AML POLICY of TESSERA LIMITED S.R.L.

1. COMPANY BUSINESS MODEL

TESSERA LIMITED S.R.L. registration number: 3-102-913501, registered address: Costa Rica, Provincia 01 San Jose, Canton 15 Montes de Oca, San Pedro, Los Yoses Bets.io is Licensed by the Offshore Finance Authority of The State of Anjouan, under The Computer Gaming Licensing Act 007 of 2005, license number: ALSI-202410047-F12 (hereinafter - Company, We)

As part of its global operations, Company has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

2. MISSION STATEMENT

This document outlines the Company’s approach to Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Combating Proliferation Financing (CPF), ensuring compliance with applicable legal and regulatory requirements.

The Company is committed to preventing the misuse of its services for illicit financial activities and adheres to relevant national and international AML/CFT/CPF frameworks, including Financial Action Task Force (FATF) recommendations, EU Directives, and other applicable regulations.

To mitigate risks associated with financial crime, the Company:

• Implements appropriate measures to detect and prevent money laundering, terrorist financing, and proliferation financing.
• Conducts due diligence to ensure that it does not establish or maintain relationships with individuals or entities suspected of engaging in illicit activities.
• Reserves the right to terminate relationships where there are reasonable grounds to suspect involvement in illegal financial activities, in accordance with applicable regulations and in cooperation with relevant authorities.

3. DEFINITIONS OF MONEY LAUNDERING, TERRORIST FINANCING AND PROLIFERATION.

Financing Money Laundering is defined as:

1. The conversion or transfer of property, knowing that such property is derived from criminal activity or from participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;
2. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
3. The acquisition, possession or use of property, knowing, at the moment of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
4. The participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to points 1, 2 and 3;

There are often three acknowledged phases of money laundering:

• Placement – the physical disposal of cash or other assets derived from criminal activity.
• Layering – the separation of the illicit proceeds from their source by layers of transactions intended to hide the origin of the funds.
• Integration – supplying apparent legitimacy to illicit wealth through the re-entry of the funds into the economy in what appear to be personal transactions. However, even simple possession of criminal property may constitute an offence. Criminal property is defined as property which is, or represents, a person’s benefit from criminal conduct, where the alleged offender knows or suspects that it is such.

Terrorist Financing is defined as: The raising and processing of funds to supply terrorists with resources, the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 3 and 4 of Directive (EU) of the European Parliament and of the Council On Combating Terrorism. Terrorist financing entails soliciting, collecting, or providing funds with the intent of using them to support terrorist acts or organizations.

4. REGULATORY COMPLIANCE FRAMEWORK

We adhere to internationally recognized Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations, including the 2016 AML/CFT Regulations and other applicable global standards. Our operations strictly prohibit any illicit financial activities, including money laundering, terrorist financing, and sanctions violations.

To ensure ongoing compliance, our dedicated AML team continuously monitors regulatory updates from the Financial Action Task Force (FATF) and other relevant authorities. Our key compliance measures include:

• Implementation of AML/CFT Policies and Controls – Ensuring effective internal mechanisms to prevent and detect financial crime.
• Dedicated AML/KYC Oversight – A specialized team responsible for compliance monitoring and customer due diligence.
• Regular Training and Awareness Programs – Equipping employees with the knowledge and skills to identify and mitigate AML/CFT risks.
• Independent Compliance Reviews – Periodic assessments to evaluate the effectiveness of our AML framework and address any identified areas for improvement.

We remain committed to upholding the highest compliance standards and continuously enhancing our risk management framework in line with evolving regulatory requirements.

5. RISK BASED APPROACH

The risk-based approach recognizes that the AML/CFT/CPF risks faced by each sector and each subject person are different and allows for resources to be invested and applied where they are most required. The risk-based approach envisages the application of checks that are proportionate to the assessed risk. The cornerstone of the risk-based approach is the risk assessment which must be carried out at different stages of a subject person’s activities. This assessment allows the subject person to identify its AML/CFT/CPF vulnerabilities and the AML/CFT/CPF risks it is exposed to. On this basis, the subject person will be able to draw up, adopt and implement AML/CFT/CPF measures, policies, controls and procedures that address any identified risks.

