KYC POLICY

In order to open an account to use the Website services, you should provide your e-mail address, choose a password, and fill in the information required to complete the registration by providing us with personal information, including your name, date of birth, and phone number.

50crowns.com is owned and operated by TESSERA LIMITED S.R.L., a company registered and established under the laws of Costa Rica and regulated by the Government of Costa Rica with a registration number is 3-102-913501 and its registered address at San Jose, Mata Redonda, South Sabana, Las Vegas Neighborhood, Blue Building Diagonal To La Salle Highschool Costa Rica. TESSERA LIMITED S.R.L. is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros and operates under License No. ALSI-202410047-F12.

We follow the rules of KYC procedures (“Know Your Customer”). Your name on your Account shall match your true and legal name and identity. To verify your identity, the Company reserves the right to request at any time satisfactory proof of identity (including but not limited to copies of a valid passport/identity card and/or any payment cards used). If you fail to supply the information and documents requested, we shall be entitled to suspend the activity of your account until the provision of the information requested and/or close your account. The Company reserves the right to review the documents within 30 (thirty) calendar days.

You hereby certify and agree that you have provided accurate, complete, and true information about yourself upon registration and you shall maintain the accuracy of that information by promptly updating it if there are any changes. Failure to do so may result in account closure, account limitations, or voiding transactions (bonus, winnings).

You shall only open a single account at the Website. In all cases, only one account per customer, per address, per shared computer, and per shared IP address shall be allowed. Any other account you open on the Website shall be considered as a duplicate account. You shall inform the Company that you wish to create a duplicate account due to the original account access loss or any other important reason and receive permission from the Company before the creation of the duplicate account.

In any other cases, all duplicate accounts may be immediately closed by the Company and:

• All transactions made from the duplicate account shall be considered null and void;
• Any returns, winnings, or bonuses which you have gained or accrued within the use of the duplicate account shall be forfeited and a return may be claimed by us.
• Any funds withdrawn from the duplicate account shall be returned to us on demand;

The Company shall not compensate any funds from both bonus and real money balances of the duplicate account. The Company reserves the right, at its sole discretion, to claim the return of any lost funds that were used for bets effected via the duplicate account;

The Company shall not accept any requests on fund returns which have been lost or initially deposited on the duplicate account provided that the duplicate account was created with intention to receive bonuses and other promo offers from the Company, as well as if a number of duplicate accounts was created with a purpose of receiving a return of the first deposits made on previously created duplicate accounts, which is considered to be an abuse. If the Company at its sole discretion assumes that the duplicate accounts were created only with a purpose of fraud and/or abuse of these Terms, then the funds deposited on this duplicate account shall not be returned to the player.

When a user makes an aggregate lifetime total of deposits exceeding Euro 2000 (or its equivalent in other currency) or requests a withdrawal of any amount inside the 50crowns.com platform, it is compulsory for them to perform a full KYC process.

During this process, the user will have to input some basic details about themselves and then upload:

• A copy of Government Issued Photo ID (in some cases front and back depending on the document)
• A selfie of themselves holding the ID document
• A bank statement or utility bill

Once uploaded, the user will get a “Temporarily Approved” Status and the documents will be reviewed by the “KYC Team” within 24 hours, who will email the user about the outcome:

• Approval
• Rejection
• More information needed – No change in Status
• When the user is on “Temporarily Approved” Status:
• They can use the platform normally
• They cannot deposit more than Euro 500 in aggregate total
• They cannot complete any withdrawal
• Guideline for the KYC Process

1. Proof of ID

• a. Signature is there
• b. Country is not a Restricted Country: Austria, France and its territories, Germany, Greece, Netherlands and its territories, Spain, Union of Comoros, United Kingdom, USA and its territories, all FATF Blacklisted countries, any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.
• c. Full Name matches the user’s name
• d. Document does not expire in the next 3 months
• e. Owner is over 18 years of age

