DragonGame N.V.
Anti-Money Laundering (AML) Program
Compliance Procedures
It is the policy of DragonGame N.V. (the “Company”) to prohibit and actively prevent money laundering and any activity
that facilitates money laundering or the funding of terrorist or criminal activities. The Company strives to comply
with all applicable requirements under the legislations in force in the jurisdictions of the European Union members
in which the Company operates, pursuant to the Directive 2005/60/EC of the European Parliament and of the
Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money
laundering and terrorist financing and the forthcoming Fourth Directive on Money laundering.
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of
criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute
legitimate assets.
Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the
origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a
key difference between terrorist financiers and traditional criminal organizations.
Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods
used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder
funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions
may not be complex.
The Company or the group of companies of which the Company is part, is licensed and regulated by Curacao
eGaming to offer remote (on-line) games over the internet, under the National Decree August 18, 1998 No. 14.
Under the license conditions issued by Curaçao, the Company is required to have in place adequate measures to
prevent its systems from being used for the purposes of money laundering, terrorist financing or any other
criminal activity.
The Company is therefore obliged to follow the provisions contained in the Curaçao legal framework in particular
the National Decree August 18, 1998 No. 14 and the legislations in force in any other jurisdiction in which the
Company undertakes its activities.
2.1 The Company is fully committed to be constantly vigilant to prevent money laundering and combat the
financing of terrorism in order to minimize and manage risks such as the risks to its reputational risk, legal risk
and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to
be abused in furtherance of these crimes.
2.2 The Company will endeavor to keep itself updated with developments both at national and international level
on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all
times, the organization and its operations and safeguards its reputation and all from the threat of money
laundering, the funding of terrorist and other criminal activities.
2.3 The Company’s policies, procedures and internal controls are designed to ensure compliance with all
applicable laws, rules, directives and regulations relevant to the Company’s operations and will be reviewed and
updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place.
3.1 The Company will take reasonable steps to establish the identity of any person for whom it is proposed to
provide its service (hereinafter “ Players”). For this purpose the process for the registration of Players provided for
under the General Terms and Conditions of the Company provides for the due diligence process that must be
carried out before the opening of a user account.
3.2 The Company will keep at all times a secure online list of all registered Players and information and
documents will be retained in accordance with the applicable data protection obligations.
3.3 The Company will collect certain minimum Player identification information from each Player who opens an
account. The Company will not accept to open anonymous accounts or accounts in fictitious names such that the
true beneficial owner is not known. The information required will include at least:
a. Player’s date of birth (showing that the player is over eighteen (18) years of age);
b. Player’s first and last name;
c. Player’s place of residence;
d. Player’s credit card or banking information;
d. Player’s valid email address; and
e. Player’s username and a password.
3.4 Documents to verify the identity information received will be requested from the Player if and when there is
considered to be risk or uncertainty about the information provided and prior to any payment in excess of EUR
2,000 per occasion or when payments to the account are made in excess of EUR 2,000. These documents shall
include, to the extent permitted under the relevant data protection regulations:
a. A copy of a valid identity card or passport;
b. Proof of address;
3.5 The Company may supplement the use of documentary evidence by using other means which may include:
a. Independently verifying the Player’s identity through the comparison of information provided by the Player with
information obtained from a reporting agency, public database or other source;
b. Checking references with financial institutions; or
c. Obtaining a financial statement.
3.6 The Company will inform relevant Players that the Company may seek identification information to verify their
identity, and will compare Player identification information with government or international -provided lists of
suspected terrorists or sanction lists for example through the European Union or FATF on a monthly basis.
3.7 Any employee of the Company who becomes aware of an uncertainty in relation to the accuracy and
truthfulness of the Player information provided shall immediately notify the AML Compliance Person, who will
review the materials and determine whether further identification is required and or so that it may be determined
whether a report is to be sent to the relevant authorities.
3.8 If a potential or existing Player either refuses to provide the information described above when requested, or
appears to have intentionally provided misleading information, the Company will not open a new account and,
after considering the risks involved, consider closing any existing account. In either case, the AML Compliance
Person will be notified so that it may be determined whether a report is to be sent to the relevant authorities.
3.9 If a Player appears on an list of (suspected terrorists or otherwise sanctioned individuals the Company will
take the appropriate steps to immediately freeze and or lose the account of the Player.
3.10 If any material personal information of a Player changes, verification documents will be requested.
4.1 The Company will monitor account activity with special attention, and to the extent possible, the background
and purpose of any more complex or large transactions and any transactions which are particularly likely, by their
nature, to be related to money laundering or the funding of terrorism.
4.2 Monitoring will be conducted through the following methods: Transactions will be automatically monitored and
a report will be generated daily that show all transactions above 2000 EURO along with all the details of the users
making those transactions. An additional report will be generated daily per user that made a transaction above
2000 EURO detailing their collected ID documents, collected personal details, and their entire account transaction
history.
4.3 The AML Compliance Person will be responsible for this monitoring, will review any activity that the monitoring
system detects, will determine whether any additional steps are required, will document when and how this
monitoring is carried out, and will report suspicious activities to the relevant authorities.
4.4 Parameters that signal possible money laundering or terrorist financing include, but are not limited to:
a) Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent reason.
b) Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately
withdrawn or wired out.
c) Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent
specific purpose.
4.5 When an employee of the Company detects any activity that may be suspicious, he or she will notify the AML
Compliance Person. AML Compliance Person will determine whether or not and how to further investigate the
matter. This may include gathering additional information internally or from third-party sources, contacting the
government, freezing the account and/or filing a report.
4.6 The Company will not accept cash or non-electronic payments from Players. Funds may be received from
Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques
and any other method approved by the respective regulators.
4.7 The Company will only transfer payments of winnings or refunds back to the same route from where the funds
originated, where possible.
4.8 Transfers of funds between Players accounts shall prohibited.
4.9 To the extent the Company utilizes a third party to process and record payments to and from Player and
accounts, the Company will ensure the services provider has transaction monitoring systems in place which will
allow for screening of the transactions pursuant to these provisions and in accordance with the applicable
legislation. The AML Compliance Person shall be responsible to review the relevant service agreement with the
service provider to ensure the adequacy of the agreement.
4.10 Records relating to the financial transactions shall be maintained in accordance with the data protection and
retention requirements in the applicable jurisdiction of Curaçao.
The AML Compliance Person will report any suspicious transactions (including deposits and transfers) conducted
or attempted by, at or through a Player account involving EUR 2,000 or more of funds (either individually or in the
aggregate) where the AML Compliance Person knows, suspects or has reason to suspect:
a. The Player is included on any list of individuals assumed associated with terrorism or on a sanctions list;
b. The transaction involves funds derived from illegal activity or is intended or conducted in order to hide or
disguise funds or assets derived from illegal activity as part of a plan to violate or evade laws or regulations or to
avoid any transaction reporting requirement under law or regulation;
c. The transaction has no ordinary lawful purpose or is not the sort in which the Player would normally be
expected to engage, and after examining the background, possible purpose of the transaction and other facts, we
know of no reasonable explanation for the transaction; or
d. The transaction involves the use of the Company to facilitate criminal activity.
6.1 The Company will develop ongoing employee training under the leadership of the AML Compliance Person
and senior management. The training will occur on at least an annual basis. It will be based on the Company’s
size, its Player base, and its resources and be updated as necessary to reflect any new developments in the law.
6.2 The training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise
during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to
whom to escalate unusual Player activity or other red flags for analysis; (3) what employees’ roles are in the
Company’s compliance efforts and how to perform them; (4) the Company’s record retention policy; and (5) the
disciplinary consequences for non-compliance with legislation.