Anti-Money Laundering (AML) Policy

This Anti-Money Laundering Policy outlines the standards and procedures that Optim Development B.V. upholds to combat money laundering and terrorism financing (collectively referred to as “Policy”). Registered in Curaçao with registration number 154511 and headquartered at Fransche Bloemweg 4, Curaçao, Optim Development B.V. (hereafter “Company”) complies with international anti-money laundering and counter-terrorism financing (AML/CFT) standards.
The Company adheres to global and regional standards, including the Financial Action Task Force (FATF) recommendations, European AML/CFT laws, and Curaçao regulations, such as the European Parliament’s Directive 2015/849 on AML, Regulation 2015/847 on fund transfer information, and the updated AML Directive (EU) 2018/843. Optim Development B.V. is committed to ensuring that all forms of illegal gambling are prevented.
This Policy is mandatory, distributed to all required personnel, and must be applied consistently by all responsible employees. It is the Company’s Policy to strictly prohibit and actively prevent money laundering and activities related to terrorism or criminal funding across all services. We operate in full compliance with applicable AML laws, ensuring we only work with clients who conduct legitimate business activities and whose funds are lawfully sourced.
Our commitment extends to enforcing internal regulations and global measures to deter money laundering and terrorist financing.

Money laundering typically occurs in three stages, each representing a unique phase in disguising illicit funds:

• Placement: The initial stage, where illegally acquired proceeds are introduced into the financial system;
• Layering: At this stage, funds are separated from their origin through complex transactions designed to obscure their source, creating an audit trail that masks their origin;
• Integration: The final stage, where laundered funds are reintroduced into the economy in ways that make them appear legitimate.

Money laundering refers to engaging in transactions intended to hide the criminal origins of funds to make them appear legally obtained. Activities considered money laundering and prohibited under this Policy include:

• Transferring or using funds suspected to be derived from criminal activity with the intent to disguise their origin or assist others in evading legal consequences.;
• Conducting transactions using illicit funds;
• Concealing the true source, location, or movement of funds associated with illegal activities;
• Acquiring, possessing, or using assets obtained unlawfully;
• Assisting others in illegal activities;
• Participating, attempting, or aiding in any of the activities mentioned above.

In a broader sense, anyone, including Company employees, can be held accountable if they are aware of illegal activities related to their business and fail to report suspicions or concerns.

This Policy informs employees, contractors, partners, players, and any third parties representing the Company of critical AML requirements. This Policy is mandatory and applies universally to the Company’s operations, covering all entities owned or controlled by the Company worldwide, including all directors, officers, employees, contractors, partners, and representatives.

Our compliance structure is designed to prevent money laundering and terrorist financing through measures including:

• Developing strict internal controls to detect and prevent misuse of Company products;
• Conducting identity verification, screening, and enhanced due diligence when required;
• Maintaining proper records, complying with data processing regulations (such as GDPR), and addressing customer or partner requests;
• Reviewing and updating internal procedures regularly.

By registering an account, users agree to the following:

• They commit to comply with all applicable AML and anti-terrorism laws, including the AML Policy;
• They confirm that funds used for gaming activities are not derived from illegal sources and are unconnected to money laundering or prohibited activities;
• They consent to provide any necessary information to support compliance with AML laws.

The Company collects and retains documents verifying user identities, maintains transaction records for at least five years, monitors suspicious transactions, and reserves the right to deny transactions suspected of involvement in illicit activities. The Company is not obligated to notify users of suspicious activity reports filed with authorities.

Under the AML Policy, the Company conducts identity checks for all users based on risk levels (low, medium, high).

To prevent fraud, the Company may verify user credentials such as name, address, age, and payment methods at any time, requiring supporting documentation for authentication.

Required documentation includes:

• Photo ID: A copy of a government-issued ID, such as a passport or driver’s license, to process withdrawal requests;
• Credit/Debit Cards: Copies of both sides of the credit/debit card used for deposits, with security details covered for protection;
• Proof of Address: A recent utility bill or credit card statement showing the name and address provided at registration;
• Notarized Documents: Legal documents must be certified by a notary or legal counsel to validate their authenticity.

All documents must be no older than six months and adhere to security standards to prevent unauthorized access to sensitive data.

Attention! In certain cases, depending on the payment method used for your deposit, additional documents beyond those typically requested may be required for verification.

Players are expected to submit the requested information within 48 hours of receiving our notice. The documents can be uploaded directly through your personal account portal. Please note that successful verification results may not always be communicated back to you.

If a player fails to respond or declines to provide the requested documents, the Company reserves the right to suspend or close the account and withhold any remaining funds.