6. KYC PROCEDURE

Know Your Customer Procedures are followed to achieve the following objectives:

• Allowing only legitimate customers to register an account (i.e. to exclude from registration the following categories: Minors, Sanctioned Persons or Players from Sanctioned countries are not allowed to register a gaming account).
• Build the risk profile associated with the customer.
• Confirming that customers are who they say they are.
• Monitoring customer accounts and transactions for illegal activities.
• Blocking duplicate accounts.
• Identifying possible PEP & Sanctioned customers.

7. REGISTRATION

Before accessing the Company's services, customers must complete the registration process, providing the following mandatory information:

• Email Address
• Full Name
• Date of Birth
• Residential Address

Upon submission, the We screen the provided information for accuracy and potential risk indicators, including:

• False or suspicious data.
• Duplicate or self-excluded accounts.
• Politically Exposed Persons (PEPs) and Sanctions List screening.

The Company also tracks the IP address of registrations. If a customer attempts to register from a restricted jurisdiction, the account will be blocked. If automated or manual checks detect a potential duplicate account, the account is suspended pending further investigation to determine intent.

8. AGE VERIFICATION

THE COMPANY STRICTLY prohibits underage gambling. Registration is restricted to individuals aged 18 and above. We reserve the right to request valid government-issued photo identification to verify age and identity at any time.

To prevent underage access, the Company implements identity verification services and other measures to ensure compliance with age restrictions.

9. RISK-BASED DUE DILIGENCE

Customer due diligence (CDD) is conducted on a risk-sensitive basis, with enhanced scrutiny applied to accounts exhibiting higher AML/CFT risks. We use a risk-scoring matrix based on predefined risk criteria to assess and manage potential threats effectively.

10. STANDARD DUE DILIGENCE (SDD)

Standard due diligence measures are applied to all customers, ensuring compliance with regulatory requirements and mitigating AML/CFT risks.

11. TRANSACTIONS MONITORING

The Company is committed to adhering to economic and trade sanctions and has implemented a transaction monitoring program that combines automated and manual processes to detect and address unusual activities. We analyze user history and activity patterns in real-time and through ongoing monitoring to identify potential risks and enforce necessary controls.

12. ONGOING MONITORING OF TRANSACTIONS

In addition to transaction reviews, the Company employs various monitoring procedures, including ban evasion detection, time zone analysis, and product usage reviews to prevent misuse of our platform and ensure compliance with regulatory obligations. We also conduct periodic evaluations of our third-party service providers to verify their adherence to compliance requirements.

These measures help the Company uphold high regulatory standards and prevent illicit activities, reinforcing our commitment to operating with integrity and responsibility in the gaming industry.

13. VENDOR MANAGEMENT

The Company collaborates with reputable third-party service providers to support its compliance framework. We conduct regular assessments to ensure these providers meet operational and regulatory standards. If a provider fails to meet expectations or if additional services are required, the Company may implement remedial actions or seek alternative solutions to maintain compliance.

14. COMPLIANCE INNOVATION

As part of our commitment to continuous improvement, the Company actively explores and tests non-documentary compliance mechanisms to enhance its regulatory framework. This includes evaluating blockchain-native compliance tools, such as fraud prevention services and on-chain KYC providers, leveraging blockchain technology for enhanced security and compliance. Pilot programs with compliance vendors may be conducted to assess the effectiveness of these tools.

15. INTERNAL TRAINING

The Company provides regular compliance training to its employees, covering Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and trade sanctions compliance. Training sessions are conducted periodically and tailored to specific roles within the organization, incorporating the latest regulatory developments and industry best practices.

16. SUSPICIOUS TRANSACTION REPORTING (STR)

The Company adheres to applicable regulatory requirements concerning the reporting of unusual or suspicious transactions. If a customer is identified as being linked to money laundering, terrorist financing, or other criminal activities, such activity will be reported to the relevant authorities as required by law.

By maintaining a robust transaction monitoring framework, the Company ensures a safe, transparent, and legally compliant gaming environment.