Anti-Money Laundering Policy

1. AML/CTF and Sanctions Compliance Policy

SpinBetter is regulated by the Anjouan Gaming Authority and is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance, in accordance with the Anjouan Money Laundering (Prevention) Act 008 of 2005 and European Directives 2005/60/EC and 2018/843.

Scope of the Policy

SpinBetter's policy prohibits and prevents any cases of money laundering and terrorist financing. Money laundering generally consists of three stages: Placement (introduction of illegal cash into financial systems), Layering (separating proceeds from their source through complex transactions), and Integration (reintroducing laundered funds as legitimate).

Risk-Based Approach

SpinBetter classifies customers into three risk categories based on profile, jurisdiction, transaction patterns and payment methods:

Customer Due Diligence (CDD)

SpinBetter applies CDD in the following cases:

• Prior to any payout
• When cumulative deposits reach USD 10,000 (or equivalent)
• When establishing a business relationship (account opening)
• When there is reasonable suspicion of money laundering
• When doubts arise about previously obtained identification documents

Politically Exposed Persons (PEPs)

Accounts of PEPs — natural persons entrusted with prominent public functions (heads of state, ministers, MPs, judges, senior military officers, etc.) — are automatically classified as High Risk and subject to Enhanced Due Diligence. Board of Directors approval is required to establish or continue a business relationship with a PEP.

Sanctions Compliance

SpinBetter screens all customers and transactions against sanction lists administered by OFAC (USA), the European Union, and the United Nations on a daily basis using automated IT solutions. Accounts matching sanctioned individuals or entities are frozen immediately pending investigation.

Prohibited Countries

SpinBetter does not accept registrations from residents of the following countries:

Cuba, Iran, North Korea, Syria, Ukraine (Crimea, Donetsk, Luhansk), Russian Federation, Burma, Côte d'Ivoire, Congo, Eritrea, Iraq, Lebanon, Liberia, Libya, Somalia, Afghanistan, Central African Republic, Ethiopia, Sudan, Venezuela, Yemen, Zimbabwe, Australia, Austria, Belgium, Belize, Bulgaria, Colombia, Comoros, Croatia, Curaçao, Denmark, Estonia, Finland, France, Georgia, Germany, Italy, Netherlands, Panama, Portugal, Romania, Spain, Sri Lanka, United Kingdom, United States, and others.

Suspicious Transactions

SpinBetter's AML Officer monitors for and reports suspicious transactions including but not limited to:

• Transactions inconsistent with the customer's usual patterns
• Large volumes or unusually structured deposits
• Payments to or from high-risk jurisdictions
• Reluctance to provide identification or documentation
• Attempts to deposit via one payment method and withdraw via another

Suspicious Activity Reports (SARs) are submitted to the Anjouan Gaming Board within 24 hours of detection.

Record Keeping

SpinBetter retains all customer identification documents, transaction logs and compliance records for a minimum of five (5) years after the termination of the business relationship, and six (6) years for transaction records related to suspicious activity reports.