AML Policy & Procedures of Final Enterprises N.V.

Know your customer (KYC) Policy
Registration To register an account at any of Final Enterprises N.V. websites, the player is required to enter the following details:
• Gender
• Full Name
• Date of Birth
• Email
• Country
• City
• Address
• Mobile Phone
• Username
• Password
• Currency

Age: FE does not allow any player under the age of 18 to register or take part in FEs services. It is not possible to register an account with the date of birth set to lower than 18 years of age, and if there is under any circumstances suspicion of a minor registering a fake date of birth, we will close the account till the customer is able to send a valid ID, and in some cases a face ID (picture where the customer is holding the ID next to his face).

First deposit: Upon the first deposit, all customers will receive an email explaining in detail about FEs KYC process, which mainly involves verifying their account information and chosen payment methods by sending documents. The customer will not be able to get a withdrawal approved until the relevant documents are approved by FEs payments team.

FE requires a valid government issued ID and proof of address in order to verify the customer’s name, date of birth/age, address and registered country. The proof of address needs to be recent, from the last three months, to prove they are currently living there. Customers also have to send documents proving their payment option. This is part of the first stage DD checks known as “Simplified Due Diligence” check and shall be carried out on all customers who reach EUR2000 in cumulative deposits or the equivalent in any other currency or upon first withdrawal request, whatever applies first.

At this stage, PEP and sanction checks are also carried out by relevant staff. Sanction lists consulted include ​Interpol, Europol, Consolidated EU Sanction List, UN Consolidated List of Targets, EEAS, Consolidated List. For PEP checks, customers are screened against CIA World Leaders Database; everypolitician.org; EU Members of Parliament. Should a customer appear on a sanction list, this shall be immediately escalated to the MLRO and the customer account shall be closed and reported to relevant authorities in Curacao or any other relevant jurisdiction. If a customer or close family member is discovered to be a PEP, this shall also be immediately flagged to the MLRO. The MLRO shall then decide whether to close the account and terminate the customer relationship, or whether to retain the customer relationship and keep the account open. If this decision is to keep the account open, the customer account shall be treated as high risk and subject to increased monitoring and fulfilment of the enhanced due diligence process.

The second stage of due diligence, known as the “Customer Due Diligence” stage, is carried out when the customer hits EUR10,000 in cumulative deposits or the equivalent in any other currency. At this stage, adverse media checks are carried out on the customer by using public sources. Therefore, ​depending on the country of residence and nationality, public sources are used to make adverse media checks on customers as necessary by using search engines such as Google, Bing, DuckDuckGo and referencing any media articles or other sources of public information.

The third stage of due diligence, known as the “Enhanced Due Diligence” process (“EDD”) shall be carried out for any customers, or any customers who have reached ​EUR50,000 in cumulative deposits or the equivalent in any other currency. At this stage, therefore, the customer shall be requested to provide a document proving the source of wealth.

Additionally, in all cases for Visa, MasterCard and bank transfers, FE would require copies of the used credit card, where you can clearly see a name and the first six and four last digits of the credit card number. If a bank account is used, FE would also need to verify that the bank account belongs to the same person as the customer, by verifying their bank statement showing customers name, bank account number and the bank logo.

For Skrill deposits and withdrawals FE would require a screenshot of the customer Skrill account, showing the email address registered as well as the customer’s name.

All suspicious transactions shall be immediately escalated to the MLRO. The MLRO will then decide whether the filing of a suspicious transaction report with the relevant authorities in Curacao and/or the relevant country of residence of the customer as appropriate is required. If a report is not made, the MLRO shall document the reason as to why this decision was made and retain all necessary information on the case.

Restricted Countries: Where strict regulations are in place prohibiting gambling, FE does not accept players. The restricted countries are clearly stated in FE’s Terms and Conditions that each player agrees upon when registering an account. The player will not be able to choose a restricted country upon registration nor register using an IP address from a restricted country.

The restricted countries are Armenia, Australia, Bulgaria, Denmark, France, Spain, Israel, Netherlands, UK, Curacao and the United States of America.

FE will also verify customers registered country by requesting proof of address before approving any withdrawals.

Fraudulent Activity: FE will demand full verification of customer account when fraudulent behaviour or patterns is detected. Fraudulent activity or suspicious patterns on customer accounts are detected by:
• name and address mismatch
• insufficient amount of information on user profile
• transaction velocity and amount limits
• registered full name and credit card name mismatch
• registrations from the same IP
• registrations with the same or similar name, address, email, phone number
• usage of blocked credit cards in other customer accounts
• high-risk payment methods
• jurisdiction/country of residence
• value of deposits
• detection of little gameplay in comparison to the size of deposits/funds available on the account.

Anti-money laundering (AML) policy
General: FE does not allow withdrawals to payment methods that customers have never used as a deposit method. (Not including bank account transfers). FE does not send money to other accounts than the one that has made a deposit. During the withdraw process, FE verifies that the person receiving a withdrawal is the same person who has made a deposit. Withdrawals to a different country than the deposit was made from is not allowed. Credit cards that are issued in a different country than the customer country are monitored separately for any fraudulent activity.

The corporate director is the appointed MLRO. Any suspicious activity of money laundering will be forwarded to the MLRO.

Pay-out management
General Upon requesting a withdrawal, the customer will either receive the same email as upon the first deposit, explaining which documents are required, or receive an update on their current KYC status.

Due to our KYC policy, withdrawals need to be requested to the last account or card which the customer used upon depositing or in some cases the payment method which the customer has deposited the most with.

In the case that the customer has used a deposit method that cannot be withdrawn to, the customer will get the withdrawal sent to either another payment method/account used by the customer, or by bank transfer. In the event that a withdrawal is transferred to a different card or account that has been used to deposit, FE will make sure that both account and card belongs to the customer, by verifying documents.

FE does not allow any payment in cash or by cheque.

Fraud Management: FE may at any point review that a player does not comply with FEs Terms and Conditions, the player might have:
• Provided insufficient or fake details upon registration
• Sent in fake or altered documents • Created more than one account to abuse bonus campaigns
• Participated in same bonus promotion with other players from the same IP
• Shared same payment accounts with other players
• Charged back a credit card deposit
• Shared the same IP address or device with a chargeback accountIn such cases, FE will investigate the account and contact the player for more information.FE might take the following action:
• Request additional KYC documentation in accordance with due diligence processes described above;
• Freeze funds in the player account;
• Cancel winnings and refund the deposits in the account;
• Close the player account;
• Blacklist the players IP, device and/or payment account;
• Reporting to relevant AML authorities by the MLRO.

Multiple Accounts Management
General: FE will monitor registrations per IP, and mark the accounts accordingly. Multiple accounts per IP is possible (not permitted), but it’s not possible to register multiple accounts with the same email address. FE will also temporarily close accounts that are registered to the same name and date of birth until the customer has verified his/her account by sending in the relevant KYC documents.All data held as described within this AML/KYC Policy shall be retained for at least five years from the date of last account transaction of the relevant player, or longer should any other relevant laws so prescribe.

Final Enterprises N.V., Kaya Richard J. Beaujon z/n, Curaçao