Anti-Money Laundering (AML) Policy

1. Introduction

Sorte Seis, licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros (License No. ALSI-152512013-F13), recognizes the inherent risks associated with money laundering and terrorist financing in its operations. This AML Policy underscores our commitment to identifying, preventing, and mitigating these risks in full compliance with applicable laws and international standards.

2. Policy Statement and Objectives

Sorte Seis is committed to ensuring that its products are not misused for money laundering, terrorist financing, or any other illicit financial activities. Our primary objectives include:

• Implementing and rigorously enforcing strong controls to prevent any improper use of our services.
• Adopting a risk-based approach to evaluate and monitor customer behavior.
• Ensuring full compliance with all relevant laws and regulatory requirements.
• Providing continuous training and support to our staff to effectively identify and manage potential money laundering or terrorist financing activities.

3. Company Business Model

Sorte Seis is an online gaming platform offering a wide range of gaming and wagering options. We recognize the potential risk of our services being exploited by money launderers or terrorists. Therefore, our business model and operational framework are meticulously designed to enhance transparency, enforce rigorous customer due diligence, and ensure full compliance with all applicable regulatory standards.

4. Chief Compliance Officer

A Chief Compliance Officer (CCO) is designated to oversee the implementation and enforcement of our AML policies and procedures. This role entails establishing and maintaining the necessary control measures, staying current with legislative updates, and ensuring that any suspicious activities are promptly and accurately reported to the appropriate authorities.

5. Know Your Customer (KYC) and Customer Due Diligence (CDD)

• Customer Identification: We gather and confirm the identification details of our customers, including government-issued identification and proof of residence.
• Risk Assessment: We evaluate and categorize customers based on their risk profiles, using the information provided and their transaction behavior.
• Enhanced Due Diligence (EDD): For customers identified as high risk or in cases of unusual activity, we will request further information and documentation to gain a clearer understanding of the transactions.

7. Employee Training and Awareness

All employees will be trained on AML regulations, including how to identify suspicious activities and the proper procedures for reporting them. This training will be regularly updated to incorporate legislative changes and address emerging risks.

8. Review and Update of AML Policy

This policy will undergo periodic reviews and updates to incorporate any changes in legislation, regulatory guidance, or the risk landscape. The Chief Compliance Officer is tasked with ensuring that the policy stays current and effective.

9. Regulatory Compliance and Cooperation

Sorte Seis is fully dedicated to cooperating with regulatory bodies and law enforcement agencies, ensuring that we meet all reporting and compliance obligations mandated by applicable laws.

10. Conclusion

Sorte Seis maintains a steadfast commitment to exceptional anti-money laundering practices and requires all employees, customers, and partners to adhere to these protocols to prevent the exploitation of its products and services for money laundering or terrorist financing purposes.

In developing this policy, we have comprehensively addressed every critical area—including customer due diligence, employee responsibilities, and continuous monitoring—to build a robust and compliant AML framework for Sorte Seis. This policy will be communicated to all stakeholders to ensure full transparency and a clear understanding of our AML commitments.