Anti-Money Laundering Policy

At 3XC Gaming Limited, we are committed to preventing the use of our platform for money laundering, terrorist financing, and any other illicit financial activity. This Anti-Money Laundering (AML) Policy outlines the procedures and internal controls we have put in place to detect, deter, and report suspicious activity in compliance with applicable laws and best practices.

1. Policy Objective

This policy is designed to:

• •Ensure our services are not used to facilitate money laundering or terrorist financing.
• •Establish robust procedures for verifying player identity and monitoring transactions.
• •Report suspicious activities to relevant authorities where required.
• •Promote awareness and training among employees and partners.

2. Scope

This AML policy applies to:

• •All users and account holders of 3XC Gaming platforms.
• •All games, tournaments, and services offered by 3XC Gaming Limited.
• •All employees, agents, and contractors acting on behalf of 3XC Gaming Limited.

3. Customer Due Diligence (CDD) & KYC

We implement a Know Your Customer (KYC) procedure for all users before allowing full access to gaming services, including:

• •Identity Verification: Full name, date of birth, address, and valid government-issued ID.
• •Age Verification: Confirming that all users are 18+ or the legal age of gaming in their jurisdiction.
• •Address Verification: Via utility bill or bank statement, where necessary.
• •Ongoing Monitoring: Regular checks to ensure the information remains accurate and up to date.

Enhanced Due Diligence (EDD) may be applied in high-risk scenarios, such as:

• •Large or irregular deposits/withdrawals
• •Users from high-risk jurisdictions
• •Inconsistent transactional behavior

4. Transaction Monitoring

We monitor player activity to identify patterns consistent with money laundering, including:

• •Rapid movement of large funds in and out of accounts
• •Use of multiple accounts or third-party deposits
• •Structuring transactions to avoid thresholds
• •Frequent deposits with minimal gameplay

Suspicious activity is flagged for internal review and, if necessary, escalation to the relevant authorities.

5. Reporting Suspicious Activities

In accordance with applicable regulations, we will file Suspicious Transaction Reports (STRs) with local law enforcement or financial intelligence units if we suspect a transaction may be linked to money laundering or other financial crime.

6. Record Keeping

We maintain comprehensive records of:

• •KYC documentation
• •Deposit and withdrawal history
• •Communication logs
• •Internal review actions

These records are retained for a minimum of 5 years in compliance with local regulations.

7. Employee Training

All staff involved in operations, support, compliance, and payments are regularly trained on:

• •AML obligations and procedures
• •How to identify and report suspicious behavior
• •Data protection and confidentiality

8. Third-Party Payments

To reduce risk, we do not accept or process payments from third-party accounts. All deposits and withdrawals must originate from accounts held in the name of the registered player.

9. Sanctions and Prohibited Jurisdictions

We do not allow users from countries subject to international sanctions or known for high money laundering risk. We regularly update our list of restricted jurisdictions to remain compliant with global AML regulations.

10. Policy Review

This AML policy is reviewed periodically and updated to reflect:

• •Changes in applicable laws and regulations
• •Operational changes within 3XC Gaming
• •Emerging risks and industry best practices