Victory Industry B.V.
Risk & Fraud & AML/CFT Policies & Procedures

Version 1.1

Date created: January 10th, 2022

Purpose of Document: To outline the Anti-fraud & AML policies and procedures to be followed forthe detection and limitation of fraud & ML - CFT.

Conformity: Financial Services Identification Act. & Unusual Transactions Act GD of July 5, 2010, no. 10/2386 of Netherlands Antilles

CONTENTS

1. Anti-money Laundering (AML) & Countering the Financing of Terrorism(CFT) 1.1 Risk Assessment - evaluating the potential risks
1.2 Identification of suspicious activities/areas
1.3 Procedures
1.4 Real Life Examples of Frauds
1.5 Training
1.6 Operators Due diligence and Conflict of interests
2. Complaints and disputes
2.1 Procedure example
2.2 Successor’s control
2.3 Handling of permanent self-exclusions 2.4 Reactivation of self-suspended accounts

1. Anti-money Laundering (AML) & Countering the Financing of Terrorism(CFT)

Money laundering is the process of concealing or disguising the nature, location, source, ownership or control of illegally obtained money while transforming them into legitimate assets.

Financing of terrorism is defined as any form of financial support towards terrorist groups or those who encourage them. The source of funds is irrelevant.

Money laundering is an illegal activity and it involves three phases:

(ii) (iii) (iv)

Placement Layering Integration

Placement
The first time funds derived from criminal activities are used in a legitimate money transfer is

referred toas “Placement”.
- Layering
Creating a series of transactions to hide the first transaction is referred to as “Layering”. - Integration
The return of funds to legitimate activities is referred to as “Integration”.

Out of the three phases, the placement phase poses the greatest risk to our business, since:

• - Transactions may be structured to avoid record-keeping or reporting thresholds.
• - False identification and/or information may be provided. This definition covers our typeof activity among a wide range of other.

1.1 Risk Assessment - evaluating the potential risks
In order to be able to evaluate and assess the potential risks, the following aspects must be thoroughly

examined:

• - Money entry and exit point (authorized R&F and Finance employees)
• - KYC verification
• - Deposit patterns
• - Gaming volume
• - Double accounts
• - Characteristics of the games played
• - Player’s playing pattern
• - Customer Risk – Traders and R&F segmentation
• - Country Risk
• - Syndication
• - Bonus Abuse

1.2 Identification of suspicious activities/areas

A firm eye must always be kept for any of the following indications:

• - Frequent max limit deposits
• - Frequent and high volume deposits with “Nearly anonymous PSP”, such as Paysafe card
• - Frequent variation in the depositing methods
• - Minimal gaming activity despite of a the cash balance available in the account(s)
• - High stakes wagered on unreliable or secondary leagues
• - Unusual High stakes
• - High stakes with very low profitability
• - Withdrawal request in different method or holder accounts is notallowed
• - Repetitive & identical bets placed on a given event for set limits avoidance
• - Chip dumbing in Poker
• - Multiple accounts
• - Common registration or deposit IPs
• - Successors Control
• - Long Term Money laundering
  
  
  
  1.3 Procedures
  In order to limit and manage the evolving risks, the following procedures must be applied andfollowed:

1) All procedures followed must be in compliance with GD no. 10/2386 of July 5, 2010, of Netherlands Antilles and related and Directives

2) Only Fraud and Finance department employees must perform Fraud control and execute payments.

3) Withdrawals must be executed on the same payment method or account that was previously used by the user to deposit.

- In case of a credit card payment, the withdrawal must be executed always on the same credit card and not on any credit card.

- In case that the credit card of a user has expired, the user must make a minimal deposit with his replacement card, provide the copy of the credit card and, after the verification is complete, we execute the payment on this card.

- The proof of payment for all other payment methods, must always display the account holder’s email or full name as well as the transaction/deposit made to our company including the transaction date and amount.

- If multiple depositing methods have been used by a given user, we always give priority on executing the payment(s) on the user’s credit card(s). The withdrawals should keep on being executed on the credit card(s) up until the point when the withdrawal amount is equal to the sum of the deposits made within the last 6 months.

4) All customers, independently of the deposit amount, must verify their account by submitting full KYCs upon requested and anyway before executing any withdrawal request.

