Anti-Money Laundering, Anti-Terrorist Financing Statement

1. The company's business model

As part of its global operations, the platform has in place compliance measures commensurate with its services and products, which are reasonably designed to deter and detect illegal activity on its platform. These include onboarding and compliance screening of customers and controls over transaction-based operations.

2. Company policy statement

Equity is not a financial institution within the meaning of the applicable laws of Curacao and is therefore not directly subject to the rules and regulations applicable to certain financial institutions, remittance or virtual asset service providers. However, Equity expressly prohibits and refuses to use Equity products for any compliance with the Anti-Money Laundering and Combating the Financing of Terrorism Regulations ("AML/CFT") 2016 applicable to the jurisdiction of Curacao as stipulated by the Curacao Gaming Control Commission. Forms of illegal activity under national anti-money laundering (“AML”) laws, regulations and norms, including money laundering, terrorist financing or trade sanctions violations. In addition to the Curaçao Gaming Control Board, the AG continues to monitor the normative parameters promulgated by the Financial Action Task Force (“FATF”) and certain gaming exchange organizations and will take necessary actions as it deems appropriate to reflect changes in the law.

The purpose of the platform is to follow global best practices and prevent stock products from being used to facilitate such activities. These best practices include:

Reasonably designed to prevent money laundering, terrorist financing and violations of trade sanctions through written policies, procedures and controls;

Where appropriate, designate a compliance officer to oversee the implementation of policies, procedures and controls;

provide relevant education and training to relevant personnel; and

Independently review, monitor and maintain policies, procedures and controls.

3. Definition

The following defined terms are widely used in the industry:

Money Laundering: The process of obtaining illicit proceeds that appears to be legitimate. This process is usually divided into three steps: placement, layering, and integration.

Placement: The process of depositing illicit proceeds by deposit or other means in a traditional financial institution.

Layering: The process of separating the proceeds of criminal activity from their source through the use of complex layers of financial transactions, such as converting cash into travelers checks, money orders, wire transfers, letters of credit, stocks, bonds, or the purchase of assets.

Consolidation: Using seemingly legitimate transactions to mask illicit gains, allowing laundered funds to be distributed back to criminals; reintegrating now clean funds into normal use.

Suspicious Activity: The use of the facility by users or non-users indicates that those involved in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are actions taken by the international community to prohibit or restrict the activities of those targeted. For example, they are used in:

Encourage targeted countries or regimes to change their behaviour;

exert pressure on targeted countries to comply with stated goals;

As a law enforcement tool when international peace and security are threatened and diplomatic efforts fail; or

Prevent and suppress terrorist financing or acts of terrorism.

4. Governance and Oversight

AG has appointed a Chief Compliance Officer to coordinate the implementation of the Anti-Money Laundering Policy and Policy Plan. The chief compliance officer's responsibilities also include developing an AML program, working with other stakeholders to revise AML policies, assessing new regulatory requirements, and investigating potentially suspicious or unusual activity. The platform also regularly provides anti-money laundering training to all employees.

5. Know Your Customer and Transaction Monitoring

The platform will take appropriate user due diligence and continuous monitoring measures in accordance with legal requirements. The platform will strive to prevent users from engaging in illegal or other unauthorized activities. The platform uses in conjunction with its software development and other service agreements, which are enforced through internal operational functions to ensure its compliance with applicable laws.

know your customer

A. Customer Due Diligence.

The platform employs risk-based CDD, which enables the platform to understand the nature and purpose of a user's relationship with the platform in order to develop a customer risk profile. To this end, the platform will collect certain document and non-document information appropriate to the account type and the nature of the services provided by Equity when opening an account. The platform maintains different CDDs for different clients