Policy

Our Best Practices Include:

• Adopting written policies, procedures, and controls reasonably designed to guard against ML, TF, and sanctions violations
• Designating a Chief Compliance Officer to oversee the implementation of policies, procedures, and controls
• Providing appropriate education and training to relevant personnel on AML/CFT compliance
• Conducting independent reviews, monitoring, and maintenance of policies, procedures, and controls
• Implementing risk-based approaches throughout the customer lifecycle
• Utilizing advanced technology solutions including blockchain analytics and transaction monitoring systems

Objectives of This AML Policy:

The objectives of this AML Policy are to:

• Establish clear procedures, systems, and controls to prevent and detect money laundering and terrorist financing
• Ensure compliance with all applicable AML/CFT regulations and international standards
• Protect Prime Roll and its users from being exploited for illicit purposes
• Define roles and responsibilities for AML compliance across the organization
• Outline customer due diligence, monitoring, and reporting procedures
• Maintain the integrity and reputation of Prime Roll as a responsible gaming operator

The CCO's Duties Include:

• Developing and updating AML/CFT initiatives and policies
• Working with stakeholders to revise the AML Policy as regulations evolve
• Assessing new regulatory requirements and ensuring compliance
• Investigating potentially suspicious or unusual activity
• Coordinating with law enforcement and regulatory authorities as required
• Overseeing customer due diligence and transaction monitoring programs
• Submitting suspicious transaction reports ("STRs") to relevant Financial Intelligence Units
• Managing AML training programs for employees
• Conducting periodic risk assessments of Prime Roll's ML/TF exposure

CCO Authority and Independence:

The CCO has an independent and direct reporting line to the Board of Directors and will act on his or her own authority. The CCO is authorized to submit suspicious transaction reports to the appropriate Financial Intelligence Unit ("FIU") without requiring prior approval to do so.

Employee Obligations:

Should any employee, director, or officer have reason to believe or suspect that any transaction, or potential transaction, could involve:

• The proceeds of criminal conduct
• Money laundering activity
• Terrorist financing
• Sanctions violations
• Any other illicit activity

They must report this to the CCO without delay. Failure to report suspicious activity may result in disciplinary action, up to and including termination of employment.

Training and Awareness:

As the business grows and the number of employees increases, Prime Roll will ensure that employees receive appropriate training to:

• Identify red flags and suspicious activity
• Understand their AML/CFT obligations
• Follow proper reporting procedures
• Stay current with regulatory developments

Prime Roll will provide AML/CFT training to its employees on a regular basis, with training tailored to each employee's role and responsibilities.

5.1 Risk-Based Customer Due Diligence (CDD)

Prime Roll has adopted risk-based Customer Due Diligence ("CDD") processes to enable it to develop a customer risk profile. These processes involve collecting certain information on customers at the onboarding stage and continuously monitoring customer activity.

Prime Roll's CDD Includes:

• Collecting Customer Information

Prime Roll will collect details on each customer to form a reasonable belief that it knows the identity of its customers. Prime Roll may collect such details as:

• Email address
• Wallet address
• Full legal name
• Date of birth
• Country of residence
• Postal code/address
• Government-issued identification documents
• Selfie verification (for identity confirmation)

(Collectively, "KYC Information")

Prime Roll may collect KYC Information at various stages, including account registration, before processing withdrawals, or when triggered by risk-based thresholds. Prime Roll utilizes Sumsub, a trusted third-party service provider, to help determine the validity of information provided by customers and to conduct identity verification.

• Identity and Age Verification

Prime Roll verifies that all customers are 18 years of age or older (or the legal gambling age in their jurisdiction, whichever is higher). Age and identity verification are conducted using government-issued identification documents verified through our third-party KYC provider.

• Excluding and Geoblocking Prohibited Jurisdictions

Customers are notified at onboarding that Prime Roll does not offer services in jurisdictions where such services are not permitted to be offered ("Prohibited Jurisdictions"). Customers must declare that they are not located in a Prohibited Jurisdiction.

Prime Roll has implemented IP address-based geo-blocking of identified Prohibited Jurisdictions to prevent access from these locations.

