MaximaBET - Anti-Money Laundering Policy

ANTI-MONEY LAUNDERING POLICY (AML)

Introduction

SUPERJOGOS N.V., company duly supplied in accordance with the laws of Curaçao, registered under number 157878, with address at Emancipatie Boulevard, Dominico F. “Don” Martina, 31, Willemstad, Curaçao, offers online gaming services via an internet platform, operating under the Online Gaming Regulations. Under the licensing conditions issued by the Curaçao Authorities, Máxima Bet is required to implement appropriate measures to prevent its systems from being utilized for money laundering, terrorist financing, or any other criminal activities. Consequently, Máxima Bet is obligated to adhere to applicable legislation.

Objective of the Policy

Máxima Bet is fully committed to maintaining constant vigilance to prevent money laundering and combat terrorist financing, aiming to minimize and manage risks such as reputational, legal, and regulatory risks. Additionally, the company is dedicated to fulfilling its social responsibility by preventing serious crimes and ensuring that its systems are not utilized for the promotion of such activities. Máxima Bet will strive to stay informed about national and international developments regarding initiatives to prevent money laundering and terrorist financing. The organization is steadfast in protecting its operations and reputation at all times, safeguarding against the threats posed by money laundering, terrorist financing, and other criminal activities.

Obligations

Máxima Bet is responsible for monitoring all transactions and verifying the identity of all players registered online. The directors, as well as all employees and service providers, are fully committed to adopting a risk-based approach to anti-money laundering (AML), concentrating efforts where necessary to facilitate payment transactions between the company and www.maximabet.net customers in a manner free of money laundering issues.

Responsibility of directors

The directors are actively engaged in the company's money laundering and terrorist financing risk assessment processes and participate in all decision-making levels to develop the necessary policies and procedures to comply with relevant legislation. Based on this involvement, the directors will designate one of their members and/or a specialized AML service provider as the Money Laundering Reporting Officer (MLRO). The MLRO's responsibilities will encompass fulfilling obligations mandated by laws, regulations, and guidance notes.

Money Laundering Reporting Officer (MLRO)

The directors are actively engaged in the company's money laundering and terrorist financing risk assessment processes, participating at all decision-making levels to develop the necessary policies and procedures for compliance with relevant legislation. Given their involvement, the directors will appoint one of their members and/or a specialized AML service provider as the Money Laundering Reporting Officer (MLRO). The MLRO will be responsible for fulfilling obligations mandated by laws, regulations, and guidance notes.

Employee responsibilities

Employees are trained to adhere to Máxima Bet's policies and procedures for customer due diligence. They are required to report any knowledge or suspicion of money laundering, whether involving customers, guests, or other employees, to the MLRO.

Responsibilities of Máxima Bet

Máxima Bet shall take reasonable steps to establish the identity of any person to whom it proposes to provide its service. To this end, it will implement a comprehensive "Know Your Customer" policy. This will help combat not only money laundering threats but also other fraud threats in general.

You will be able to maintain a secure list of your registered players, as well as preserve the identification and documentation submitted, in case of legal requirements.

Systems will be implemented to record all transactions on an account. These account histories will undergo regular and ongoing checks against indicators of fraud and social responsibility. In cases where unusual betting and winning patterns are detected, they will also be cross-referenced with call history to ensure that staff are not colluding with customers or acting unlawfully.

Máxima Bet will also maintain a record of customers who pose a high risk or are politically exposed. For such cases, there will be more frequent verification and monitoring of activities on the portal.

In general, when illegal or inappropriate user behavior is identified, investigation procedures and disciplinary measures will follow the applicable legislation as well as the terms of the contract between the user and the supplier.

All transactions conducted on our site will be monitored to prevent money laundering or terrorist financing activities. Suspicious transactions will be reported to the relevant authority based on the jurisdiction governing the transaction and the user's location.

If Máxima Bet suspects fraud, it may request the player to provide appropriate documentation. If there is sufficient evidence of fraudulent behavior (such as operating the account by a third party, using forged documents, or engaging in payment fraud), the account will be suspended pending clarification of the situation. The suspension must be promptly communicated to the competent authority, along with the respective grounds (evidence or collected evidence), within 24 hours, as well as to the authorities responsible for criminal proceedings. Simultaneously with the suspension, Máxima Bet may freeze the player's account balance as a precautionary measure until the decision of the competent authorities.

