Anti-Money Laundering and Know Your Customer Policy

1. Purpose

Mobile Incorporated Limited (the "Company", "we", "our", or "us") is committed to conducting its business in a manner that safeguards the integrity of the financial system and prevents its products and services from being used for money laundering, terrorist financing, fraud, or other unlawful activities.

As a holder of a Business-to-Consumer Gaming Service Licence issued by the Malta Gaming Authority ("MGA"), the Company is a subject person under Maltese anti-money laundering legislation and implements appropriate controls to comply with its legal and regulatory obligations.

This Policy applies to all customers and prospective customers of the Company.

2. Risk-Based Compliance Programme

The Company maintains a comprehensive AML and KYC compliance programme based on a risk-sensitive approach. Customer relationships and transactions are assessed according to their potential exposure to financial crime risks, allowing compliance measures to be proportionate to the level of identified risk.

The Company's compliance programme includes:

• customer identification and verification procedures;
• ongoing monitoring of customer relationships;
• financial crime risk assessments;
• sanctions and Politically Exposed Person (PEP) screening;
• suspicious activity reporting procedures;
• employee training and awareness; and
• governance and internal oversight arrangements.

3. Customer Identification and Verification

The Company requires customers to verify their identity before, during, or after the establishment of a business relationship where required by law or internal risk assessment.

Verification procedures may include confirmation of:

• full legal name;
• permanent residential address;
• date and place of birth;
• nationality;
• identity document validity; and
• ownership of payment methods used on the account.

Verification may be completed using electronic identity verification services, documentary evidence, or other reliable and independent information sources.

Where verification cannot be completed to the Company's satisfaction, account access or certain account functions may be suspended until the required information has been received and approved.

4. Enhanced Customer Due Diligence

Additional due diligence measures may be implemented where higher financial crime risks are identified.

Circumstances that may require Enhanced Due Diligence include:

• identification of a customer as a Politically Exposed Person;
• transactions or account activity presenting elevated risk;
• uncertainty regarding the legitimacy of funds or wealth;
• business relationships involving higher-risk jurisdictions;
• adverse media or other negative intelligence; or
• any circumstance requiring enhanced scrutiny under applicable legislation.

Enhanced Due Diligence measures may involve:

• obtaining additional identity documentation;
• verifying source of funds and source of wealth;
• conducting independent verification checks;
• obtaining further information regarding the intended nature of the business relationship; and
• approval from appropriately authorised personnel before continuing the relationship.

5. Source of Funds and Source of Wealth

The Company may require customers to demonstrate the legitimate origin of funds deposited or used through its services.

Where appropriate, customers may also be required to demonstrate the origin of their overall wealth.

Examples of supporting documentation include:

• bank statements;
• employment or salary documentation;
• tax records;
• company ownership documentation;
• investment statements;
• inheritance records; or
• contracts relating to property or asset sales.

Failure to provide requested documentation may result in restrictions being placed on the account until the review has been completed.

6. Monitoring of Customer Activity

The Company continuously monitors customer activity throughout the duration of the business relationship.

Monitoring procedures are designed to identify, among other things:

• unusual deposit or withdrawal activity;
• transactions inconsistent with the customer's profile;
• rapid movement of funds;
• structuring intended to avoid regulatory thresholds;
• irregular betting behaviour; and
• any activity that may indicate money laundering or terrorist financing.

Where unusual activity is identified, additional enquiries or verification measures may be undertaken before further account activity is permitted.

7. Withdrawal Procedures and Identity Verification

The Company may apply verification procedures before processing withdrawals in order to comply with AML, CTF, fraud prevention, and regulatory obligations.

Customers may be required to complete identity verification where cumulative deposits exceed €2,000.

For this purpose, cumulative deposits may be calculated:

• from all deposits made since the commencement of the business relationship, assessed on a daily cumulative basis; or
• over a rolling period of one hundred and eighty (180) days.

Until the required verification has been completed, the Company may delay or suspend withdrawal requests.

Depending on the circumstances, customers may also be required to provide additional documentation relating to their identity, payment instruments, source of funds, or any other information considered necessary to satisfy regulatory obligations before withdrawals are authorised.

8. Sanctions Screening

The Company screens customers against applicable sanctions and risk databases during onboarding and periodically throughout the business relationship.

Screening may include:

• European Union sanctions lists;
• United Nations sanctions lists;
• national sanctions registers;
• Politically Exposed Person databases; and
• other recognised compliance screening databases.