• Excluding and Geoblocking Sanctioned Jurisdictions

Customers are notified at onboarding that Prime Roll does not offer services in jurisdictions subject to United States, European Union, United Nations, or other global sanctions or watch lists, including but not limited to:

• Iran
• Cuba
• North Korea
• Syria
• Crimean region of Ukraine
• Any other comprehensively sanctioned territories

(Collectively, "Sanctioned Jurisdictions")

Customers must declare that they are not located in a Sanctioned Jurisdiction and are not personally subject to international sanctions. Prime Roll has implemented IP address-based geo-blocking of identified Sanctioned Jurisdictions.

• Screening for Sanctioned Parties

Before processing deposits or withdrawals, Prime Roll screens customer wallet addresses against applicable sanctions databases. Such screening measures rely on third-party blockchain forensics vendors such as Chainalysis or similar services.

• Corporate and Non-Natural Persons

At this time, Prime Roll does not permit accounts for corporate entities or non-natural persons. All accounts must be held by individual natural persons who are of legal gambling age.

5.2 Ongoing Transaction Monitoring

Prime Roll performs ongoing monitoring of its customers in order to detect any behavior or circumstances that might indicate money laundering, terrorist financing, sanctions breaches, or other illicit activity.

Prime Roll Has Implemented the Following Monitoring Processes:

• Transaction Monitoring for Sanctioned or Prohibited Jurisdictions

Prime Roll conducts a combination of manual and automated transaction monitoring processes to identify "red flag" behavior. Where such red flag behavior is identified, Prime Roll may:

• Refuse to process withdrawal attempts
• Suspend the customer's account
• Require additional information from the customer
• Conduct Enhanced Due Diligence (EDD)

Prime Roll will endeavor to limit any attempted customer account funding from Prohibited Jurisdictions where the associated wallet address indicates that the customer or the customer's funds are located in such a jurisdiction.

For example, Prime Roll may prohibit a customer from funding their account using a known exchange wallet from a Prohibited Jurisdiction, as this may indicate that the customer is located in or subject to that jurisdiction's regulations.

Customers will have the ability to provide additional information to address any suspension as part of Prime Roll's ongoing transaction monitoring and customer due diligence standards.

• Transaction Monitoring for Sanctioned Parties

Prime Roll will periodically re-screen customers' wallet addresses against applicable sanctions databases to ensure ongoing compliance.

• Identification of Unusual Activity

Prime Roll monitors account activity for unusual:

• Transaction size
• Transaction volume
• Transaction patterns
• Transaction types

Monitoring takes into account risk factors, customer profiles, and red flags. Monitoring is conducted by running regular reports of unusual, high-risk, or suspicious customer activity.

• Examples of unusual activity include:

• Rapid deposits followed immediately by withdrawal requests
• Minimal or no gameplay between deposits and withdrawals
• Multiple failed deposit attempts from different wallet addresses
• Sudden large increases in deposit or withdrawal amounts
• Transactions inconsistent with the customer's known profile
• Coordinated activity across multiple accounts

• Anti-Mixing and Anonymity-Enhancing Technology Measures

Prime Roll does not allow the use of anonymity-enhancing technologies such as:

• Mixers or tumblers
• Privacy coins designed to obscure transaction origins
• Technologies designed to mask the source or destination of funds

Where Prime Roll becomes aware that an anonymity-enhancing technology is being used on the Prime Roll platform, Prime Roll will disallow such use and may suspend the associated account.

Prime Roll may also take steps to address suspicious deposit or withdrawal patterns. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk.

• Chainalysis Review

Each cryptocurrency deposit and withdrawal is analyzed through Chainalysis (or similar blockchain analytics provider) and reviewed for signs of:

• Fraud
• Suspicious behavior
• Links to illicit activities
• Sanctions violations
• High-risk wallet addresses

A customer's account will be suspended and reviewed upon alert of potential illicit behavior. Sufficient proof of wealth and source of funds may be requested from high-risk accounts.

Prime Roll may refuse to process withdrawals to certain "high-risk" addresses as determined in consultation with Chainalysis risk scoring or similar blockchain forensics tools.

• Withdrawal Threshold KYC

Any account's withdrawal function may be suspended until adequate KYC due diligence has been carried out once that account has reached a withdrawal threshold dependent on:

• The account's risk characterization
• The account's lifetime activity
• The customer's transaction history
• Other risk factors assessed according to Prime Roll's sole discretion

This threshold-based KYC requirement applies independently of other monitoring measures and ensures that higher-value withdrawals are subject to appropriate verification.