Provide initial and ongoing training to all relevant staff, including but not limited to:

Personal responsibilities of staff;

Procedures relating to the identification of Players;

Monitoring of player activity;

Record keeping;

Reporting any unusual/suspicious transactions;

Unusual betting patterns;

Suspicious deposit and withdrawal patterns (size and frequency);

Card Data Reliability ;

Customer verification issues and identity theft;

Account linking/multiple accounts;

Account for High Risk Jurisdictions;

Customer due diligence (CDD), including enhanced requirements for high-risk customers, which includes PEPs;

Ensure that this policy is developed and maintained in accordance with evolving statutory and regulatory obligations, as well as advice from competent authorities. Additionally, examine the background and purpose of any complex or large transactions, along with transactions that are particularly likely, by their nature, to be associated with money laundering or terrorist financing.

Máxima Bet reserves the right to close accounts and withhold all balances in cases of suspected fraudulent activity, which may include, but are not limited to, the submission of fraudulent, falsified, altered, or stolen personal information, or instances of multiple account registrations.

Any suspicion or knowledge of money laundering and terrorist financing must be promptly reported to the Financial Intelligence Analysis Unit (FIAU), a government agency established by law, responsible for collecting, processing, analyzing, and disseminating information aimed at preventing money laundering and combating terrorist financing.

The suspicious activity mentioned in this instance pertains to questionable transactions within player profiles, characterized by divergent deposit patterns, among other fraudulent indicators. Such cases necessitate our team to conduct risk monitoring of our clients, incorporating enhanced Player Due Diligence checks. For further information, please contact compliance@maximabet.net

Passport or identity card;

Proof of income

Photo of the rosco holding the document; and

Other proof of identity.

Due Diligence checks are tailored to the profiles of the players and the level of risk they represent to us. These checks may also encompass financial inquiries, such as verifying the client's place of employment, the value of their residence, and ensuring that their financial activity aligns with their spending patterns.

At Máxima Bet, we ensure that all employees immediately report any knowledge or suspicion of a person's or customer's involvement in money laundering (ML) or terrorist financing through Suspicious Activity Reports (SARs), which are imperative. Failure to comply with this standard may result in criminal prosecution. The submission of SARs must be confidential and discreet, preferably in handwritten form to ensure maximum anonymity. Avoid communication via email; instead, submit reports directly to compliance@maximabet.net

It is strictly forbidden for any employee to disclose information related to AML (Anti-Money Laundering). Such disclosure, also known as "whistleblowing," is subject to serious legal penalties.

The Company undertakes to cooperate with all relevant administrative, enforcement, and judicial authorities in their efforts to prevent and detect criminal activity. Additionally, the company must:

Do not agree to open anonymous accounts or accounts in fictitious names in such a way that the true beneficial owner is not known.
Do not accept cash from players. Funds can only be received via credit cards, debit cards, electronic transfers, or checks.
Do not register a player under eighteen (18) years of age.
Do not allow more than one account to be registered in the name of the same individual; multiple account practices are strictly prohibited.
Do not accept a bet unless a user account has been established in the player's name and there are adequate funds in the account to cover the amount of the bet.
Do not accept players residing in or playing from non-respectable jurisdictions.

Do not make a payment of more than BRL 500.00 (USD 99.00) from an account until the "Know Your Customer" procedure has been carried out, and the player's identity, age, and place of residence have been verified. Once verified, the user will be subject to a financial transaction cap of BRL 50,000.00 (USD 10,000.00) per month and BRL 5,000.00 (USD 1,000.00) per day.

If no transactions have been registered by the user for thirty months, the account will be closed, and the balance will be remitted to the player's account. If the player cannot be located, the balance will be remitted to the regulatory body.

If it becomes known that a person has provided false information when submitting due diligence documents, the registration of that person will be prohibited. If the person has already been registered, the company must immediately cancel the player's registration on the platform.

Responsibilities of Users

The customer expressly declares and guarantees that all amounts deposited and used to participate in online games at Máxima Bet come from legitimate sources and are not related to any fraudulent activity, money laundering, or terrorist financing. In accordance with the law in force and regulations that may be issued at any time by the regulator on the prevention of money laundering and terrorist financing, Máxima Bet reserves the right to take any measures it deems necessary to comply with these requirements.

Users may not use loans to play on the Máxima Bet platform. In such cases, Máxima Bet reserves the right to monitor any transfer of funds deposited or withdrawn by the user and to report any user information to regulatory or criminal authorities and/or payment service providers.

