Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy

1. Purpose & Scope

This Policy sets out the standards, controls and procedures adopted by Betida Entertainment Ltd to prevent its products and services from being used for money laundering (ML), terrorist financing (TF) or sanctions evasion.

It applies to all directors, officers, employees, contractors, and relevant third parties.

2. Governance & Responsibilities

The Board/Senior Management is ultimately responsible for AML/CTF compliance.
A suitably qualified Compliance Officer (also acting as MLRO) will be appointed with sufficient authority, independence and resources to:

• Implement this Policy
• Conduct investigations
• File reports
• Liaise with the regulator and law enforcement as required

Key responsibilities include:

• Maintaining the AML/CTF framework, procedures and risk assessment
• Approving high-risk relationships and EDD outcomes
• Overseeing training, quality assurance and independent reviews
• Reporting material issues to Senior Management/Board

3. Risk-Based Approach

Betida applies a documented, risk-based approach covering:

• Products
• Delivery channels
• Geographies
• Customer types
• Payment rails
• Technology

Controls are proportionate to identified risks and reviewed at least annually or upon material change.

4. Customer Due Diligence (KYC)

Before enabling deposits or real-money play, Betida performs identification and verification using reliable, independent sources (including third-party providers where appropriate).

Information collected is appropriate to risk and may include:

• Full name
• Date of birth
• Nationality
• Residential address
• Contact details
• Device/IP data
• Wallet addresses (where applicable)

KYC requirements include:

• Sanctions/PEP/adverse media screening at onboarding and periodically thereafter
• Geo-blocking to restrict access from prohibited or restricted jurisdictions
• Record-keeping of KYC evidence for the statutory retention period

5. Enhanced Due Diligence (EDD)

EDD applies to higher-risk customers, complex structures, or when red flags are identified.
Measures may include:

• Additional identity documents and liveness checks
• Verification of source of funds (SoF) and source of wealth (SoW)
• Clarification of purpose and nature of the relationship
• Senior management approval

6. Acceptance & Prohibited Users

Betida will not onboard or will terminate users who:

• Refuse to provide information
• Submit forged/altered documents
• Attempt to obfuscate location (e.g., VPN/geo-evasion)
• Originate from prohibited jurisdictions
• Appear on sanctions/watchlists
• Present unacceptable AML/CTF risk

7. Sanctions & Jurisdiction Controls

Betida complies with applicable sanctions regimes.
Access from prohibited or restricted jurisdictions is blocked via IP-based and other geo-controls.
Transactions involving sanctioned persons, entities, or jurisdictions are prohibited.

8. Transaction Monitoring

Betida operates ongoing, risk-sensitive monitoring to identify unusual or suspicious activity using internal rules and reputable third-party tools (including blockchain analytics where applicable).

Controls include:

• Screening deposits/withdrawals and wallet addresses
• Pattern analysis (size, frequency, velocity)
• Anti-mixing safeguards and rejection of anonymity-enhancing techniques
• Alert investigation and withdrawal controls (e.g., KYC refresh over thresholds)

9. Suspicious Activity Management & Reporting

Alerts are triaged and investigated.
Where required by applicable law and licence conditions, suspicious activity reports (SARs) will be filed with the competent authority/regulator in Anjouan.
Betida will cooperate with lawful requests from authorities.

10. Record-Keeping & Data Protection

KYC, transactional and monitoring records are retained for the legally required period and protected with appropriate technical and organisational measures, in line with data protection laws.

11. Training & Awareness

Relevant personnel receive AML/CTF and sanctions training:

• At onboarding
• Periodically thereafter

Attendance is recorded, and refresher training is provided upon material legal or risk changes.

12. Vendor Management

KYC/screening and monitoring vendors are subject to:

• Due diligence
• Contractual controls
• Periodic performance reviews

13. Audit & Review

This Policy and its underlying controls are reviewed:

• At least annually, or
• Upon material changes in products, risks or law

Independent reviews assess effectiveness and recommend enhancements.