• Multiple Account Detection (Ban Evasion)

Prime Roll will utilize third-party service providers and internal systems to detect the use by one customer of multiple accounts, which is in breach of Prime Roll's Terms of Service.

Prime Roll prohibits:

• Creating multiple accounts to circumvent limits or restrictions
• Peer-to-peer account transfers within the Prime Roll platform infrastructure
• Any attempts to evade account suspensions or bans

Any attempts to circumvent these restrictions will be treated as a red flag and may result in account suspension, forfeiture of funds, and permanent ban.

• Time Zone and Location Monitoring

Prime Roll has implemented time zone controls which check customers' device location information against restricted jurisdictions to determine whether customers are attempting to use VPNs, proxy servers, or other software to mask their true location.

Any indication that a customer is attempting to access Prime Roll from a Prohibited or Sanctioned Jurisdiction will result in account suspension and investigation.

• Platform Feature Monitoring

Prime Roll monitors the use of its unique features to detect potential abuse:

• VIP System Abuse: Monitoring for accounts that wager unusually large amounts solely to gain VIP XP without normal gameplay patterns
• PrimeOrb Trading: Monitoring PrimeOrb customization purchases for unusual patterns that may indicate value transfer
• Loot Box Activity: Identifying unusual loot box purchase or redemption patterns
• Battle and Challenge Abuse: Detecting coordinated activity in battles or challenges that may indicate collusion or value transfer
• Rakeback Exploitation: Monitoring for patterns suggesting rakeback is being used for purposes other than intended

• Vendor Management

Prime Roll will periodically assess the strength of its key third-party service providers (including KYC providers, blockchain analytics vendors, and payment processors) to determine whether:

• Additional services are needed
• The service provider is performing in accordance with contractual obligations
• Other remedial action is necessary for Prime Roll to comply with this AML Policy

Prime Roll may request information from any third-party service provider as part of its vendor review process.

• Compliance Innovation

In addition to vendor management, Prime Roll will continuously monitor emerging compliance technologies and blockchain-native compliance tools to determine whether their use on the Prime Roll platform would be viable.

Prime Roll may run test or trial mechanisms on a limited basis with compliance vendors to determine their effectiveness. Blockchain-native compliance tools may include:

• Fraud prevention services
• On-chain KYC providers
• Decentralized identity verification systems
• Advanced transaction tracing tools
• Other tools designed to reflect the technological features of blockchain platforms

5.3 Enhanced Due Diligence (EDD)

Whenever a red flag is triggered, the relevant customer's account will be suspended and Prime Roll will perform Enhanced Due Diligence ("EDD").

EDD May Include, But Is Not Limited To, Requiring Customers to Provide:

• Full legal name (as it appears on government-issued identification)
• Country of citizenship
• Permanent residential address (must be a residential or business street address)
• Identification number (passport number and country of issuance, taxpayer identification number, national ID number, or other government-issued document number)
• Government-issued identification document (e.g., passport, national ID card, driver's license with photo)
• Selfie verification (photograph of the customer holding their identification document)
• Proof of address (utility bill, bank statement, or other official document showing residential address)
• Source of funds (explanation and documentation of the origin of funds used on Prime Roll)
• Source of wealth (explanation and documentation of the customer's overall wealth and financial situation)
• Employment information (occupation, employer name, industry)
• Purpose of account usage (explanation of intended use of Prime Roll services)
• Transaction history from originating exchanges or wallets

Prime Roll may use Sumsub or other third-party service providers to verify any of the above information.

Circumstances That May Trigger EDD:

• High-value deposits or withdrawals
• Cumulative transaction volumes exceeding risk thresholds
• Unusual transaction patterns
• Wallet addresses flagged by blockchain analytics
• Customers from higher-risk jurisdictions
• Failed or inconsistent KYC information
• Behavioral red flags identified through monitoring
• Law enforcement or regulatory inquiries
• Media reports or adverse information
• Any other circumstances determined by Prime Roll's risk assessment

5.4 Customer Acceptance and Blocking Policy

Prime Roll Will Not Onboard and Will Block or Suspend Customers Who:

• Do not provide the identification information requested by Prime Roll within a reasonable timeframe
• Provide fake, forged, or fraudulent identification documents or information
• Adopt measures to conceal their true location, including using VPNs, proxy servers, or other tools to circumvent geo-blocking
• Are from Prohibited or Sanctioned Jurisdictions as defined in this policy
• Are subject to United States, European Union, United Nations, or other global sanctions or watch lists
• Are under 18 years of age or below the legal gambling age in their jurisdiction
• Are identified as problem gamblers or have self-excluded from Prime Roll or other gambling platforms
• Have mental health issues that make gambling inappropriate (where Prime Roll becomes aware)
• Deposit funds which originate from exchanges, mixers, or wallets in Prohibited or Sanctioned Jurisdictions
• Fail Enhanced Due Diligence requirements when requested
• Are identified through blockchain analytics as having links to illicit activities, fraud, or high-risk sources
• Create or attempt to create multiple accounts in violation of Terms of Service
• Engage in collusion, fraud, or exploitation of Prime Roll's platform features
• Are subject to criminal investigations related to financial crimes (where Prime Roll becomes aware)

Additional Discretionary Blocking:

In addition, Prime Roll reserves the right to block and suspend players for any other reason at its sole discretion, including but not limited to:

• Violation of Terms of Service
• Abusive behavior toward staff or other customers
• Attempting to manipulate or exploit platform features
• Providing false or misleading information
• Any conduct that Prime Roll determines poses a risk to the platform or other users

Account Closure and Fund Handling:

When an account is blocked or suspended:

• Prime Roll will notify the customer via email (where possible and appropriate)
• Pending bets or gameplay will be settled according to Terms of Service
• Legitimate withdrawable balances may be returned to the customer after appropriate due diligence (subject to regulatory obligations)
• In cases involving fraud, money laundering, or other illicit activity, funds may be frozen pending investigation and may be reported to authorities
• Prime Roll reserves the right to forfeit funds in cases of Terms of Service violations

6.1 Suspicious Transaction Reports (STRs)

If a customer is identified as:

• Being on a sanctions list
• Linked to money laundering, terrorist financing, or other criminal activities
• Engaging in suspicious transactions or behavior
• Involved in potential fraud or illicit conduct

Prime Roll will make an appropriate report to the relevant Financial Intelligence Unit ("FIU") or regulatory authority as required by applicable law.

6.2 Reporting Standards

Prime Roll's reporting procedures adhere to the following standards:

• Timeliness: Suspicious activity reports are filed promptly upon identification
• Confidentiality: STR filings are kept strictly confidential and are not disclosed to the subject of the report
• Completeness: Reports include all relevant information, documentation, and transaction details
• Legal Compliance: Reports comply with all applicable legal and regulatory requirements
• Documentation: All suspicious activity and reporting decisions are documented and retained

6.3 Cooperation with Authorities

Prime Roll will fully cooperate with law enforcement and regulatory authorities in investigations related to money laundering, terrorist financing, or other criminal activities. This includes:

• Providing transaction records and account information as legally required
• Responding to information requests in a timely manner
• Maintaining confidentiality regarding ongoing investigations
• Following lawful instructions regarding account freezes or seizures
• Testifying or providing evidence as required by law

6.4 Record Retention

Prime Roll maintains comprehensive records of:

• Customer identification and verification documents
• Transaction histories and account activity
• Suspicious activity reports and internal investigations
• Communications with customers regarding AML/CFT matters
• Communications with regulators and law enforcement
• AML training records and policy documentation

Records are retained for a minimum period as required by applicable law, typically at least 5 years from the date of the transaction or account closure.

7.1 Training Program

Prime Roll provides AML/CFT training to employees on a regular basis, including:

• Initial onboarding training for all new employees
• Annual refresher training for all staff
• Role-specific training for employees with AML/CFT responsibilities
• Ad hoc training when regulations change or new risks emerge

7.2 Training Content

Training covers:

• Overview of money laundering and terrorist financing
• Applicable laws and regulations
• Prime Roll's AML Policy and procedures
• Red flags and suspicious activity indicators
• Customer due diligence requirements
• Reporting procedures and obligations
• Confidentiality requirements
• Consequences of non-compliance
• Case studies and practical examples

7.3 Training Recordkeeping

Prime Roll maintains records of all training provided, including:

• Date and duration of training
• Topics covered
• Employees who attended
• Training materials used
• Assessment results (where applicable)

• Our customer base and their geographic distribution
• Our products and services (including VIP system, PrimeOrbs, loot boxes, battles, challenges)
• Our transaction types and volumes
• Our delivery channels (web-based platform)
• Our technology infrastructure (crypto payments, blockchain interactions)
• Emerging threats and typologies

Risk Assessment Process:

1. Identify risks based on internal data, regulatory guidance, and industry information
2. Assess the likelihood and potential impact of identified risks
3. Evaluate the adequacy of existing controls
4. Implement additional controls where gaps are identified
5. Monitor the effectiveness of controls on an ongoing basis
6. Review and update the risk assessment regularly (at least annually)

Risk assessment findings inform updates to this AML Policy and Prime Roll's overall compliance program.

