented on the Website in the Cashier section.

4.7. Withdrawals

4.7.1. The Client can withdraw any amount less than or equal to the amount of the balance on his gaming account by sending a request to the Provider to withdraw funds from the Client's gaming account. Withdrawal notice must be sent through the Website. The Provider does not accept withdrawal requests by phone or email. Supplier's employees are prohibited from violating this rule.

5. Monitoring client activity

5.1. In order for the Provider to know its Client and the source of origin of the funds received, the Provider must constantly monitor transactions and closely monitor the activity of its Clients, applying the following measures:
• monitoring and verification of compliance of the Client's actions with the expected nature and purpose of opening a gaming account;
• monitoring and verifying that the Client's transactions are within their normal scope by comparing new and previously collected data;
• general monitoring and updating of collected documents and data about Clients.

5.2. In the event that the Provider suspects one of the following:

5.2.1. The Client engages in fraudulent activities, collusion, coordination with other players or any other illegal act related personally to the Client or third parties, and/or uses prohibited types of various programs, methods and/or equipment; or
5.2.2. The client places and withdraws funds from the system, using the system as an intermediate object for transferring money

5.2.3. The supplier investigates each case on an individual basis. Such behavior may be considered suspicious and will be reported to the designated MLRO by the Supplier for further investigation.

5.3. Money Laundering Officer (MLRO)

5.3.1. Employees through the Supplier's internal information channels are required to report to MLRO any suspicious activities of the Client. The application must contain the following information about the Client: full name, address, date of birth, basis and nature of the suspicion and details of the transaction. Employees should report any concerns as soon as possible.

5.3.2. Once a matter is reported to the MLRO, employees must follow further instructions from the MLRO and cease self-investigation of the matter. The MLRO will decide whether disclosure is required to the Authorities and, if necessary, refer the matter to the appropriate competent Authority. Employees must not report an investigation to a Client who is suspected of money laundering, even if they have received confirmation from the MLRO that consent has been given to perform a specific action, as this may be considered an offense, namely “disclosure of private information”.

6. Prevention of money laundering and terrorist financing

6.1. When processing data on the Client's gaming account and performing transactions, the Provider interacts with rating agencies, agencies that detect fraud and prevent money laundering.

6.2. After the registration of the Client, the Provider uses software for the prevention of fraud and duplication of game accounts that compares the data of the Clients, for example, name, address, telephone number and IP address, and if a duplicate is detected, the Provider will restrict access to such a game account of the Client. The client is not able to withdraw funds without providing KYC (Know Your Client) documents.

6.3. The Supplier complies with all relevant anti-money laundering and anti-terrorist financing regulations. The supplier is obliged to report all suspicious transactions to the competent Authority.

6.4. When money laundering or terrorist financing is suspected, the Provider takes all necessary measures and may suspend, block or close the Client's gaming account and block access to all funds, if required in accordance with the Rules.

6.5. By completing the registration process on the Website, the Client confirms and indicates that the Client does not violate the laws of any country or state. In addition, by accepting the provisions of this Policy and/or the Website Conditions, the Customer, who is the owner of the payment card, must confirm that he/she has the right to use the goods and/or services offered on the Website. If the Client uses the Website's services such as games, the Client must provide legally relevant proof that he/she meets the age of majority specified by the laws of the Client's jurisdiction required to use the Website's services.

6.6. When using the Website's services, the Client assumes all responsibility for compliance with the laws of any country or state where this service is used, and confirms that the Provider is not responsible for any illegal or unauthorized violations. By opening a gaming account on the Website, the Client agrees to comply with and comply with the obligations set forth in this Policy and the Terms. The Supplier shall not be liable for any damage that may result from the actions of the Supplier, in the performance of any obligations set out in the Policy or Rules, or any action taken required by the relevant competent Authority.

6.7. Through the Provider's policies and procedures, it ensures the prevention of the use of its technologies for money laundering and terrorist financing, the procedures include additional verifications of identification data and constant monitoring of completed transactions.

6.8. The Supplier works only with Clients who are natural persons. Legal entities are prohibited from having a gaming account on the Provider's Website and withdrawing funds to accounts of legal entities.

6.9. The Supplier uses the list of restricted territories and jurisdictions specified in the Terms to avoid accepting payments and making payments to Customers in territories with an undefined status.

6.10. When the Supplier checks documents, each document is checked separately to ensure that they are not forged (modified with a graphical editor). To verify bank cards, the Supplier's employees must check the data through the BIN database (binbase.net) to make sure that the bank card in the photo provided is indeed issued by the bank. The provider also matches the card country from the BIN database with the address on the utility bill.

6.11. Supplier reserves the right to use additional procedures and means to verify compliance with all Supplier's anti-money laundering and anti-terrorist financing regulations.

6.12. The Supplier is working on the creation of an appropriate information system that will effectively implement the implementation of all measures and actions specified in the Rules and the Policy in order to identify unusual or suspicious transactions based on risk indicators and other factors.

6.13. It is extremely important that the Supplier's employees be absolutely honest, whose incorruptibility would not be in doubt. To achieve this goal, Supplier follows a process whereby all applicants are required to provide curriculum vitae, at least two references, and relevant educational and/or professional certificates, which are reviewed and verified by the Supplier's Human Resources department.