5) If player doesn't provide requested documents within 14 days after the request his account would been deactivated, all players fund would been confiscated

6) The process of identifying and blocking the users that have not verified their accounts is flagged in the back-office system. In case of any technical malfunction, the process will be fulfilled by the R&F controllers (by extracting dailydeposit
reports and manually checking relevant user accounts’ KYC).

7) With “Full KYCs”, we mean:

a. ID proof; a photo of the identity card or the passport or drivinglicense.

b. Proof of payment; in the case of credit cards, it’s the photo of the front side of the card with the last 4 digits visible. In case of electronic wallets a screenshot with the transaction made to Victory Industry B.V. shall be visible.

c. Proof of residence; any bank statement or utility bill not older than 3months.
KYC documents can be directly uploaded by the user once logged in his/her account. In case for any reason, the KYC documents were sent via email, R&F operator must upload them in the users’ account and then immediately delete the attachments from the email where documents were

attached.

6a) R&F operator will make an initial check for the identification of fake or manipulated documents, cross check the information registered in the users’ account and confirm the authenticity of the payment solution used. Then depositing and playing patterns will be reviewed and then approve verification if no conflicts were found.

1. 8) Customers need to be at least 18 years old, in order to be able to register.
2. 9) Checking for the Payment method’s expiration date (if applicable). As mentioned in point

2, if the credit card of a user is expired, we request user to submit a minimal deposit with the new card, we verify and then pay on this card.

10) Users can only withdraw funds using the same payment details that were used for depositing funds into your account. If the depositing method does not offer the possibility of withdrawals, then the withdrawal must be processed on the customer’s verified Bank account.

11) Long term Money Laundering must be checked on players who are moving big amounts of money and they accept low losses - they opt of frequent withdrawals of

the entire balance and then again shortly they come with high deposits. In these cases on we must run a verification of alternative payment methods used and if so, the case must be reported to the Head of Department for further investigation and actions needed.

12) If AML or CFT action or bet for illegal purposes is verified the account must be blocked, the customer has to be notified that his/her account is temporarily closed for “Routine Controls” and then notify the Head of R&F department, who will act according to the legal framework and always in contact with our Legal Department. Moreover suspicious activities will be reported according to the directives of the Government of N.A

Victory Industry B.V. may suspend or close a player's game account, by immediately notifying the player, in two different situations:

(i) (ii)

if the player breaches the legal provisions, or
if richy.casino’ game rules are breached.

If Victory Industry B.V. decides to suspend the transfer from or into the player’s account in any situation provided above, Victory Industry B.V. will communicate to the player a justified decision for the case customer may want to proceed to any claim in N.Aauthorities.

1.4 Real Life Examples of Frauds

1) Stolen (or vouchers which are product of fraudulent activity in other businesses) of Paysafe card vouchers can be deposited regularly, often in discrete amounts as for example 1000 euro/day and the player place bets in minimum odds, like 1.05 or 1.15 or so and after few wagers or after turned over a bit more that once his total deposit he request withdrawal to his bank account, since there isn’t any withdrawal method available for Paysafe card.

The identification starts from the wagering pattern

2) Syndications of players having information on fixed games are presenting as individuals with “borrowed identities” depositing via e-wallets (Skrill-Neteller etc) where they have stated multiple email accounts try to exploit our offer.
The identification starts from the gameplay pattern

3) Same as above without having info on fixed games but they try to exploit the bonus offer playing like “Pyramid” until the last get mathematical advantage. The identification starts from the contradicting wagering pattern and the deposit/bonus similarities.

4) Classic Chip dumping in Poker, where person lose in purpose in order to pass amount of money in other players belonging to other companies participating in the same Poker network.

The identification occurs in special department of the Poker provider and continue in our Fraud department.

1.5 Training

All Fraud, Finance and Customer-Support departments’ operators are obliged to have knowledge of all Victory Industry B.V. AML & CFT policies and must attend the training sessions help at least once a year and keep up- to-date with any policy or procedure changes.

If for any reason, an operator is not able to attend on the specified dates, then he is responsible to read the respective documentation and will be subject to an examination of his comprehension without prior notice.

1.6 Operators Due diligence and Conflict of interests

RF operators have a standard contract as well as salary level, before they take the R&F position they must pass through another position in the company until they prove reliability.