2. Proof of Residence

• a. Bank Statement or Utility Bill
• b. Country is not a Restricted Country: Austria, France and its territories, Germany, Greece, Netherlands and its territories, Spain, Union of Comoros, United Kingdom, USA and its territories, all FATF Blacklisted countries, any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.
• c. Full Name matches the user’s name and is the same as in proof of ID
• d. Date of Issue: In the last 3 months

3. Selfie with ID

• a. Holder is the same as in the ID document above
• b. The ID document is the same as in “1”. Make sure photo/ID number is the same notes on the KYC Process

1) When the KYC process is unsuccessful, the reason is documented and a support ticket is created in the system. The ticket number along with an explanation is communicated back to the user.
2) Once all proper documents are in our possession, the account gets approved.
Other AML Measures
1. If a user has not passed full KYC then they cannot make additional deposits or withdrawals of any amount.
2. If a user has passed the KYC process successfully then:

• a. There is a deposit limit per transaction as per Terms and Conditions
• b. Prior to any withdrawal there is a detailed algorithmic and manual check on the activity and balance of the user to see if the amount withdrawn is a result of proper activity in the platform.

3. Under no circumstances may a user transfer funds directly to another user.
Personnel Training
The Company appoints AML Compliance Officers Mr. Boriss Pančenko and Anna Viktor Glam, who are fully responsible for the Company’s compliance with CFT and AML policies, establishing and maintaining the Company’s AML program, AML training employees, receiving, investigating and maintaining internal suspicious activity reports.
All the employees, managers and directors of the Company are suitably trained while entering into employment.

Employees who are dealing with clients or are involved in any AML checking, verification or monitoring undergo AML training. Each new employee has to follow an AML training plan. The AML training program includes suspicious transactions identification training as well as training in prevention, detection and reporting of money laundering and terrorism financing crimes. Any violation of the AML policy must be reported to the AML Compliance Officer, unless the violation implicates the AML Compliance Officer, in which case an employee must report the violation to the CEO.

Where the Company relies on third-party service providers for customer due diligence, screening, or verification services, the Company will ensure that:
A written agreement or Service Level Agreement (SLA) is in place defining responsibilities, performance standards, and reporting obligations.
The third party is regulated and/or reputable, and subject to independent audits.
Ultimate responsibility for compliance with AML/KYC obligations remains with the Company, and not the third party.
Beneficial Ownership and Corporate KYC for the Corporate Entities Partners.
For legal entity partners, the Company will identify and verify the Ultimate Beneficial Owners (UBOs) who directly or indirectly own or control 25% or more of the entity, or otherwise exercise control.
Documentation may include corporate registries, shareholder registers, and certified ownership declarations.
The Company will ensure that the corporate structure is transparent, and that UBO information is kept updated throughout the relationship.

Risk Assessment
A money laundering and terrorist financing risk assessment attempts to identify, analyse and understand money laundering and terrorist financing risks. It serves as the first step in addressing the risks and, ideally, involves making judgments about threats, vulnerabilities and consequences.

The Company shall identify the threats (persons, or groups of people, objects or activities with the potential to cause harm, including criminals, terrorist groups and their facilitators, their funds, as well as past, present and future money laundering or terrorist financing activities), vulnerabilities (things that can be exploited by the threat or that may support or facilitate its activities and means focusing on the factors that represent weaknesses in AML or CTF systems or controls or certain features of a country, particular sector, financial product or type of service that make them attractive for money laundering and terrorist financing), consequences (this refers to the impact or harm that money laundering or terrorist financing may cause, including the effect of the underlying criminal and terrorist activity on financial systems and institutions, the economy and society more generally). The Company adopts an approach that attempts to distinguish the extent of different risks to assist with prioritizing mitigation efforts, rather than being a generic box-ticking exercise.

That is why the Company performs the:

Identification: The identification process begins by developing an initial list of potential risks or risk factors when combating money laundering and terrorist financing. Risk factors are the specific threats or vulnerabilities that are the causes, sources or drivers of money laundering and terrorist financing risks. Analysis: Analysis involves consideration of the nature, sources, likelihood, impact and consequences of the identified risks or risk factors. The aim of this stage is to gain a comprehensive understanding of each of the risks, as a combination of threat, vulnerability and consequence, in order to assign a relative value or importance to each of them. Risk analysis can be undertaken with varying degrees of detail, depending on the type of risk, the purpose of the risk assessment, and the information, data and resources available.

