Version 1.1

March 2024

1. Introduction

   Clover Leaf B.V. (“MyPrize” or the “Company”) is a Curaçao company which operates the MyPrize online gaming platform accessible at www.myprize.com under Curaçao license no. 165739.

   This policy (the “AML Policy”) sets out MyPrize’s approach to preventing and countering money laundering and terrorist financing. In developing this policy, MyPrize has considered all current Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) obligations required under Curaçao law, as well as best practice guidance issued for the gaming sector and by the Curaçao Gaming Control Board. MyPrize is committed to ensuring compliance with all applicable laws and regulations, including but not limited to offering services solely in permitted jurisdictions (and associated geo-blocking, as required), anti-money laundering and combating the financing of terrorism, and sanctions compliance.

   The Company and its management affirm their commitment to combating the abuse of the Company’s products and services for the purpose of money laundering and terrorist financing. This includes through compliance with current AML/CFT legislation as well as provisions and guidelines. To that end, MyPrize has established and maintains a Compliance & Anti-Money Laundering Manual, as documented herein.

   MyPrize acknowledges that its products and services are at risk of being sought for use by individuals, groups, or entities seeking to launder criminal proceeds or facilitate funds designated for the financing of terrorism. As a result, MyPrize is committed to fostering and promoting a culture of compliance throughout the Company which highlights the importance of AML/CFT measures.

2. Policy Statement and Objectives

   MyPrize prohibits the use of its products and services for money laundering, terrorist financing, sanctions violations, and any form of criminal or illicit activity. In order to combat these bad acts, MyPrize is committed to following global best practices in guarding against such use of its products and services. These best practices include:

   1. Adopting a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing, and sanctions violations;

   2. Designating a compliance officer to oversee the implementation of the policy, procedures and controls;

   3. Providing appropriate education and training to relevant personnel; and

   4. Conducting independent reviews, monitoring and maintenance of the policy, procedures and controls.

   The purpose of this AML Policy is to describe the primary set of procedures, systems, and controls that MyPrize is implementing to ensure that it follows industry best practices, and in particular, to prevent and detect money laundering and terrorist financing.

3. Chief Compliance Officer

   MyPrize has appointed a Head of Compliance, who is responsible for coordinating the implementation of this AML Policy and related compliance policies. The Head of Compliance’s duties also include, but are not limited to, developing AML-related Company initiatives, working with other Company stakeholders to update and revise the AML Policy as needed, assessing the applicability of new regulatory requirements and overseeing implementation of compliance measures accordingly, and investigating and reporting potentially suspicious or unusual activity.

   The Head of Compliance will act on the Head of Compliance’s own authority. The Head of Compliance will be authorized to submit suspicious transaction reports (“STRs”) to the Financial Intelligence Unit of Curaçao (the “FIU”) without requiring approval to do so.

4. Responsibilities of Employees, Directors and Officers

   Regardless of their positions, MyPrize’s employees, directors, and officers must comply with this AML Policy. Such individuals have a duty to be aware of the need to prevent money laundering and terrorist financing. Should such individuals have any reason to believe or suspect that any transaction, or potential transaction, could involve the proceeds of criminal conduct, they must report their suspicions to the Head of Compliance without delay. Failure to do so may result in disciplinary action. As the Company grows, MyPrize will ensure that employees are trained to identify and report suspicious activity, including by providing AML training to employees on a regular basis.

5. Know Your Customer Measures and Transaction Monitoring

   MyPrize recognises the risks that bad actors may attempt to use its services for money laundering and terrorist financing and has implemented controls, as well as policies and procedures, which are proportionate and targeted to those risks. MyPrize applies appropriate Know Your Customer (“KYC”) and ongoing monitoring measures to further the objectives of this AML Policy and as required by law.

   1. • KYC Measures. MyPrize has adopted risk-based Customer Due Diligence (“CDD”) processes to enable the Company to develop a customer risk profile and to maintain an understanding of the Company’s customers. The CDD processes involve collecting certain information on customers at the onboarding stage, throughout the customers’ use of the platform, and monitoring customer activity. MyPrize’s CDD processes include the following measures:

      1. Collecting Customer Information. MyPrize will collect details on each customer to form a reasonable belief that it knows the identity of its customers. MyPrize may collect such details as a customer’s wallet address, name, address, country, date of birth, or postal code (collectively, “KYC Information”). MyPrize has the right to collect any of the above KYC Information before permitting customers to deposit funds. MyPrize may utilize a third-party service provider to help it to determine the validity of the information provided by customers.

