Introduction

Anti-Money Laundering Countering Terrorism Financing Policy (hereinafter - the “AML/CTF Policy”) is designated to prevent and mitigate possible risks of Us ( Elite4game company) to be involved in any kind of illegal activity. Also, AML/CTF Policy aims to protect Clients' funds and interests.

This Anti-Money Laundering and Countering Terrorist Financing Policy (hereinafter referred to as the Policy or also as AML/CTF) is Company’s strategy used to prevent and effectively combat money laundering, terrorist financing and other financial crimes.

The aim of this Policy is to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable laws and requirements.

The Policy will be reviewed and updated on a regular (at least once per year) and ad-hoc basis to ensure appropriate procedures and internal controls are in place to account for both changes in law regulations and changes in Company’s business.

Company defines money laundering as any activity that is carried out in an attempt to misrepresent and/or hide the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities. Money laundering always consists of primary (predicate) crime and in often case it’s fraudulent activity. Examples of types of fraudulent activities inter alia include insider trading, market manipulation, ponzi schemes, cybercrime, crypto investing activity with malfunctioned account and other investment-related fraudulent activity.

We ensure complete compliance with laws and regulations pertaining to AML/CTF. All our affiliates (subsidiaries, holding companies and other related entities) are obligated to comply with the Policy and with all applicable AML/CTF laws and regulations as well as Company requires its management and employees to adhere to these standards to prevent use of the services for money laundering purposes.

Company will analyze the information and ensure that we have a reasonable belief that we know the true identity of customer (KYC) by using risk-based procedures to verify and document the accuracy of the information we get about our customers.

Based on the risk, and to the extent reasonable and practicable, Company will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available.

This AML/CTF Policy covers the following aspects:

Verification Procedures;

Compliance Officer;

Sanctions, adverse media and PEP lists screening;

Monitoring Transactions;

Risk Assessment;

Confidentiality and personal data protection.

1. Verification Procedures

Customer Due Diligence – ‘CDD’ is one of the international standards used to prevent illegal activities. Based on CDD, we have developed our own verification procedures in accordance with standards of anti-money laundering and ‘Know Your Customer’ (KYC) frameworks and best market practice.

1.1. Identity Verification

Our identity verification procedure requires the User to provide us reliable, independent source documents, data or information. For such purposes we reserve the right to collect User’s identification information for the AML/CTF Policy purposes.

We will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and we reserve the right to investigate certain Users who have been determined to be risky or suspicious in regards of AML/CTF regulation

We reserve the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, we reserve the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with our Privacy Policy and related Data Protection regulations.

Once the User’s identity has been verified, we are able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

1.2. Payment methods and Card Verification

The users who use payment cards in connection with our service will have to pass a card verification, the users who use other payment methods via service providers is passing appropriate service provider’s verification and fulfill it’s requirements.

2. Compliance Officer

We have authorized a special person – The Compliance Officer who will ensure that the AML/CTF Policy is effectively implemented.

The Compliance Officer