Evaluation: The evaluation stage involves assessing the risks analyzed during the previous stage to determine priorities for addressing them, taking into account the purpose established at the beginning of the assessment process. These priorities can then contribute to development of a strategy for the mitigation of the risks.
The Company pays special attention to country and geographic risk (some countries pose an inherently higher money laundering and terrorist financing risk than others. In addition to considering their own experiences, there should be taken into account a variety of other credible sources of information identifying countries with risk factors in order to determine that a country and customers from that country pose a higher risk. Customers that are associated with higher risk countries, as a result of their citizenship, country of business or country of residence may present a higher money laundering and terrorist financing risk, taking into account all other relevant factors. We check customer location because of the additional risks which arise from cross-border operations. The country or geographic risk can also be considered in conjunction with the customer risk).

We also assess customer risk (determining the potential money laundering and terrorist financing risks posed by a customer, or category of customers, is critical to the development and implementation of an overall risk-based framework. We seek to determine whether a particular customer poses a higher risk and the potential impact of any mitigating factors on that assessment. Application of risk variables may mitigate or exacerbate the risk assessment). Categories of customers whose activities may indicate a higher risk include:

Customers who are PEPs, family members of PEPs or known close associates of PEPs.
High spenders – the level of spending which will be considered to be high for an individual customer will vary among casino operators, and among casinos managed by the same operator.
Disproportionate spenders – information is obtained about customers’ financial resources to determine whether spending is proportionate to income or wealth.
Casual customers – includes tourists, participants in junkets and local customers who are infrequent visitors.

Regular customers with changing or unusual spending patterns.
Improper use of third parties – criminals may use third parties or agents to avoid CDD undertaken at the threshold or to buy chips, or to break up large amounts of cash.

Junkets – may pose higher risks including criminal control of the junket operator or participants, cross-border movement of funds, and obscured identities
Structuring, refining and currency exchange risks
Transaction risk and product risk are also considered. Many customers carry a lower money laundering or terrorist financing risk, such as those regularly employed or with known sources of income. Conversely, many customers carry a higher risk of money laundering, including known criminals, customers without regular income sources, or problem gamblers.

EDD Procedure
The Company follows the following EDD rules’ recommendations:

• The Company scrutinizes customers’ risk profile;
• The Company obtains additional information where necessary;
• The Company conducts extensive background checks and monitors transactions;
• The Company organizes and secures its data in line with compliance standards;
• The Company keeps the data available for regulators.

The Company obtains additional identifying information from a wider variety or more robust sources and uses the information to inform the individual customer risk assessment:

Carrying out additional searches (for example, verifiable adverse media searches) to inform the individual customer risk assessment;
Commissioning an intelligence report on the customer or beneficial owner to understand better the risk that the customer or beneficial owner may be involved in criminal activity;
Verifying the source of funds or wealth involved in the business relationship to be satisfied that they do not constitute the proceeds from crime;
Seeking additional information from the customer about the purpose and intended nature of the business relationship.

Sanctions Screening
The Company has implemented due diligence and sanctions screening procedures. The Company shall screen and identify persons and transactions subject to and/or prohibited by the following:
US OFAC SDN List;
UK HMT Consolidated List of Persons and Ukraine List of Persons;
UN restrictive measures;
EU Consolidated List.

The Company utilizes Thomas Reuters World-Check (World-Check) and Refinitiv to conduct sanctions screening, which allows the Company to screen all relevant sanctions lists using a single search function. The following internal documents should be cross-referenced to effectively carry out sanctions screening:

• 1) Screening Request Form;
• 2) Partnership Appraisal Form;
• 3) Screening Procedures Matrix;
• 4) Due Diligence and Partnership Appraisal Map;
• 5) Thomson Reuters World-Check User Guide.

