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AML Policy

Last Updated: 20 October, 2025
I) Introduction

Novatrix SRL (“Company”) is an entity that organises special games of chance through the means of electronic communication.

Being licensed by Tobique Gaming Commission, Company is committed to full compliance with legal and regulatory requirements in order to detect and prevent money laundering and other crimes through its services.

Company reports directly to Tobique Gaming Commission in regard to the activity that may be connected to money laundering or predicate offences.

This policy provides an overview of the AML procedures and controls Company adheres to.

II) Company risk profile

Based on our business profile, the risk of money laundering and terrorist financing is minimal, especially compared to financial institutions.

The main reason is that cash is not accepted and only credit cards, e‐wallets and other licensed instruments can be used to effect deposits and withdrawals.

Additionally, the average transaction is of a relatively small value. Since only RNG games are offered, the products offered by Company cannot really be used as a tool to launder money. The only money laundering stage that could be of a risk potential for the Company is the layering stage, which is mitigated by various daily screening measures described below.

III) Customer onboarding

1. In order to register with Company a customer needs to provide the following mandatory details:

  • First name
  • Last name
  • Address
  • City and postal code
  • Country
  • Email address
  • Date of birth
  • Password (will be encrypted)
  • Confirmation of password
  • Account currency
  • Mobile phone number

2. Players who are not registered are unable and not allowed to play for real money. Any online transaction, may it be pay­in or pay­out, will not be accepted or processed in cash.

3. Once the registration process has been accomplished, customers will receive a welcome email with a link to access their accounts. This procedure aims at verifying the customer’s email address.

4. Customers will not be able to register with a country of residence from the following list:

  • The Bahamas
  • Botswana
  • Cambodia
  • Ethiopia
  • Pakistan
  • Panama
  • Sri Lanka
  • Syria
  • Trinidad and Tobago
  • Tunisia
  • Yemen
  • Saudi Arabia
  • USA
  • North Korea
  • Iran
  • Hong Kong
  • China
  • Panama
  • Saudi Arabia
  • From other restricted / sanctioned countries in respect of FATF / UN guidance and regulations.

5. Customers under the age of 18 will be denied to register an account.

IV) Customer due diligence

1. Customer due diligence procedure includes collection and verification of the following documents:

  • Proof of Identity (POI)
  • Proof of Address (POA)
  • Proof of Payment Account (POPA)
  • Source of Wealth declaration (SOWD)

2. Customer due diligence is to be applied to the customer upon the following events:

  • In case of transactions amounting to USD 10,000 or more, irrespective of whether it is a single transaction or more than one interrelated transaction.
  • Customer performs small deposits accompanied by unusually large deposits and CDD was not yet carried out.
  • Customer is observed to attempt to create multiple accounts and CDD was not yet carried out.
  • Customer account has been inactive for the period over 6 months’, is now back active and customer’s IP and transactional activity differ from previously observed activity.

3. Additional due diligence measures may be applied to the customer per sole decision of Company staff, that include:

  • Selfie
  • Selfie with POI
  • Selfie with a special note (example: Hello 'casino name') and/or other special conditions (blinking eye, head/hand turning etc.)
  • Video verification
  • Liveness check
  • Biometrics check

4. Verification document acceptance criterion:

  • POI: all data (name, date of birth, citizenship) should completely coincide with the data in the Player's details tab. The document should be valid, and include the photo of the holder, date of birth, date of issue/expiration.
  • POA: all data (name, address) should completely coincide with the data in the Player's details tab. At the moment of verification, the document should not be older than 90 days from the date of issuance.
  • POPA: all data should completely coincide with the data in the Payment systems debts tab.

Scanned copies of the documents are not to be accepted for verification purposes.

V) Enhanced due diligence and monitoring

1. Enhanced Due Diligence is applied when additional steps of examination are needed to confirm that customer activities are carried out with legitimate funds.

2. Enhanced Due Diligence procedure includes collection and verification of the following documents:

  • Source of Wealth
  • Source of Funds

3. Enhanced Due Diligence is to be triggered at the following events:

  • Customer is classified as high risk as per Customer Risk Assessment and SOW/SOF are not yet obtained and verified.
  • Customer determined to be a PEP or a relative or a close associate of a PEP.

4. Forms of acceptable SOW:

Salary income:

  • Mandatory: Bank statement(s) showing receipt of salary (3 months’ minimum);
  • Additional evidence if required: payslip, letter from employer, or tax return statement.

Company profits:

  • Mandatory: Distribution of dividends certificate, certificate of incumbency.
  • Additional evidence if required: audited accounts, accountant declaration, invoices.

Sales of shares or investments:

  • Mandatory: Bank statement (6 months) showing receipt of funds and investment company name.
  • Additional evidence if required: certified certificates or contract notes.

Sale of property:

  • Mandatory: Copy of contract of sale, bank statement showing proceeds of the sale.
  • Additional evidence if required: solicitor letter stating property details and proceeds.

Sale of company:

  • Mandatory: Letter detailing company sale signed by a licensed solicitor or accountant.
  • Additional evidence if required: media coverage (if applicable).

Inheritance:

  • Mandatory: Copy of the deceased's will.
  • Additional evidence if required: letter from solicitor or grant of probate with estate value.

Loan:

  • Mandatory: Copy of the loan agreement.
  • Additional evidence if required: ID documents of the lender.

