Anti-Money Laundering Policy

1. Company Business Model

XYes Online Casino (hereinafter referred to as "the Casino") is a company established under relevant laws and focuses on providing online gambling services. We are committed to ensuring that our operations are not used for money laundering or terrorist financing activities and comply with global anti-money laundering (AML) and counter-terrorism financing (CFT) regulations.

2. Company Policy Statement

Although we are not a financial institution, in the operation of the Casino, we expressly prohibit the use of XYes products for any form of illegal activities, including money laundering, terrorist financing or violation of trade sanctions. We will comply with international anti-money laundering regulations and local regulatory requirements and take necessary measures to maintain the security and legality of the platform.

Our intention is to follow global best practices to prevent our services from being used to facilitate these illegal activities. Our best practices include:

• Developing written policies and reasonable procedures and controls to prevent money laundering and terrorist financing.

• Appointing a compliance officer to oversee the implementation of the policy.

• Providing relevant education and training to relevant personnel.

• Independently reviewing, monitoring and maintaining policies, procedures and controls.

3. Definitions

• Money laundering: The process of converting illegal proceeds into legal funds, which is generally divided into three steps: placement, layering and integration.

• Suspicious activity: Activity by users or non-users on our platform that shows signs of possible fraud or illegal purposes.

• Sanctions: Measures imposed by the international community on specific countries or individuals to prohibit or restrict activities.

4. Governance and Oversight

We have designated a Chief Compliance Officer (“CCO”) to coordinate the implementation of the Casino’s anti-money laundering policy and compliance procedures. The Compliance Officer’s responsibilities also include developing the anti-money laundering program, working with other stakeholders to revise the policy, evaluating new regulatory requirements, and investigating potential suspicious or unusual activities.

5. Know Your Customer (KYC) and Transaction Monitoring

The Casino will follow appropriate customer due diligence (CDD) and continuous monitoring measures to prevent users from engaging in illegal or unauthorized activities.

Customer Due Diligence:

• Collect basic information required at account opening to establish a customer risk profile.

• Verify user identity and maintain records.

• Assess the nature and purpose of the user’s relationship with our platform.

We will adopt various measures to ensure the accuracy and completeness of the information collected, including third-party identity verification services.

Continuous Monitoring:

• We will monitor user transaction activities to identify any suspicious behavior or indicators

• User accounts that trigger red flags will be reviewed quickly and appropriate actions will be taken.

6. Acceptance Policy

The casino will not accept the following users and will block their registration:

• Users who do not provide the requested identity information.

• Users who provide false identity documents.

• Users from restricted or prohibited jurisdictions.

7. Transaction Monitoring

We will strive to comply with economic and trade sanctions and establish transaction monitoring procedures to identify and detect any unusual activities in real time. We will conduct regular reviews using rules-based systems developed internally and by third parties.

8. Education and Training

We will provide regular anti-money laundering, counter-terrorist financing and trade sanctions compliance training to our employees to ensure that all employees are aware of the relevant policies and procedures.

9. Reporting

XYes Online Casino is obliged to report any suspicious or unusual transactions in accordance with relevant laws and regulations. Customers associated with money laundering, terrorist financing or other criminal activities will be flagged as suspicious activities and reported to regulatory authorities.