Once the deposit has been confirmed, the customer can use the deposited funds for betting. Deposits are credited to the player's account as soon as the bank transfer is successfully validated. Deposits and withdrawals are only made in Reais (R$) and US Dollars (US$), with the minimum deposit amount being R$ 5.00 (USD 1.00). It is the customer's responsibility to check whether their bank imposes any fees on these transfers.

The customer declares that they are the holder of the payment account provided to Máxima Bet and that the payment methods used are associated with that same account, or if this is not possible, associated with an account held by the customer. The total balance of the player's account includes Casino Balance, Real Sportsbook Balance, Casino Bonus Balance, and Sportsbook Bonus Balance.

The existence of two wallets (casino and sportsbook) does not alter the behavior of your player account when making a withdrawal request. Consequently, making a withdrawal request, regardless of whether the balance to be withdrawn is transferred from your casino wallet, may result in the loss or cancellation of sports betting bonuses.

Withdrawals must be made by the same method used for deposits, whenever the method used allows it. If the deposit method does not allow withdrawals, they must be made by bank transfer to the account provided by the user when registering or to the payment account they have indicated and hold and which is chosen for this purpose.

Before any withdrawal is processed, the following procedures are carried out:

The client's deposit history is reviewed to confirm that no suspicious payments have been made to the client's account.

The frequency and total sum of deposits are reviewed to ensure that they are within the permitted limits.

The customer's turnover is examined to ensure that they are not using Máxima Bet as a means of money laundering. To comply with legal requirements, your identity must be verified by Máxima Bet, and in some cases, by the payment method company responsible for financial transactions.

Whenever you wish to change your payment account, you must send new proof of ownership of the new account; otherwise, your payment will not be processed.

Your player account on the platform must not be used or treated as a bank account. In the case of deposits or withdrawals without gaming activity, or activity with reduced proportions of initial deposits, ReidoCasino reserves the right to request explanations before transferring the withdrawal request in question.

Your withdrawal request will be canceled within 72 hours of the date of your request if you do not provide Máxima Bet with the information necessary to allow verification of your identity.

Any withdrawal is free of charge. Politically exposed person: The guidelines on the Prevention of Money Laundering and Terrorist Financing laws have come into force, changing the definition of politically exposed persons. In order to minimize the risks of corruption and money laundering, Máxima Bet is required by law to collect data and to identify which of its clients/customers' beneficiaries should be considered politically exposed persons, along with their family members or close associates.

According to the "Money Laundering and Terrorist Financing" law, the following person is considered a politically exposed person (hereinafter PEP): a person who holds or has held a public position in any country, including senior state officials, heads of state administrative units (municipalities), heads of government, ministers (deputy ministers or assistant deputy ministers, if such positions exist in a relevant country), secretaries of state, or other senior government or state administrative unit officials (municipalities), members of parliament or similar legislative bodies, members of the administrative bodies (boards) of political parties, judges of the Constitutional Court, Supreme Court, or other level courts (members of the judicial bodies), members of the council or board of directors of supreme audit institutions, members of the council or board of directors of central banks, ambassadors, chargés d'affaires, senior officers of the armed forces, members of the council or board of directors of state-owned companies, heads (directors, deputy directors) of international organizations, and members of the council or individuals occupying similar positions in such organizations. The following person is considered a member of the family of a politically exposed person: a spouse or a person considered to be equivalent to a spouse. A person can only be considered equivalent to a spouse if they have such status under the laws of their country; a child or a child of the spouse of a politically exposed person or of a person considered equivalent to a spouse, their spouse, or a person considered equivalent to a spouse; a parent, grandparent, or grandchild; a brother or sister.

A close associate of a politically exposed person is an individual publicly known to have a business or other close relationship with a politically exposed person, or to be a shareholder in the same business enterprise as a PEP, and also an individual who is the sole owner of such a legal entity known to be actually established for the benefit of a PEP.

