1 AML PROCEDURES

1.1 • AML Detection

Withdrawals may be requested for amounts that have been wagered at least once. This protects BRASILWIN against abuse for money laundering purposes and also protects our system from free deposits that may be exploited to our disadvantage. All withdrawal requests are initially checked by monitoring all withdrawal requests and indicating those that are suspicious, based on any suspicion of fraudulent history. Each customer can only deposit a maximum of $1,200 per week. Players who wish to deposit more funds than the initial limit set will have to undergo a more comprehensive verification process, including voice confirmation, and will be periodically monitored for gaming activity. Additionally, these players will be highlighted/tagged in our software back office, facilitating their identification, tracking, and control.

In addition to system automatic controls, all customer transactions/accounts are checked for multiple accounts, individuals who may have been included on blacklists by any relevant organization or company, transaction and betting behavior, amounts moved, deposit/withdrawal methods, and other things that may lead to any suspicious activity based on the long-term experience of our related employees.

If no such issues are found, this finding will be forwarded to our accounting department for a final check and for the final payment to be made. This process is completed within one business day.

1.2 • AML Reporting

In any case where BRASILWIN identifies and verifies that any form of anti-money laundering is occurring or being attempted, this activity will be reported to the Curaçao Gaming Authorities as necessary.

2 KYC PROCEDURES

2.1 Player Registration

To open an account with BRASILWIN through the web portal, the user must first complete the registration process and deposit some funds, with which they can then start playing. The registration details that all new customers must provide include first and last name, address, country of residence, date of birth, email address, and account currency. All customers must be at least 18 years old and can only have one player account in their name, as specified in the Curaçao Remote Gaming Regulations. Therefore, no minors can play on the BRASILWIN site. Users without a registered player account will not be able to play.

2.2 • Due Diligence

Players from restricted countries/states cannot register due to strict non-gaming regulations in their country. These countries are also included in the Terms and Conditions so that players can be aware of these restrictions before registering. Before any withdrawal, the customer will be asked for the following documentation: bank account proof, credit card, utility bill (not more than 3 months old), and ID. This documentation must be verified before approving the withdrawal. Additionally, voice and phone number checks will be performed on high-volume customers and on customers with serious irregularities in their betting behavior. All documentation will be formally requested via email for both due diligence scenarios and will be archived according to company internal procedures.

After an accumulated withdrawal of €2,300 or more by any customer, proof of identity in the form of scanned documents such as ID scans or passport scans will be required to confirm their identity and, in specific cases, a recent bill to confirm their address.

Withdrawals of €2,300 or more will not be processed until these documents are submitted by the customer requesting the withdrawal and are verified and confirmed by the Fraud Management team.

Every time a new customer deposits money and starts playing or betting on the BRASILWIN site, our system will daily check and monitor their transactions and betting behavior. This procedure allows us to analyze how each individual customer uses the products on our sites, enabling the categorization of players and the establishment of individual limits based on their betting patterns.

2.3 • Email Verification

When a new account is created, a verification link is sent to the email address specified during the registration process. When the user clicks the link, the account is successfully created. Only at this point can the player deposit money and start placing bets.