AML Policy

1. Introduction

This Anti-Money Laundering (“AML”) Policy outlines Play Arcade’s commitment to combatting Money Laundering (“ML”) and Terrorist Financing (“TF”). Play Arcade adheres to global standards and regulatory requirements in its approach, implementing procedures that follow both legal obligations and best practices for the gaming sector. Play Arcade acknowledges the potential risk that its services may be exploited by individuals or groups attempting to launder funds or finance illicit activities. Consequently, Play Arcade fosters a compliance-driven culture to ensure vigilant monitoring and prevention of ML and TF activities.

2. Policy Statement and Key Objectives

Play Arcade strictly prohibits using its platform for any unlawful purposes, including ML, TF, or sanctions violations. To prevent such misuse, Play Arcade adheres to industry standards that include:

• Establishing formal policies, procedures, and controls to detect and mitigate ML, TF, and sanctions risks;

• Appointing a Compliance Officer responsible for overseeing the AML Policy and related controls;

• Ensuring training programs are in place to educate relevant staff on identifying suspicious activities; and

• Conducting regular reviews and assessments to update policies and improve the effectiveness of AML measures.

This AML Policy sets forth the main controls, practices, and systems Play Arcade has established to uphold these commitments and objectives.

3. Role of the Compliance Officer

Play Arcade’s Compliance Officer oversees the execution of the AML Policy, including coordinating AML-related initiatives, ensuring regulatory compliance, and investigating any potentially suspicious activities. This role reports independently to the Board, allowing the Compliance Officer full authority to act on potential AML and TF threats, including filing Suspicious Transaction Reports (“STRs”) directly to the Financial Intelligence Unit (“FIU”), where required.

4. Employee, Director, and Officer Responsibilities

All staff, regardless of role, are required to comply with this AML Policy and to remain vigilant against potential ML and TF activities. If any employee, director, or officer suspects or identifies activity related to ML or TF, they must report it immediately to the Compliance Officer. Failure to report such activity may result in disciplinary measures. Play Arcade also provides ongoing training to ensure all employees are informed and capable of recognizing signs of ML and TF.

5. Know-Your-Customer and Transaction Monitoring Measures

Play Arcade has designed proportionate KYC measures and transaction monitoring processes to manage the risks associated with ML and TF. These practices allow Play Arcade to identify potential risks and comply with legal obligations to prevent illicit activities on the platform.

5.1. Customer Due Diligence (CDD) and KYC

Play Arcade uses a risk-based Customer Due Diligence approach, gathering specific customer information during registration to assess potential risks. Key steps include:

• Collecting basic identifying information, including name, address, and date of birth, to confirm customer identity.

• Geoblocking jurisdictions where Play Arcade’s services are restricted or prohibited, using IP address filters and requiring customer confirmation during account setup.

• Excluding and screening sanctioned countries and regions, including those listed by the United States and European Union, using geo-blocking and customer declarations.

• Screening all customer wallet addresses through sanctions databases via third-party providers before issuing any funding addresses.

5.2. Continuous Monitoring of Accounts

Play Arcade conducts ongoing monitoring to identify potentially suspicious behaviour, ML, TF, and sanctions violations. Several key practices are followed to support this goal:

• Monitoring Transactions by Jurisdiction: Manual and automated processes are used to flag suspicious activities, especially those linked to sanctioned or prohibited locations.

• Screening for Sanctioned Parties: Wallet addresses are periodically re-checked against current sanctions lists to ensure ongoing compliance.

• Detecting Unusual Activity: Regular reports are generated to track irregular or high-risk activity based on transaction size, volume, and frequency.

• Preventing Use of Anonymity Tools: Technologies that enhance anonymity, such as mixers or tumblers, are prohibited, with monitoring to identify these tools on the platform.

• Chainalysis Monitoring: All cryptocurrency transactions are monitored for suspicious activity via Chainalysis, with heightened scrutiny applied to flagged accounts.

• Account Withdrawal Threshold: Accounts with activity reaching specified thresholds undergo additional KYC verification before any withdrawal is processed.

• Detecting Multiple Accounts and Ban Evasion: Advanced tools help detect users attempting to circumvent bans or create multiple accounts.

• Time Zone and Location Monitoring: Play Arcade checks device location information against jurisdiction restrictions to verify customer compliance.

• Reviewing Vendor Performance: Play Arcade routinely assesses third-party service providers to ensure compliance standards are upheld and that services are effective in managing AML-related risks.

5.3. Enhanced Due Diligence (EDD)

If a customer’s activity is flagged as potentially high-risk, Play Arcade initiates Enhanced Due Diligence (EDD) measures, which may include requesting additional information such as:

• Full name, country of citizenship, and residential address;

• Government-issued identification;

• Source of funds and wealth documentation.

6. Customer Blocking and Suspension

Play Arcade reserves the right to suspend or block accounts under specific circumstances, including failure to provide requested identification, attempts to mask location, engagement with restricted jurisdictions, or any indication of problematic behaviour related to ML, TF, or gambling issues. Play Arcade also reserves discretion to close accounts in other circumstances as deemed necessary.

7. Reporting Obligations

If a customer is found to be on a sanctions list, or associated with ML, TF, or other criminal activities, Play Arcade will promptly report the activity to the relevant FIU.