Gift:

  • Mandatory: Letter from donor explaining reason for gift and source of wealth, certified ID of donor.
  • Additional evidence if required: passport, bank statement showing origin, or selfie of donor holding ID.

Fixed deposit / Savings:

  • Mandatory: Savings statement.
  • Additional evidence if required: letter from provider or account start proof.

Funds generated from gambling / gaming winnings:

  • Mandatory: Receipt of winnings and bank statement showing origin of deposited funds.

Pension:

  • Mandatory: Bank statement showing pension payments.
  • Additional evidence if required: pension statement.

Mining:

  • Mandatory: Ledger of cryptocurrency mined and wallet address with transaction hash.
VI) Payout management

The following checks to be performed on each payout:

Account check

  • The owner of the Company account must be the same person as the owner of the bank account or credit card.
  • All account information, like address, email, date of birth, etc., must be complete and authentic.
  • Withdrawals will be made to the same source where the funds originated (where possible).

Wagering check

  • On each payout it has to be checked if the deposits have been used for stakes.
  • A payout cannot be processed if the deposited amount has not been used for stakes.
  • If the deposited amount has not been used, the payout has to be denied.

Activity check

  • Funds deposited in the gaming wallet can only be used for gaming activity.
  • If regular changes are noticed to the linked bank account, the account will be suspended until explanations are provided.

Collusion check

  • Company staff closely monitors origins of winnings acquired by the customer.
  • If there are reasonable grounds to suspect that customer is attempting to transfer funds between accounts through strategic betting (e.g., roulette, punto banco, craps, etc.), no payouts are to be processed until activity is reviewed by the game provider and confirmed legitimate.
VII) Politically Exposed Persons (PEPs) and sanctioned individuals

A Politically Exposed Person is someone who has been entrusted with a prominent public function, such as a senior political figure. Individuals who are closely related to this person, for instance, immediate family members and close associates, are also considered as PEPs.

PEPs are classified as a money laundering risk since they may be exposed to property that has been generated by corruption and bribery because of their position.

Novatrix SRL carries out manual screening of customers through OSINT (open-source intelligence) and the following links are “at minimum” considered for manual screening:

Upon learning that the customer might be a PEP, the following measures are applied:

  • Customer is asked to provide POI, POIA and a selfie (if not obtained previously).
  • Novatrix SRL AML Compliance unit is to conduct a review of the account to determine if customer is a true PEP.
  • If customer is determined to be a true PEP:
    • EDD measures are applied.
    • Approval for continuance of business relationship with the customer is requested from the senior management.
    • If it’s decided to continue relationship with the customer, monitoring measures are applied.

New customers are screened for their PEP status within 30 days from the start of CDD procedure.

Sanctioned individuals are classified as a money laundering risk since they may be exposed to property that has been generated by corruption and bribery because of their position.

Novatrix SRL carries out manual screening of customers through OSINT (open-source intelligence) and the following important links are “at minimum” considered for manual screening:

Should a customer be flagged as potentially being a person listed on a financial sanction list:

  • The client shall be immediately frozen, and all funds shall be also frozen.
  • Internal Report form is to be immediately sent to the MLRO.

New customers are screened for SL status within 30 days from the start of CDD procedure. Active customers are reviewed on a monthly basis.

Once the appropriate investigation is carried out, and it is confirmed that the customer is indeed likely to be a person subject to financial sanctions, a report will be submitted by the MLRO to the appropriate authority to report the actions taken in respect of the customer.

VIII) MLRO

The MLRO is the first person to notify when the suspicion of money laundering activities evolves.

The MLRO is appointed by senior management and is trained for the money laundering risk factors that the company faces. When the company appoints the MLRO, the competent authorities need to be notified. The main duties of the MLRO are:

  • Keeping up to date with AML/CTF legislations.
  • Making sure that implementation takes place in line with the internal procedures.
  • Making sure that anti‐money laundering training is periodically given to staff.
  • Recording and updating risk assessments.
  • To receive and evaluate internal reports.
  • To advise, guide and assist.
  • To keep statistical data.
  • Filing STRs to the Tobique Gaming Commission.

All incidents involving a suspicious person or transaction in terms of money laundering or funding terrorism need to be reported to the Tobique Gaming Commission by the MLRO within 5 working days.

In the Suspicious Transaction Report, the MLRO must give a clear and complete explanation of the suspicious behaviour including also customer identification and transaction records.

IX) Record keeping

The following records are kept:

  • Identification Records:
    • Copy of ID‐document
    • Copy of bank/credit statement
    • References
  • Transaction Record Details:
    • Deposit/withdrawal method used
    • ID of person performing the transaction
    • Destination of funds
    • The authorisation of credit card payments performed by our clearing companies
    • Volume of transactions

The records are kept for 5 years from the end of the business relationship in accordance with the directive.

X) Staff training

Periodical training ensures that the staff is aware and compliant with the anti‐money laundering regulatory requirements.

XI) Employee hiring

For all new employees hired by Company, Company will conduct a thorough background check and various due diligence documents will be collected for reference (birth certificate, clear police conduct, etc.). Interviews are carried out and requested references are checked, whenever available.

It is a company policy that all new employees are also given training with regards to the anti‐money laundering policy and the internal procedures used to mitigate this risk.

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