• Evaluate the effectiveness of policies, procedures, and controls
• Identify deficiencies or areas for improvement
• Ensure compliance with applicable laws and regulations
• Test the adequacy of transaction monitoring systems
• Review suspicious activity reporting processes
• Assess training effectiveness

Independent reviews may be conducted by:

• Internal audit teams (where sufficiently independent)
• External audit firms
• Compliance consultants
• Regulatory examiners

Findings from independent reviews are reported to the Board of Directors and senior management, and remedial actions are implemented promptly to address any identified deficiencies.

We Are Committed To:

• Staying informed about regulatory developments and industry best practices
• Investing in technology to enhance our detection and prevention capabilities
• Collaborating with industry peers, regulators, and law enforcement
• Adapting our policies to address new risks and vulnerabilities
• Maintaining transparency with regulators and stakeholders
• Fostering a culture of compliance throughout the organization

For AML-Related Inquiries:

If you have questions about our AML Policy or need to provide information related to AML compliance, please contact:

Prime Roll Compliance Team

For Reporting Suspicious Activity:

If you wish to report suspicious activity on the Prime Roll platform:

All reports will be treated with strict confidentiality and investigated promptly.

• Changes in applicable laws and regulations
• Evolving industry best practices
• New risks identified through risk assessments
• Lessons learned from monitoring and investigations
• Feedback from regulators or independent reviewers

Prime Roll reserves the right to update this policy at any time. The "Last Updated" date at the top of this page indicates when the policy was most recently revised. We encourage all users and employees to review this policy periodically.

Major changes to this AML Policy will be subject to approval by Prime Roll's Board of Directors or designated senior management.

Money Laundering (ML): The process of concealing the origins of illegally obtained money, typically by means of transfers involving legitimate businesses, foreign banks, or complex transactions. Money laundering generally involves three stages:

• Placement: Introducing illegal proceeds into the financial system
• Layering: Disguising the origins of criminal proceeds through complex transactions
• Integration: Reintroducing laundered money into the economy as apparently legitimate funds

Terrorist Financing (TF): The provision or collection of funds with the intention that they be used, or in the knowledge that they will be used, to carry out terrorist acts or to support terrorist organizations.

Suspicious Activity: Transactions, behaviors, or patterns that suggest potential fraud, money laundering, terrorist financing, sanctions violations, or other illegal activities.

Sanctions: Measures imposed by governmental or international bodies (such as the United States, European Union, United Nations, or other authorities) to restrict activities with targeted entities, individuals, or nations.

Know Your Customer (KYC): The process of verifying the identity of customers and assessing their risk profile for money laundering or terrorist financing.

Customer Due Diligence (CDD): The measures taken to identify customers and verify their identity, understand the nature and purpose of customer relationships, and assess money laundering and terrorist financing risks.

Enhanced Due Diligence (EDD): More extensive customer due diligence measures applied to higher-risk customers, transactions, or situations.

Red Flags: Indicators or warning signs that may suggest suspicious activity requiring further investigation.

Prohibited Jurisdictions: Countries, territories, or regions where Prime Roll does not offer services because such services are not legally permitted.

Sanctioned Jurisdictions: Countries, territories, or regions subject to comprehensive economic or trade sanctions by the United States, European Union, United Nations, or other international bodies.

• Operating with integrity and in compliance with all applicable AML/CFT laws and regulations
• Protecting our platform from being exploited for illicit purposes
• Cooperating fully with law enforcement and regulatory authorities
• Maintaining robust controls to detect and prevent money laundering and terrorist financing
• Training our staff to recognize and respond to suspicious activity
• Continuously improving our AML compliance program
• Being transparent with our customers about our AML obligations
• Treating customers fairly while fulfilling our compliance responsibilities