Potential matches are reviewed by the Compliance function before any decision regarding the customer relationship is made.

9. Suspicious Transaction Reporting

Where the Company knows, suspects, or has reasonable grounds to suspect that customer activity may involve money laundering, terrorist financing, or related criminal conduct, it will comply with its statutory obligations by submitting a Suspicious Activity Report ("SAR") to the Financial Intelligence Analysis Unit ("FIAU").

The Company is prohibited from informing customers that a report has been made or that an investigation is being conducted.

The Company will cooperate fully with the FIAU, the MGA, and any competent authority exercising lawful powers.

10. Customer Responsibilities

Customers are expected to:

• provide complete, accurate, and up-to-date information;
• notify the Company of any material changes to their personal information;
• respond promptly to requests for verification;
• submit authentic documentation when requested; and
• cooperate fully with compliance reviews.

Failure to comply may result in limitations on account functionality, refusal of transactions, suspension, or closure of the account where appropriate.

11. Internal Governance

The Company maintains an AML governance framework designed to support effective regulatory compliance.

This framework includes:

• a designated Money Laundering Reporting Officer (MLRO);
• documented AML and CTF policies and procedures;
• internal reporting and escalation arrangements;
• periodic enterprise-wide risk assessments;
• independent compliance monitoring; and
• mandatory AML and CTF training for relevant employees.

The effectiveness of these arrangements is reviewed periodically as part of the Company's compliance monitoring programme.

12. Record Management and Confidentiality

The Company maintains records relating to customer due diligence, monitoring activities, risk assessments, transaction history, and regulatory reporting in accordance with applicable legal requirements.

Records are retained for a minimum of five (5) years following the termination of the business relationship or the completion of the relevant transaction, as required by law.

All personal information collected under this Policy is processed in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR). Access to such information is limited to authorised personnel and competent authorities where disclosure is legally required.

13. Review of the Policy

This Policy forms part of the Company's compliance framework and is reviewed periodically to ensure that it remains consistent with applicable legislation, regulatory guidance, and operational requirements.

The Company reserves the right to amend this Policy where necessary. Any updated version will replace previous editions and will be made available through the Company's official communication channels.

Chính Sách Chống Rửa Tiền và Biết Người Dùng Của Bạn

1. Purpose

Mobile Incorporated Limited (the "Company", "we", "our", or "us") is committed to conducting its business in a manner that safeguards the integrity of the financial system and prevents its products and services from being used for money laundering, terrorist financing, fraud, or other unlawful activities.

As a holder of a Business-to-Consumer Gaming Service Licence issued by the Malta Gaming Authority ("MGA"), the Company is a subject person under Maltese anti-money laundering legislation and implements appropriate controls to comply with its legal and regulatory obligations.

This Policy applies to all customers and prospective customers of the Company.

2. Risk-Based Compliance Programme

The Company maintains a comprehensive AML and KYC compliance programme based on a risk-sensitive approach. Customer relationships and transactions are assessed according to their potential exposure to financial crime risks, allowing compliance measures to be proportionate to the level of identified risk.

The Company's compliance programme includes:

• customer identification and verification procedures;
• ongoing monitoring of customer relationships;
• financial crime risk assessments;
• sanctions and Politically Exposed Person (PEP) screening;
• suspicious activity reporting procedures;
• employee training and awareness; and
• governance and internal oversight arrangements.

3. Customer Identification and Verification

The Company requires customers to verify their identity before, during, or after the establishment of a business relationship where required by law or internal risk assessment.

Verification procedures may include confirmation of:

• full legal name;
• permanent residential address;
• date and place of birth;
• nationality;
• identity document validity; and
• ownership of payment methods used on the account.

Verification may be completed using electronic identity verification services, documentary evidence, or other reliable and independent information sources.

Where verification cannot be completed to the Company's satisfaction, account access or certain account functions may be suspended until the required information has been received and approved.

4. Enhanced Customer Due Diligence

Additional due diligence measures may be implemented where higher financial crime risks are identified.

Circumstances that may require Enhanced Due Diligence include:

• identification of a customer as a Politically Exposed Person;
• transactions or account activity presenting elevated risk;
• uncertainty regarding the legitimacy of funds or wealth;
• business relationships involving higher-risk jurisdictions;
• adverse media or other negative intelligence; or
• any circumstance requiring enhanced scrutiny under applicable legislation.

