Anti-Money Laundering Policy

zCasino Ltd ("zCasino", "the Company") is committed to the highest standards of Anti-Money Laundering (AML) compliance and combating the financing of terrorism (CFT). This policy sets out our procedures for detecting, preventing, and reporting money laundering and related criminal activity. We are licensed by Curaçao eGaming (License No. 8048/JAZ). We comply with applicable AML/CFT regulations and cooperate fully with competent authorities.

Money laundering is the process of making illegally obtained funds appear to have legitimate origins. It typically occurs in three stages: Placement: Introducing criminal proceeds into the financial system. Layering: Concealing the origin through a series of transactions. Integration: Reintroducing laundered funds into the legitimate economy. Online gambling platforms can be targeted for money laundering activities due to their financial flows. We take this risk seriously and maintain robust controls.

3.1 Standard CDD: All customers must verify their identity before making withdrawals or reaching transaction thresholds. Verification requires a government-issued photo ID and proof of address. 3.2 Enhanced Due Diligence (EDD): Applied to higher-risk customers, including politically exposed persons (PEPs), customers from high-risk jurisdictions, and those exhibiting unusual transaction patterns. EDD may require source of funds or source of wealth declarations. 3.3 Ongoing CDD: We continuously monitor customer activity and may request updated documentation at any time. 3.4 Politically Exposed Persons (PEPs): PEPs and their family members and close associates are subject to automatic EDD. Accounts may be subject to additional restrictions.

4.1 We employ automated systems to monitor transactions in real time for indicators including: • Deposits followed immediately by large withdrawals with minimal gameplay • Multiple accounts depositing to a single withdrawal destination • Unusual or inconsistent betting patterns • Deposits and withdrawals via different payment methods • Large cash equivalent transactions 4.2 Suspicious transactions are reviewed by our compliance team. Where suspicion cannot be resolved, we will file a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit.

5.1 Verification Thresholds: Identity verification is required prior to any withdrawal. For high-volume accounts, verification is required at lower thresholds. 5.2 Acceptable Documentation: • Identity: Passport, national ID card, or driving licence (must be valid and clearly legible) • Address Proof: Utility bill, bank statement, or official government document (dated within 3 months) • Source of Funds: Bank statements, payslips, or business accounts as applicable 5.3 All documents are verified using third-party identity verification services. Documents suspected to be fraudulent will be rejected and reported.

zCasino does not accept customers: • From countries designated as high-risk by the FATF (Financial Action Task Force) • Subject to international sanctions (EU, UN, OFAC) • Who are minors (under 18 years of age) • Who have provided false or misleading information • Who are on the Company's internal prohibited persons list Accounts found to be associated with prohibited persons will be suspended immediately and relevant balances frozen pending investigation.

We maintain records of all customer identification data and transaction history for a minimum of 5 years following account closure, in compliance with Curaçao eGaming requirements and international AML standards. Records are available for review by competent authorities upon lawful request.

All employees with customer-facing or financial responsibilities receive mandatory AML/CFT training upon onboarding and annually thereafter. Training covers recognition of suspicious activity, internal reporting procedures, and relevant legal obligations including tipping-off prohibitions.

9.1 Internal Reporting: Any employee who suspects money laundering must report to the Compliance Officer using the internal SAR form. The Compliance Officer reviews all reports within 48 hours. 9.2 External Reporting: Substantiated suspicions are reported to the Curaçao Financial Intelligence Unit (CIFA) as required by applicable law. We strictly prohibit "tipping off" — disclosing to a customer that an SAR has been filed.

Customers found to have engaged in money laundering or to have provided false identification will have their accounts permanently suspended and balances frozen. All relevant information will be reported to competent authorities. zCasino will cooperate fully with any law enforcement investigation.

This policy is reviewed annually by the Compliance Officer and updated whenever relevant law, regulations, or guidance changes. The Board approves the policy annually. The last review date is shown at the top of this document.