Should submitted documents fail our security checks—for instance, if we suspect that they are fraudulent, contain misleading information, or have been altered—we will consider them invalid and will notify the player of our decision.

The Company is committed to confirming the identity of every individual who registers to use our services (referred to as Users/Players). As part of our registration process, and in accordance with our Terms and Conditions, we conduct both Standard Due Diligence and Enhanced Due Diligence checks before a player account is activated.

The Company collects essential identification details from each User/Player, which include:

• Date of birth, ensuring the player meets the minimum age requirement of eighteen (18) years;
• Full name of the User/Player;
• Residential address of the User/Player;
• Valid email address;
• Username and password for account security.

In some instances, additional information or documentation may be required, and, where applicable, notarized copies of certain documents may also be requested.

Documents verifying identity information will be requested when there is a perceived risk or ambiguity regarding the provided information. Verification documents are mandatory prior to any transactions exceeding EUR 1,000, or if cumulative account transactions surpass this amount. Required documentation may include a valid photo ID or passport and proof of address, adhering to data protection regulations.

Within two business days of identifying suspicious activities or gaining relevant knowledge, the Company will report to the appropriate authorities, including the details and basis of the suspicion.

• Appointment of a Money Laundering Reporting Officer (MLRO): The Company designates an MLRO to whom employees report any evidence or suspicion of money laundering or terrorist financing, in compliance with the 2007 and 2018 Prevention and Suppression of Money Laundering Activities and Terrorist Financing laws;
• Risk-sensitive Policies: The Company enforces procedures that address customer due diligence, reporting obligations, record keeping, internal control, risk management, and compliance monitoring, with regular updates on AML policies for staff;
• Vigilance Among Employees: All employees are trained to recognize signs of potential money laundering. If an employee suspects such activity, they are required to promptly report it to the Compliance Officer (MLRO);
• Transaction Monitoring: According to Regulation 2015/847, the Company is responsible for verifying the accuracy of payer or payee information for fund transfers exceeding EUR 1,000, or when multiple transfers collectively exceed this amount. This monitoring excludes any additional transaction fees but applies when there is reason to suspect illicit activities.

The Company has appointed a dedicated AML Compliance Officer, who holds full responsibility for overseeing the Company’s Anti-Money Laundering (AML) program. In line with Directive (EU) 2015/849 and other relevant AML directives, the Company is required to register its MLRO and Compliance Officer within the AML registration system.
The Compliance Officer’s responsibilities include monitoring compliance with AML regulations, facilitating communication, and providing training for employees in accordance with Directive (EU) 2015/849. The Compliance Officer is also responsible for ensuring that the Company maintains accurate AML records and has full authority to enforce the Company’s AML program.

The Company is dedicated to providing continuous AML training for all employees, under the guidance of the MLRO and senior management, with mandatory sessions held at least once annually. The training program may be updated in response to changes in the Company’s client base, available resources, or legislative amendments.

Key training topics include:

• Identifying high-risk clients and recognizing signs of money laundering in daily duties;
• Step-by-step actions following risk identification, including reporting suspicious activity to the Compliance Department;
• The Company’s document storage policy for User/Player information;
• Disciplinary measures for non-compliance with AML laws.

In compliance with Chapter II, Article 5 of Regulation (EU) 2015/847, the Money Laundering Reporting Officer (MLRO) will report any suspicious transactions involving EUR 1,000 or more, whether conducted or attempted through a User/Player account. The MLRO is required to report when there is knowledge, suspicion, or reason to believe that:

• The User/Player appears on a terrorism-related or sanctioned list;
• The transaction involves illegal funds or attempts to disguise the origin of illicit funds;
• The transaction is unusual and lacks a lawful explanation based on its background and purpose;
• The Company’s services may be used to support criminal activity.

Company management is fully committed to adhering to all relevant AML laws. Any employee or User/Player who breaches this Policy or allows others to do so may face disciplinary action, which may include termination and personal civil or criminal penalties.
The Company is responsible for cultivating a compliance-focused environment with robust controls to prevent, identify, and address money laundering and terrorist financing activities. Compliance with European AML laws and regulations is a top priority, and all employees are made aware of the consequences of non-compliance.
All employees, contractors, and partners are required to read and comply with this Policy. Violations may lead to disciplinary actions and other potential legal consequences based on individual behavior.
This Policy will be updated as required by law, with the latest version made available on the Company’s intranet.

This Policy is governed by the laws of Curacao. Each clause in this Policy is independent; if any clause is deemed invalid or unenforceable, the remaining clauses will remain effective.