Anti-Money Laundering Policy

Betify Ltd ("Betify," "we," "our," or "us") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy sets out the measures we take to prevent our platform from being used for money laundering, terrorist financing, or other financial crimes.

As a provider of AI-powered gaming intelligence services, we recognize our responsibility to maintain the integrity of the financial system and support law enforcement efforts to combat financial crime. This policy applies to all employees, contractors, and third parties acting on behalf of Betify.

Our AML program is designed to comply with applicable laws and regulations, including but not limited to:

• European Union: 4th, 5th, and 6th Anti-Money Laundering Directives (AMLD)
• Malta: Prevention of Money Laundering Act (PMLA) and Prevention of Money Laundering and Funding of Terrorism Regulations
• United Kingdom: Proceeds of Crime Act 2002, Money Laundering Regulations 2017
• International: Financial Action Task Force (FATF) Recommendations
• Gaming Regulations: Malta Gaming Authority (MGA) AML/CFT requirements, UK Gambling Commission guidance

We conduct comprehensive risk assessments to identify, assess, and mitigate money laundering and terrorist financing risks. Our risk assessment considers:

We apply Customer Due Diligence measures to all customers before establishing a business relationship and on an ongoing basis. Our CDD process includes:

4.1 Identity Verification

• • Collection of full legal name, date of birth, and residential address
• • Verification against government-issued identification documents
• • Electronic identity verification using trusted data sources
• • Biometric verification where appropriate

4.2 Beneficial Ownership

For corporate customers, we identify and verify the beneficial owners (individuals who ultimately own or control more than 25% of the entity) and understand the ownership and control structure.

4.3 Purpose and Nature of Business Relationship

We obtain information about the intended purpose and nature of the business relationship to establish a baseline for monitoring.

We apply Enhanced Due Diligence measures in higher-risk situations, including:

• Politically Exposed Persons (PEPs): Individuals who hold or have held prominent public positions, their family members, and close associates
• High-Risk Countries: Customers from jurisdictions identified as high-risk by FATF or other relevant bodies
• Complex Structures: Customers with complex ownership structures or unusual business arrangements
• Unusual Transactions: Transactions that are unusually large, complex, or lack apparent economic purpose

We employ sophisticated AI-powered transaction monitoring systems to detect suspicious activity. Our monitoring includes:

• • Real-time monitoring of all transactions
• • Pattern analysis to detect unusual behavior
• • Threshold-based alerts for large transactions
• • Velocity checks for rapid transaction patterns
• • Cross-referencing with sanctions lists and PEP databases
• • Behavioral analytics to identify anomalies

When we identify suspicious activity, we follow a structured reporting process:

1. 1. Internal Escalation: Suspicious activity is immediately escalated to the Money Laundering Reporting Officer (MLRO)
2. 2. Investigation: The MLRO conducts an investigation to determine if a report is warranted
3. 3. SAR Filing: If warranted, a Suspicious Activity Report (SAR) is filed with the relevant Financial Intelligence Unit (FIU)
4. 4. Tipping-Off Prevention: We ensure that customers are not informed of any SAR filing (tipping-off is a criminal offense)
5. 5. Record Keeping: All investigations and decisions are documented and retained

We maintain comprehensive records in accordance with regulatory requirements:

All employees receive comprehensive AML training appropriate to their role:

• • Initial AML training upon joining
• • Annual refresher training
• • Role-specific training for high-risk positions
• • Updates on regulatory changes and emerging risks
• • Practical case studies and scenarios

Our AML program is overseen by senior management with clear lines of responsibility:

• Board of Directors: Ultimate responsibility for AML compliance
• Money Laundering Reporting Officer (MLRO): Day-to-day oversight of AML program
• Compliance Committee: Regular review of AML policies and procedures
• Internal Audit: Independent assessment of AML controls

For questions about our AML policies or to report suspicious activity: