AML/CFT Policy

ANTI-MONEY LAUNDERING (AML) AND COUNTERING THE FINANCING OF TERRORISM (CFT) POLICY

Company: 21Orbit N.V. Effective Date: June 27, 2026 Version: 1.0

1. Introduction and Commitment

21Orbit N.V. is fully committed to preventing money laundering and terrorist financing. As a CGA licensee under the National Ordinance on Games of Chance (LOK), we comply with all applicable Curaçao laws, including:

National Ordinance on Identification when Rendering Services (LID)
National Ordinance on the Reporting of Unusual Transactions (LMOT)
CGA AML/CFT Policy and Guidelines (2025)
AML reporting system requirements

This policy applies to all operations, employees, contractors, affiliates, and third parties.

2. Legal and Regulatory Framework

The Company adheres to:

LOK (National Ordinance on Games of Chance)
LID and LMOT (as amended)
CGA directives and risk-based approach
FATF Recommendations and Caribbean FATF (CFATF) standards
Sanctions regimes (UN, EU, and others)

3. Risk-Based Approach

We implement a documented risk-based approach:

Business Risk Assessment (BRA): Annual assessment covering customers, products, delivery channels, geography, and technology (including crypto).
Customer Risk Assessment (CRA): Players are classified as Low, Medium, or High risk. Higher-risk customers receive Enhanced Due Diligence (EDD).

4. Customer Due Diligence (CDD)

Standard CDD: At registration or before NAf 4,000 cumulative deposits/transactions:
1. Full name, date of birth, residential address, email, phone
2. Government-issued photo ID verification
Enhanced Due Diligence (EDD) for:
1. High-risk jurisdictions
2. Politically Exposed Persons (PEPs)
3. Large or unusual transactions
4. Crypto deposits
5. Source of funds / source of wealth verification required
Ongoing monitoring of player activity.

Accounts are frozen or closed if CDD cannot be completed.

5. PEP, Sanctions & Adverse Media Screening

Screening at onboarding and ongoing (real-time where possible).
UN, EU, and other sanctions lists.
PEP status triggers mandatory EDD and senior management approval.

6. Transaction Monitoring

Automated systems monitor for red flags such as:
1. Rapid deposit/withdrawal cycles
2. Structuring to avoid thresholds
3. Inconsistent betting patterns
4. Crypto mixer or high-risk wallet involvement
Unusual transactions are investigated and reported.

7. Reporting of Unusual Transactions

8. Crypto / Virtual Asset Requirements

Crypto accepted only for gambling activity.
Strict segregation of player, operational, and treasury wallets.
Blockchain analytics tools for wallet screening and transaction monitoring.
Enhanced due diligence for crypto transactions.
Compliance with CGA Crypto Guidelines (phased implementation).

9. Money Laundering Reporting Officer (MLRO)

The Company appoints an independent MLRO (Compliance Officer) who:

Oversees the AML/CTF program
Has direct access to senior management
Ensures staff training and internal reporting
Files UTRs with goAML

10. Staff Training and Awareness

Mandatory initial and annual training for all staff.
Specialized training for customer-facing and compliance roles.
Records of training are maintained.

11. Record Keeping

CDD, transaction, and monitoring records retained for a minimum of 5 years (or longer as required by law).
Records are secure, searchable, and available to the CGA upon request.

12. Internal Controls and Auditing

Independent audits of the AML/CTF program.
Annual policy review or upon regulatory changes.
Non-compliance may result in disciplinary action and regulatory reporting.

13. Policy Approval

This policy is approved by senior management and forms part of the Company’s licensing obligations.