ANTI-MONEY LAUNDERING POLICY

Obligations Under the Prevention of Money Laundering Act

1. General Measures
Aurora Holdings N.V. shall, at a minimum:

• Appoint a Money Laundering Reporting Officer (MLRO): A senior officer responsible for compliance with the regulations and guidance notes under the law.

• Conduct Due Diligence: Verify user identity during registration in accordance with the General Terms and Conditions, ensuring users are of permitted age.

• Accepted forms of photo identification:

• National Identity Card

• Valid Photo Card Driving License

• Valid Passport

• Recent Utility Bills or Bank Statements (issued within the last 3 months)

• Maintain Records:

• Securely store a digital list of all registered users.

• Retain transactional and identification documentation as per legal regulations.

• Training and Awareness:

• Provide initial and ongoing training to staff on procedures and their responsibilities in identifying users, monitoring activities, record-keeping, and reporting suspicious or unusual transactions.

• Policy Updates: Ensure that the policy evolves in line with statutory and regulatory changes and advice from relevant authorities.

• Transaction Monitoring:

• Investigate the background and purpose of large or complex transactions or those potentially linked to money laundering or terrorism financing.

• Suspicious Activity Reporting: Report any suspicion or knowledge of money laundering or terrorism financing to the LGA or relevant government agency.

• Cooperate with Authorities: Collaborate with administrative, enforcement, and judicial authorities to detect and prevent criminal activity.

2. Additional Measures
Aurora Holdings N.V. shall also:

• User Account Registration:

• Register users only if the true beneficial owner of the account is identified.

• Restrict registration to individuals aged 21 and above.

• Prohibit multi-account practices.

• Acceptable Payment Methods:

• Refuse cash transactions. Accept funds only through electronic transfer, wire transfer, cheques, debit cards, credit cards, or other approved methods.

• Fund Transfers: Return winnings or refunds to the original payment method where possible.

• Wagering Rules:

• Reject wagers unless sufficient funds are available in the user account.

• Require funds to be provided through appryuoved channels.

• Jurisdiction Restrictions: Reject users residing or playing from non-reputable jurisdictions.

• Verification and Creditworthiness:

• Verify identity, age, and residence before processing payments.

• Assess users’ creditworthiness with third-party providers when necessary.

• Fraudulent Registration: Immediately cancel registrations and prohibit future accounts for users providing false information during the due diligence process.