Company: Aldex Win Ltd

Registration No: 16207

License No: ALSI-202512034-FI1

Jurisdiction: Autonomous Island of Anjouan, Union of Comoros

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1. STATEMENT OF COMPLIANCE

1.1. Aldex Win Ltd (hereinafter — the "Company") is committed to high standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance.

1.2. This Policy is designed to comply with the Betting and Gaming Act 2005 of the Autonomous Island of Anjouan and international standards, including the Financial Action Task Force (FATF) recommendations.

1.3. The Company maintains a zero-tolerance approach to any attempt to use its platform for the laundering of funds derived from criminal activities.

2. APPOINTMENT OF AML COMPLIANCE OFFICER

2.1. The Company has appointed a designated Money Laundering Reporting Officer (MLRO) responsible for overseeing the implementation of this Policy.

2.2. The MLRO’s duties include monitoring suspicious activities, conducting staff training, and reporting to the Anjouan Offshore Authority or relevant Financial Intelligence Units (FIUs).

3. CUSTOMER DUE DILIGENCE (CDD) & KYC

The Company applies a Risk-Based Approach (RBA) to verify the identity of its users.

3.1. Standard Verification: Before any withdrawal or when a deposit threshold is reached (as determined by the MLRO), users must provide:

• A valid government-issued ID (Passport, Driving License, or ID Card).
• Proof of residence (Utility bill or bank statement not older than 3 months).
  3.2. Enhanced Due Diligence (EDD): Applied to high-risk customers, including Politically Exposed Persons (PEPs) or transactions exceeding $2,000 (or currency equivalent). This may require:
• Proof of Source of Wealth (SOW).
• Proof of Source of Funds (SOF).
  3.3. Identity Authentication: The Company reserves the right to request "liveness checks" (video verification) to ensure the document holder is the account owner.

4. TRANSACTION MONITORING

4.1. Real-Time Monitoring: All transactions are monitored for suspicious patterns, such as rapid turnover of funds without significant betting activity.

4.2. Thresholds: Any single transaction or aggregate transactions exceeding regulatory limits will be flagged for manual review.

4.3. Structured Transactions: The Company monitors for "smurfing" (breaking large transactions into smaller ones) to circumvent reporting requirements.

5. PROHIBITED ACTIVITIES & SANCTIONS

5.1. Sanctioned Jurisdictions: The Company does not provide services to individuals residing in countries listed on the FATF "Black" or "Grey" lists, or those subject to UN/EU sanctions.

5.2. Prohibited Methods: Use of anonymous payment methods or third-party accounts is strictly forbidden. Funds must be withdrawn to the same method used for the deposit.

5.3. Stolen Assets: Immediate account freeze and reporting will occur if there is a suspicion of using stolen credit cards or hacked e-wallets.

6. SUSPICIOUS ACTIVITY REPORTING (SAR)

6.1. If the Company has reasonable grounds to suspect that funds are the proceeds of crime, a Suspicious Activity Report (SAR) will be filed internally.

6.2. No "Tipping Off": According to Anjouan law, it is a criminal offense to inform the user that a SAR has been filed or that their account is under investigation for money laundering.

7. RECORD KEEPING

7.1. In accordance with Anjouan regulatory requirements, the Company maintains records of:

• User identification documents.
• Transaction history (deposits, bets, withdrawals).
• Internal and external SARs.
  7.2. These records are kept for a minimum of 5 (five) years after the business relationship has ended.

8. STAFF TRAINING

8.1. All employees involved in processing transactions and customer support receive mandatory AML/CTF training annually.

8.2. Training covers identification of "red flags," reporting procedures, and legal liability for non-compliance.

9. ACCOUNT CLOSURE AND ASSET FREEZING

9.1. The Company reserves the right to freeze funds and block accounts indefinitely if an AML investigation is ongoing.

9.2. Any attempt to provide false or misleading information during the KYC process will result in immediate termination of the contract.

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