Due Diligence and Partnership Appraisal Screening Process
The first phase of sanctions screening requires fact gathering due diligence and partnership appraisal process. This requires completion of Screening Request Form and/or Partnership Appraisal Form (depending on the type of transaction). Staff should cross-reference the Screening Procedures Matrix to determine which form(s) require completion. In accordance with the Due Diligence and Partnership Appraisal Map, Programmes/POC carries out the fact gathering process in conjunction with new and potential partners. These forms are intended to capture information necessary to conduct effective screening utilizing World-Check. Essential information to be captured includes names and aliases, addresses, date of birth (individuals), and ownership structure and identification (trustees, directors, decision-makers, and shareholders). Pertinent data fields are noted in the Screening Request Form and Partnership Appraisal Form, respectively. Once the fact gathering process is complete, the information is forwarded to internal audit staff (Finance). Internal audit staff screens persons and organisations utilizing World-Check.

Risk Rating
The next phase of sanctions screening requires the Company to assign a risk rating. A risk rating is assigned by internal audit staff and is documented on the Screening Request Form and/or Partnership Appraisal Form. A risk rating will be assigned to any person or organisation subject to sanctions screening procedures:

• High-risk: Persons and entities subject to sanctions in the US, UK, UN or EU. High-risk is defined as a transaction that poses or allows for a significant reputational risk to the organisation. The Company will not engage with any person, entity or financial institution deemed high-risk.
• Medium-risk: Persons and entities identified as Politically Exposed Persons (PEPs). Medium-risk is defined as a transaction that poses a greater than average reputational risk. Medium-risk parties are subject to rescreening annually and require dispensation from the Director.
• Low-risk: Transactions that pose average reputational risk, including persons or entities with exposure to PEPs. Low-risk parties are rescreened every two years.
• No-risk: Transactions that do not pose any reputational risk. No-risk parties are rescreened every five years.

Decision Making and Escalation
The final phase of sanctions screening requires the Company to decide whether to move forward with an engagement, contract, or transaction. All transactions where a sanctions risk is deemed present (low, medium or high) are forwarded to the Director for review and potential investigation. The Director and compliance specialist review the transaction before approval. Decisions and supporting documentation are retained in the person or organisation’s file. The Company reviews the sanctions lists daily and informs regulators on any suspected criminal activities or transactions with sanctioned persons/organizations.
Reporting of Suspicious and Unusual Transactions (SAR / UTR)
The Company maintains procedures for identification, escalation, and reporting of any suspicious transactions or activities.

Internal reporting procedure:

• Staff must complete an Internal Suspicious Activity Report (ISAR) for unusual activity and forward it to the MLRO without delay.
• The ISAR must contain relevant facts, observations, and supporting documentation.
• The MLRO acknowledges receipt, conducts a preliminary review, and determines whether further investigation or external reporting is needed.
• All ISARs are recorded in the Internal Suspicious Activity Register and retained for at least five (5) years.

External reporting to competent authorities:
If the MLRO determines suspicion is justified, a Suspicious Activity Report (SAR) or Unusual Transaction Report (UTR) is filed with the appropriate Government authority.
Where required, the Anjouan Gaming Board may also be notified.
Reports include customer, transaction, and reasons for suspicion. Copies are securely retained.

Prohibition of “tipping off”: Employees must not inform the customer or any unauthorized third party about a SAR/UTR or ongoing investigation.
Record keeping and audit: MLRO ensures all reports and analyses are retained for a minimum of five (5). Periodic reviews are conducted to ensure compliance.

Scope and Applicability
This policy applies to brand 50crowns.com, operated by TESSERA LIMITED S.R.L., a company registered and established under the laws of Costa Rica and regulated by the Government of Costa Rica with a registration number is 3-102-913501 and its registered address at San Jose, Mata Redonda, South Sabana, Las Vegas Neighborhood, Blue Building Diagonal To La Salle Highschool Costa Rica. TESSERA LIMITED S.R.L. is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros and operates under License No. ALSI-202410047-F12.

Governance and Policy Review
This Policy is reviewed at least annually, or sooner if triggered by:
Significant changes in business operations or risk exposure;
Regulatory feedback or audit findings.