Forbidden Countries

The following countries are prevented from participating in Máxima Bet:

Uganda, Iraq, South Africa, Croatia, Slovenia, Greece, Sweden, Romania, Belarus, Switzerland, Lithuania, Monaco, Estonia, Latvia, Isle of Man, Afghanistan, Antigua and Barbuda, Australia, Austria, Belgium, Bulgaria, Cayman Islands, Cuba, Cyprus, Czech Republic, Denmark, Kingdom of the Netherlands (Netherlands, Curaçao, Aruba, Bonaire, Sint Maarten, Sint Eustatius, Saba), France, French Guiana, French Polynesia, French Southern Territories, Guadeloupe, Germany, Hong Kong, Hungary, Iran, Ireland, Israel, Italy, Japan, Kahnawake, Libya, Macau, Malta, Martinique, Mayotte, Myanmar, Netherlands, Netherlands Antilles, North Korea, Philippines, Poland, Portugal, Reunion, Russia, Saudi Arabia, Serbia, Singapore, Slovakia, Spain, Sudan, Syria, Turkey, United Kingdom, United States of America, Vatican City, Yemen, Ontario, Canada.

Know Your Customer procedure

Máxima Bet will implement a COMPREHENSIVE "Know Your Customer" policy. This will help combat not only money laundering threats but also other fraud threats in general. Customers will be advised at the time of registration and in general on the non-transactional support site that the Company will use online verification tools. In cases where we are unable to meet the criteria, identity and address verification documents may be requested, including by the company responsible for the payment method.

To open an account on the www.maximabet.net portal, the Customer must first complete the "Registration process." This begins with the Customer's registration, during which they must provide their name, country of residence, tax ID, and account currency. This information will be confirmed by specific software that will also verify other data, such as the date of birth, which will allow verification of age and the validity of the document with the agency responsible for registering tax identification.

All customers must be at least 18 years old and may only have one player account in their own name, as specified in the Curaçao Online Gaming Rules. Therefore, no minors may play at www.maximabet.net. Users who do not have a registered player account will not be able to play.

The "Verification Procedure" will take place whenever the Customer reaches one of the following thresholds:

(i) One or more withdrawals totaling BRL 500.00 (USD 99.00): The Customer must access the Documents Area in the Account Settings and provide a copy of their ID card, as well as take a photo of themselves holding the ID card.

(ii) Any cash flow of R$50,000.00 (USD 10,000.00) or more in one month: The Customer must access the Documents Area in the Account Settings and provide a copy of a utility bill, as well as the latest Income Tax Return submitted by them.

After registering, the Customer will receive an SMS to verify and validate their mobile number. Without this confirmation, the Client will not be able to complete the registration.

Records of both procedures will be kept for five years from the end of the business relationship or the customer's last visit to www.maximabet.net.

If the "Verification Procedure" cannot be completed for any reason, the Client will not be allowed to access their User Account or withdraw any funds.

All documentation will be formally requested by email for both Due Diligence scenarios and filed in accordance with the company's internal data protection procedures.

In light of the requirements imposed by law and regulations, the Company adopts the following procedures when the Verification Procedure is triggered under the threshold approach:

(iv) At the point when verification is triggered, the Company will suspend any transactions from the User Account, and no withdrawals can be made.

(v) Further deposits can be made to that account as long as they too are locked into it until the Verification Procedure is completed.

(vi) Bets can be made from the account, again, provided that any winnings will remain locked until the Verification Procedure is completed.

(vii) Once the Verification Procedure is completed, the account can be unlocked, and business can continue as normal.

(viii) If the Verification Procedure cannot be completed, then the Company will terminate the business relationship with the Customer.

(ix) If there are monies to be repaid, the amount repaid will consist of the monies owed to the Customer at the point when the Verification Procedure was triggered, plus all deposits made at that point and thereafter.

(x) Money will be returned to the originating account.

(xi) Appropriate risk mitigation measures will be implemented.

Collusion and cheating

The company has systems in place to detect cheating, collusion, or any illegal activity, including suspicious and large transaction alerts, risk management solutions to monitor customer transactions, and online risk solutions. When suspicious activity is identified, the customer’s account will be reviewed, and this will be reported as a Suspicious Transaction Report (STR) to the Money Laundering Reporting Officer (MLRO). The customer’s account will be suspended, and if cheating/collusion is identified, the account will be closed, and the customer will be reported, where necessary.

If an employee is implicated in any cheating, collusion, or other illegal activity, they will be suspended pending a full investigation.

Applicable Legislation

- National Ordinance on Identification of Clients when Rendering Services (P.B. 2010, no. 40 and P.B. 2015, no. 69)

- National Ordinance on the Reporting of Unusual Transactions (P.B. 2010, no. 68 and P.B. 2015, no. 68)

- National Ordinance on Offshore Gambling (P.B. 1993, no. 63)

- National resolution No. 5536/JAZ