AML POLICY OF CURACAO CO N.V.

Last Updated: 20 July 2024

This Anti-Money Laundering (AML) Policy, managed by RINO Entertainment B.V. and based in Willemstad, Curacao (Registration number 10692), outlines our commitment to high standards of AML compliance in accordance with EU regulations. Our aim is to protect our users by implementing a three-step verification process and comprehensive monitoring of transactions to prevent money laundering.

Objectives of the AML Policy
Rino-Casino is committed to ensuring that all users’ identity and payment sources are verified to prevent misuse of the site for illicit purposes. Our AML policy complies with the EU "Directive 2015/849" on money laundering prevention, "Regulation 2015/847" on fund transfer information, and additional laws.

Definition of Money Laundering
Money laundering refers to hiding or disguising the origins of illicitly acquired funds or assets by transferring or concealing the nature or ownership of the property.

Organization and AML Oversight
Rino-Casino has appointed an AML Compliance Officer (AMLCO) who reports directly to senior management. The AMLCO ensures compliance and enforces this policy. Major changes to AML policy are subject to approval by Miracle Entertainment B.V. management.

Three-Step Verification Process
1. Step 1: Basic personal details (name, DOB, address) for account creation.
2. Step 2: For deposits or withdrawals exceeding $2,000, ID verification is required with a government-issued ID alongside a unique verification code.
3. Step 3: For transactions over $5,000, proof of source of funds (SoW) such as business ownership or employment details is mandatory.

Know Your Customer (KYC) Requirements
KYC is a fundamental component of AML compliance:
- Users must submit official ID and a photo of themselves with a verification note.
- Proof of address is required via recent utility bills.
- Source of funds documentation for significant transactions.

Risk Management
Countries are categorized into low, medium, and high-risk regions, with additional verification for users from higher-risk regions. Monitoring occurs for unusual activities, including rapid deposits and withdrawals without gameplay or attempts to change payment methods.

Ongoing Transaction Monitoring
Our AML team monitors transactions continuously in coordination with trusted payment processors, ensuring due diligence on all transactions.

Record-Keeping
All user identification and transaction records are securely stored for at least 10 years.

Training and Auditing
All staff involved in AML processes undergo regular training and the AML policy is subject to internal audits.

Data Security
User data is protected under strict data security policies, aligned with Directive 95/46/EC. Data is shared only when legally required to prevent money laundering.