      2. Excluding and Geoblocking Prohibited Jurisdictions. MyPrize does not offer services in jurisdictions where such services are not permitted to be offered (“Prohibited Jurisdictions”). By using the services, customers represent and warrant that they are not located in a Prohibited Jurisdiction. MyPrize has implemented IP address-based geo-blocking of identified Prohibited Jurisdictions.

      3. Excluding and Geoblocking Sanctioned Jurisdictions. MyPrize does not offer services in jurisdictions subject to United States, European Union, or other global sanctions or watch lists, including Iran, Cuba, North Korea, Syria and the Crimean region of Ukraine (“Sanctioned Jurisdictions”). By using the services, customers represent and warrant that they are not located in a Sanctioned Jurisdiction are not personally subject to international sanctions. MyPrize has implemented IP address-based geo-blocking of identified Sanctioned Jurisdictions.

      4. Screening for Sanctioned Parties. Before permitting customers to deposit funds, MyPrize will screen a customer’s wallet address against applicable sanctions databases.

   2. • Ongoing Monitoring. MyPrize performs ongoing monitoring of its customers in order to detect any behavior or circumstances that might indicate money laundering or terrorist financing activity, sanctions breaches, or other illicit activity. MyPrize has implemented a range of processes to help it achieve this goal:

      1. Transaction Monitoring for Sanctioned or Prohibited Jurisdictions. MyPrize undertakes transaction monitoring processes to identify suspicious behavior. Should such behavior be identified, MyPrize may refuse to process any withdrawal attempts or may require additional information from the customer. MyPrize will further endeavor to limit any attempted customer account funding from Prohibited Jurisdictions where the associated wallet address indicates that the customer or the customer’s funds are located in such a Prohibited Jurisdiction. Customers will have the ability to offer information that they believe to rebut any suspension as part of MyPrize’s transaction monitoring and customer due diligence standards.

      2. Identification of Unusual Activity. MyPrize will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and any other red flags.

      3. Anti-Mixing Measures. MyPrize does not permit the use of anonymity-enhancing technologies such as mixers, tumblers, or certain digital assets. If MyPrize becomes aware that an anonymity-enhancing technology is being used on the MyPrize platform, MyPrize will disallow such use. MyPrize may also take steps to address suspicious deposit or withdrawal patterns, dealing with such occurrences on a risk basis.

      4. Blockchain Analytics. Digital asset deposit and withdrawal activity will be monitored using blockchain forensic tools and reviewed for signs of fraud or suspicious behavior. A customer’s account will be suspended and reviewed upon an alert of potential illicit behavior. Sufficient proof of wealth may be requested from high-risk accounts. MyPrize may refuse to withdraw to certain high-risk addresses as determined in consultation with its blockchain forensics vendors.

      5. Withdrawal Threshold KYC. Any customer account may be prevented from  withdrawing funds until adequate due diligence has been carried out once that account has reached a withdrawal threshold dependent on the account’s risk characterisation over the life of the account, assessed according to MyPrize’s sole discretion.

      6. Vendor Management. MyPrize will periodically assess the strength of its key third-party service providers to determine whether additional services are needed, and whether the third-party service provider is performing in accordance with its contractual obligations, or if other remedial action is necessary for MyPrize to comply with this AML Policy. MyPrize may request information from any third-party service provider as part of its vendor review process.

      7. Compliance Innovation. MyPrize will continuously monitor any non-documentary compliance mechanisms to determine whether their use on the MyPrize platform would be viable. MyPrize may run test or trial mechanisms on a limited basis with such compliance vendors to determine their effectiveness. Blockchain-native compliance tools may include fraud prevention services, on-chain KYC providers, and other tools designed to reflect the technological features associated with blockchain platforms.

   3. • Enhanced Due Diligence. If suspicious activity is identified, in MyPrize’s discretion according to its compliance policies and procedures, the relevant customer’s account will be suspended and MyPrize will perform enhanced due diligence (“EDD”) on the account. EDD may include requiring customers to provide certain information and/or documentation to enable MyPrize to verify the customer’s identity and ascertain the customer’s source of funds and/or source of wealth. MyPrize may use third-party service providers to verify any of the above information.

      • Blocking of Customers. MyPrize will take measures to block or suspend customers who, in violation of MyPrize’s Terms & Conditions: (i) do not provide the identification information requested by MyPrize; provide false identification documentation; adopt measures to conceal their true location; are from restricted or prohibited jurisdictions; are subjected to United States, European Union, or other global sanctions or watch lists; are addicted to gambling or have mental health issues; or deposit funds which originate from restricted jurisdictions. In addition, MyPrize reserves the right to block and suspend customers for any other reason at its sole discretion.

6. Reporting

   If a customer is identified as being on a sanctions list, or linked to money laundering, terrorist financing, or other criminal activities, MyPrize will make an appropriate report to the FIU, as applicable.