ANTI MONEY LAUNDRING POLICY

ZWEELER’s primary goal is to facilitate people in having fun and compete in the sports they love. It is for that reason that ZWEELER will happily support anyone (*) to join as long as FUN IS AND STAYS THE GOAL! The opposite is also true; IF ANYTHING ELSE BUT FUN becomes the goal of the player, ZWEELER will do everything within its power to protect, educate and assist the individual that has misunderstood the means of ZWEELERS existence.

(*) anyone legally allowed to join/compete

To prevent situations in which ZWEELER is (attempted to be) used for other means than FUN, The following guidelines are in place:

COMPLIANCY

ZWEELER aims to be fully compliant with the general license conditions and associated code of practice provisions (LCCP) under the Gambling Act 2005 (the Act) and in particular:

License condition 12.1.1 Anti Money Laundering and Terrorist Funding;

and

License condition 12.1.2. For remote operating licenses where any of the licensee’s equipment is located outside Great Britain,

… under the general license conditions and associated code of practice provisions (LCCP) under the Gambling Act 2005 (the Act) and Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business.

COMMITTMENT

ZWEELER is fully committed 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;

Be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risk such as the risks to its reputation, legal risk and regulatory risk;

The social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes;

To remain updated with developments both at national and international on any initiatives to prevent money laundering and the financing of terrorism;

OPERATIONAL MEASURES

In order to prevent Money laundering and Terrorist Financing to occur, ZWEELER,

Appointed 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;

Has taken reasonable steps to establish the identity of any person for whom it is proposed to provide its service. For this purpose the process for the registration of Players provided for under the General Terms and Conditions provides for the due diligence process that must be carried out before the opening of a User Account;

Retains a secure list of all registered Players;

Retains identification and transactional documentation as defined in the laws regulations and guidance notes;

Provides initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions;

Ensures that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities;

Examines with special attention, and to the extent possible, the background and purpose of any 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;

Report any suspicion or knowledge of money laundering or terrorism financing to the UK Gambling Commission, Victoria Square House, Victoria Square, Birmingham B2 4B;

Co-operate with all relevant administrative, enforcement and judicial authorities in their endeavor to prevent and detect criminal activity;

Transfer payments of winnings or refunds back to the same route from where the funds originated;

If no transaction has been recorded on a User Account for thirty (30) months, close the User Account and remit the balance in that account to the Player.