1 ALD PROCEDURES

1.1 • AML Detection

Withdrawals of amounts that have been turned over at least once can be requested. This protects Oroplay from abuse for money laundering purposes and also protects our free deposit system that can be exploited to our disadvantage. All withdrawal requests are initially verified by monitoring all withdrawal requests and flagging those that are suspicious based on any suspected fraudulent history. Each customer can only deposit a maximum of $1,200 per week. Players wishing to deposit more funds than the established initial limit will have to go through a more thorough verification process, including voice confirmation, and will be periodically monitored for gaming activity. Additionally, these players will be highlighted/tagged in our software back office, making them easier to identify, track and control.

In addition to the system's automatic controls, all customer transactions/accounts are checked for multiple accounts, people who may have been blacklisted by any relevant organization or company, transaction and betting behavior, amounts moved, deposit methods/ withdrawal, and other things that may lead to any suspicious activity based on the long-term experience of our related employees.

If no such issue is found, this finding will be forwarded to our accounting department for a final check and so that final payment can be made. This process is completed within one business day.

1.2 • ALD Reports

In any case where Oroplay identifies and verifies that any form of anti-money laundering is occurring or attempted, such activity will be reported to the Curaçao Gaming Authorities as necessary.

2 KYC PROCEDURES

2.1 Player Registration

To open an account with Oroplay via the web portal, the user must first complete the registration process and deposit some funds, with which they can then start playing. The registration details that all new customers must provide include first and last name, address, country of residence, date of birth, email address and account currency. All customers must be at least 18 years old and may only have one player account in their name as specified in the Curacao Remote Gaming Regulations. Therefore, no minor can play on the Oroplay website. Users without a registered player account will not be able to play.

2.2 • Due diligence

Players from restricted countries/states cannot register due to strict non-gambling regulations in their country. These countries are also included in the Terms and Conditions so players can be aware of these restrictions before registering. Before any withdrawal, the customer will be asked for the following documentation: proof of bank account, credit card, utility bill (not older than 3 months) and ID. This documentation must be verified before approving the withdrawal. Additionally, voice and phone number checks will be carried out on high-volume customers and customers with serious irregularities in their betting behavior. All documentation will be formally requested via email for both due diligence scenarios and will be archived in accordance with the company's internal procedures.

After an accumulated withdrawal of €2,300 or more by any customer, you will be required to send proof of identity in the form of scanned documents, such as ID scans or passport, to confirm your identity and, in specific cases, a recent invoice to confirm your adress.

Accumulated withdrawals of €2,300 or more will not be processed until these documents are submitted by the customer requesting the withdrawal and are verified and confirmed by the Fraud Management team.

Every time a new customer deposits money and starts playing or betting on the Oroplay website, our system will check and monitor their transactions and betting behavior on a daily basis. This procedure allows us to analyze how each individual customer uses the products on our websites, allowing us to categorize players and establish individual limits based on their betting patterns.

2.3 • Email verification

When a new account is created, a verification link is sent to the email address specified during the registration process. When the user clicks on the link, the account is created successfully. Only at this point can the player deposit money and start placing bets.