Introduction Three Aces Curaçao N.V. is licensed and regulated by the Governor of Curaçao to offer remote (online) games over the internet under the Remote Gaming Regulations. Under the license conditions issued by Curaçao Authorities, Megabets247 is required to have in place adequate measures to prevent its systems from being used for purposes of money laundering, terrorist financing, or any other criminal activity. Megabets247 is therefore obliged to follow the provisions contained in the legal framework, namely the Proceeds of Crime Act 2002 (Part 7) and The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulation no. 692 of June 26, 2017, along with any guidance notes issued by the relevant authorities.

• Appoint one of its senior officers as the designated Money Laundering Reporting Officer (MLRO), whose responsibilities include the duties required by the laws, regulations, and guidance notes. • All instances of suspected money laundering attempts must be reported to the MLRO, but that suspicion must not be conveyed to the customer. Further actions must await consents. The MLRO is responsible for liaising with legal authorities, submitting Suspicious Activity Reports (SARs), and seeking consents from the responsible legal authority in the relevant jurisdiction. • Take reasonable steps to establish the identity of any person for whom it is proposed to provide services. Megabets247 will implement a comprehensive Know Your Customer policy to assist in tackling not just money laundering threats but also other fraud threats. Customers will be advised at registration and via the supporting website that the company utilizes online verification tools. In cases where these tools do not meet criteria, ID and address verification documents will be requested. • Keep a secure online list of all registered players at all times. • Retain identification and transactional documentation as defined by laws, regulations, and guidance notes. • Operate without any cash elements to mitigate risks associated with counterfeit monies. The company’s systems will record all transactions on player accounts. These account histories will be subject to regular and continual checks for fraud and social responsibility indicators. Unusual betting patterns or winning patterns will also be cross-referenced to call history to ensure no collusion or illicit activities by staff. • Maintain a register of high-risk or politically exposed customers, subjecting those accounts to greater scrutiny. • Ensure that staff found engaging in illegal or inappropriate behavior undergo investigatory and disciplinary procedures as outlined in employment law directives.

Megabets247 ensures compliance by providing initial and ongoing training to all relevant staff, including: • Staff responsibilities; • Procedures for identifying players; • Monitoring player activity; • Record-keeping; • Reporting unusual or suspicious transactions; • Unusual betting patterns and deposit/withdrawal patterns; • Customer verification and identity theft; • Enhanced due diligence (EDD) for high-risk clients, including Politically Exposed Persons (PEPs). Enhanced Due Diligence (EDD) includes verifying the customer’s identity with documents such as a passport, ID card, utility bill, or bank statement. Additional checks include the customer’s occupation, assets, and spending behavior to flag and monitor high-risk customers.

Megabets247 has adopted strict policies, including: • Prohibiting anonymous accounts or accounts with fictitious names. • Prohibiting cash deposits. • Accepting funds only through approved methods, such as credit cards, debit cards, or electronic transfers. • Prohibiting registrations for individuals under 18. • Allowing only one account per person. Megabets247 reserves the right to close accounts after 30 months of inactivity and remit the balance to the regulator if the player cannot be located. Furthermore, Megabets247 reserves the right to monitor and report any fraudulent or suspicious behavior to regulatory authorities and payment service providers. Funds connected to illicit activities may be retained at the company’s discretion.