14) Reporting is a tool for controlling the operational behavior. Each single operator must report all payments made by the end of the shift mentioning payments issues, the number and the amounts of the outgoing payments. The report is send to the head of thedepartment as well as to the management daily

Head of department approves any action taken outside the routine procedures.

2. Complaints and disputes

In the event of a dispute, it is advisable that the user lodges a complaint with Victory Industry B.V. customer service using the contact details in the Website. The parties should do their utmost to reach an amicable settlement within a reasonable time. The client may also file a complaint to N.A Authorities - info at https://www.curacao-egaming.com/ - complaint must contain clear and unequivocal information about the complainant's identity and shall give all the relevant details that gave rise to the complaint.

If a user has a complaint, he/she can:

1. Email customer support at [email protected] Victory Industry B.V. will use best efforts to resolve a reported matter promptly.
2. If for some reason the user is not satisfied with the resolution of the complaint by the

Company, he should lodge a complaint with the NBA: Email: [email protected]

2.1 Procedure example

Step 1:

If a user has a complaint to make with any aspect of the service he/she has received from Victory Industry B.V., or he/she wishes to challenge how a bet has been settled in any of the channels offered, the user must email us at [email protected] , stating the terms of his/her grievance.

Step 2:

A member of our Customer Support Team will read the user’s query or complaint and a decision may be delivered at that time. Nevertheless, for more complex queries or complaints where further investigation may be required, the user will be contacted at all times within 5 working days with a decision, or a request for further information in order to make that decision.

Step 3:

If the user is not in agreement with the decision of our Customer Support Team, he/she may then choose to escalate the matter to a member of the department that is more senior than the member that fielded the user’s original complaint, up to and including the Head of Customer Support.

In order to escalate a complaint, the user will need to clearly state the reasons for appealing the previous decision, and any other relevant information.

Step 4:

The decision of our Head of Customer Support, on a dispute or complaint, will be considered as the view ofthe Company, unless it is subsequently overruled by the N.A. Authorities or a Company Director.

Step 5:

In the unlikely event that the user is not satisfied with the outcome of his/her query, under all of the steps

above the user at all times has the right to bring disputes to the attention of the N.A. Authorities, as explained above, if he/she deems the complaint to be unresolved. Details may be found also in T&Cs.

2.2 Successor’s control

In the occurrence where a Victory Industry B.V. account-holder passes away, and we are contacted by anyone claiming that he is a successor or a family member, requesting for a refund, a withdrawal or the closing of the user’s account, then he/she will have to provide all of following
documents:

• - The KYC documents of the successor who contactedus.
• - The official death certificate of the deceased.
• - An official written statement from the Police, stating clearly that the person thatcontacted Victory Industry B.V. is indeed a/the legal successor of the deceased.When all the above documents are verified, we forward the case to NBA, enclosing all documents and
  communications and we shall proceed to the actions required, according to the NBA’s feedback.

2.3 Handling of permanent self-exclusions
According the Provisions of the license terms any user facing a gambling addiction problem is able to

self-exclude for a decided period of time or permanently.

As soon as the user self-excludes permanently, an email is dispatched informing him about the actions that need to be taken in order to withdraw any cash remaining on his account, including also instructions to attend institutions that may assist him to overcome gambling-addiction problems.

2.3.1 Reactivation of self-suspended accounts
Before we proceed to the reactivation of a permanently self-suspended account, it is important to consider the following steps:

Step 1: We can reactivate a permanently self-suspended account only after 6-months have passed from the time that the self-exclusion took effect. This is the first thing we must check before proceeding further. In case of accidental permanent-self exclusion we may accept to examine the request of reopening only if the customer notifies immediately the faulty selection made. If more than one day is passed we do not get in consideration any notification of accidental permanent – self exclusion.

Step 2:

Taking into consideration the existing legislation concerning gambling addiction, we need to make sure that the user in question is not facing such an issue. Therefore, we need to kindly ask him to send us a written confirmation that he is not facing such an issue.

Step 3:

As soon as the first two steps are complete, we may proceed to the reactivation of the account (as described in section above).

Step 4:

Last, we leave a comment on the user’s account including the ticket number corresponding to the written confirmation we have received in our ticketing system from the user.