Enhanced Due Diligence measures may involve:

• obtaining additional identity documentation;
• verifying source of funds and source of wealth;
• conducting independent verification checks;
• obtaining further information regarding the intended nature of the business relationship; and
• approval from appropriately authorised personnel before continuing the relationship.

5. Source of Funds and Source of Wealth

The Company may require customers to demonstrate the legitimate origin of funds deposited or used through its services.

Where appropriate, customers may also be required to demonstrate the origin of their overall wealth.

Examples of supporting documentation include:

• bank statements;
• employment or salary documentation;
• tax records;
• company ownership documentation;
• investment statements;
• inheritance records; or
• contracts relating to property or asset sales.

Failure to provide requested documentation may result in restrictions being placed on the account until the review has been completed.

6. Monitoring of Customer Activity

The Company continuously monitors customer activity throughout the duration of the business relationship.

Monitoring procedures are designed to identify, among other things:

• unusual deposit or withdrawal activity;
• transactions inconsistent with the customer's profile;
• rapid movement of funds;
• structuring intended to avoid regulatory thresholds;
• irregular betting behaviour; and
• any activity that may indicate money laundering or terrorist financing.

Where unusual activity is identified, additional enquiries or verification measures may be undertaken before further account activity is permitted.

7. Withdrawal Procedures and Identity Verification

The Company may apply verification procedures before processing withdrawals in order to comply with AML, CTF, fraud prevention, and regulatory obligations.

Customers may be required to complete identity verification where cumulative deposits exceed €2,000.

For this purpose, cumulative deposits may be calculated:

• from all deposits made since the commencement of the business relationship, assessed on a daily cumulative basis; or
• over a rolling period of one hundred and eighty (180) days.

Until the required verification has been completed, the Company may delay or suspend withdrawal requests.

Depending on the circumstances, customers may also be required to provide additional documentation relating to their identity, payment instruments, source of funds, or any other information considered necessary to satisfy regulatory obligations before withdrawals are authorised.

8. Sanctions Screening

The Company screens customers against applicable sanctions and risk databases during onboarding and periodically throughout the business relationship.

Screening may include:

• European Union sanctions lists;
• United Nations sanctions lists;
• national sanctions registers;
• Politically Exposed Person databases; and
• other recognised compliance screening databases.

Potential matches are reviewed by the Compliance function before any decision regarding the customer relationship is made.

9. Suspicious Transaction Reporting

Where the Company knows, suspects, or has reasonable grounds to suspect that customer activity may involve money laundering, terrorist financing, or related criminal conduct, it will comply with its statutory obligations by submitting a Suspicious Activity Report ("SAR") to the Financial Intelligence Analysis Unit ("FIAU").

The Company is prohibited from informing customers that a report has been made or that an investigation is being conducted.

The Company will cooperate fully with the FIAU, the MGA, and any competent authority exercising lawful powers.

10. Customer Responsibilities

Customers are expected to:

• provide complete, accurate, and up-to-date information;
• notify the Company of any material changes to their personal information;
• respond promptly to requests for verification;
• submit authentic documentation when requested; and
• cooperate fully with compliance reviews.

Failure to comply may result in limitations on account functionality, refusal of transactions, suspension, or closure of the account where appropriate.

11. Internal Governance

The Company maintains an AML governance framework designed to support effective regulatory compliance.

This framework includes:

• a designated Money Laundering Reporting Officer (MLRO);
• documented AML and CTF policies and procedures;
• internal reporting and escalation arrangements;
• periodic enterprise-wide risk assessments;
• independent compliance monitoring; and
• mandatory AML and CTF training for relevant employees.

The effectiveness of these arrangements is reviewed periodically as part of the Company's compliance monitoring programme.

12. Record Management and Confidentiality

The Company maintains records relating to customer due diligence, monitoring activities, risk assessments, transaction history, and regulatory reporting in accordance with applicable legal requirements.

Records are retained for a minimum of five (5) years following the termination of the business relationship or the completion of the relevant transaction, as required by law.

All personal information collected under this Policy is processed in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR). Access to such information is limited to authorised personnel and competent authorities where disclosure is legally required.

13. Review of the Policy

This Policy forms part of the Company's compliance framework and is reviewed periodically to ensure that it remains consistent with applicable legislation, regulatory guidance, and operational requirements.

The Company reserves the right to amend this Policy where necessary. Any updated version will replace previous editions and will be made available through the Company's official communication channels.