AML Policy

Aslot.com is owned and operated by Rubycode Solution Ltd.

Registration number: 000047922.

Registered address: Sea Urchin Street, San Pedro Town, Ambergris Caye, Belize.

Aslot.com is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros and operates under License No. ALSI-202505051-F12. Aslot.com has passed all regulatory compliance and is legally authorized to conduct gaming operations for all games of chance and wagering.

1Company Business Model

Rubycode Solution Ltd. (“Aslot” or the “Company”) is a company established in Belize and operates the online casino www.aslot.com. Aslot.com is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros under License No. ALSI-202505051-F12.

As part of its global operations, Aslot 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.

2Company Policy Statement

Aslot is not a financial institution within the meaning of applicable law of its operating jurisdiction(s) and is accordingly not directly subject to statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers, except where required by law.

However, in accordance with applicable Anti-Money Laundering and Combating the Financing of Terrorism (“AML/CFT”) principles and gaming compliance obligations, Aslot expressly prohibits and rejects the use of Aslot products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with applicable anti-money laundering (“AML”) laws, regulations and norms.

Aslot continues to monitor relevant standards and guidance, including norms promulgated by the Financial Action Task Force (“FATF”), applicable regulators, and gaming industry bodies, and will take necessary action as it deems appropriate to reflect changes in law and best practice.

Aslot’s intention is to follow global best practices in guarding against Aslot products being used to facilitate such activities. Those best practices include:

• Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;

• Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;

• Provision of related education and training to relevant personnel; and

• Independent reviews, monitoring and maintenance of the policy, procedures and controls.

3Definitions

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.

Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions. For example, they are used:

• To encourage a change in behaviour for a target country or regime;

• To apply pressure on a target country to comply with set objectives;

• As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or

• To prevent and suppress the financing of terrorists or terrorist acts.

4Governance and Oversight

Aslot has appointed (or may appoint, where applicable) a Chief Compliance Officer (“CCO”) that is responsible for coordinating the implementation of the AML Policy and policy program.

The Chief Compliance Officer’s duties may include developing AML initiatives, working with other stakeholders to revise the AML policy, assessing new regulatory requirements and investigating potentially suspicious or unusual activity. Aslot may also provide AML training to relevant employees on a regular basis.

5Know Your Customer and Transaction Monitoring

Aslot will apply appropriate user due diligence and ongoing monitoring measures required by law. Aslot will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity.

Aslot uses a combination of software development, internal controls and third-party service agreements to support compliance with applicable law.

5.1. Know Your Customer

A. Customer Due Diligence

Aslot has adopted a risk-based CDD approach to enable Aslot to understand the nature and purpose of the user relationship to the Aslot platform in order to develop a customer risk profile. In order to do so, Aslot collects certain documentary and non-documentary information at account opening commensurate with the type of account and services that Aslot offers. Aslot maintains different CDD for different accounts and services.

For instance, the CDD may require users to go through Aslot’s customer identification program (“CIP”). The CIP consists of procedures for:

• Collecting baseline (e.g., wallet address, email address) information at account creation through Aslot’s user onboarding portal;

• Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user’s account;

• Maintaining records of the information used to identify the user; and

• Determining if a user appears on any list of known or suspected terrorists or terrorist organisations provided to relevant institutions based on the above information.

The above steps are operationalised using the following measures:

Identity and Age Verification. A third-party service provider may support Aslot’s ability to determine the legitimacy of identification information and other KYC materials or information provided and will confirm that the user is permissible. The service provider may also confirm that the user does not appear to be located in a comprehensively sanctioned or otherwise prohibited jurisdiction and may search global sanctions lists using onboarding information such as wallet addresses.

Customer Information. Aslot will collect details on each user to form a reasonable belief that Aslot knows the identity of its users commensurate with the user’s risk profile. For instance, Aslot may collect such details as wallet address, name, address, country, date of birth, or postal code (collectively, “KYC Information”). Aslot may collect any of the above KYC Information prior to issuing a funding address (e.g., QR code) to users. Aslot may, at its own discretion, rely on the performance by another institution of some or all elements of its CIP where legally permissible.

Geo-blocking for Prohibited Jurisdictions. Aslot may require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.

Geo-blocking for Sanctioned Jurisdictions. Aslot may also require contractual client certifications that such users are not subject to United States, European Union, or other global sanctions or watch lists, including individuals or entities associated with comprehensively sanctioned jurisdictions. Aslot may rely on various risk-based measures to verify these representations, including KYC measures and IP address-based geo-blocking.

Contractual Prohibitions on Users Onboarding from Prohibited Jurisdictions. Users are notified at onboarding that Aslot does not offer services in restricted jurisdictions. Aslot’s policy on restricting user activity stems from a combination of risk, fraud prevention, and AML standards, as well as assessments associated with the permissibility of its services in certain jurisdictions.

B. Enhanced Due Diligence and Ongoing Monitoring

Aslot performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, Aslot may implement a set of red flag indicators that help determine such behaviours and require further action in assessing customer information.

Whenever one of those red flags is triggered, the user account may be suspended and Aslot may pursue enhanced due diligence. Enhanced KYC diligence under this policy may include, but is not limited to, the provision of:

• Full legal name;

• Country of citizenship;

• Permanent address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office or other physical location);

• Identification number (either a taxpayer identification number, or, if unavailable, a passport number and country of issuance, alien identification card number, or number and country of issuance of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);

• Identification document; and

• Source of funds and source of wealth.

Aslot may use a third-party service provider to verify any of the above information as determined necessary to establish a reasonable basis to know the true identity of the user where the user’s activity warrants such action.

C. Acceptance Policy

Aslot may decline to accept and may block users that:

• Do not provide the identification information requested by Aslot;

• Provide fake identification documents;

• Try to use different means to deceive about their location;

• Are from restricted or prohibited jurisdictions;

• Are subject to United States, European Union, or other global sanctions or watch lists;

• Present responsible gaming concerns or other legal/compliance concerns, subject to applicable law and policy;

• Have source of funds originating from or exchanged in restricted jurisdictions; or

• Otherwise trigger risk concerns under Aslot’s internal risk policies and applicable law.

Aslot reserves the right to block and suspend a player for other reasons at its own discretion, subject to applicable law and regulatory obligations.

5.2. Transactions Monitoring

Aslot is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the Company conducts business. For that purpose, Aslot may establish a transaction monitoring program with controls and processes to identify and detect unusual activity in real time and in ongoing monitoring.

Aslot may conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and/or by third-party vendors to review user history and patterns of activity, detect and report unusual activity as required, and develop and implement additional controls or limits in its platform.

Aslot may implement procedures addressing the following two key components of unusual or suspicious activity management:

• Identification of unusual activity through methods that may include employee and customer identification, law enforcement inquiries, other referrals, or transaction and surveillance monitoring system reports; and

• Alert management that focuses on processes used to investigate, evaluate and document identified unusual or potentially suspicious activity.

Aslot may use the following processes to achieve both goals:

• Transaction Monitoring for Sanctioned or Prohibited Jurisdictions. Aslot may, in its reasonable discretion, impose certain due diligence requests at user balance withdrawal. Aslot may conduct a mixture of manual and automated transaction monitoring processes to identify red flag behaviour. Where such behaviour is identified, Aslot may refuse to process withdrawal attempts or collect additional information from the recipient.

• Screening for Sanctioned Parties. Prior to issuing a funding address to a user, Aslot may screen a user’s wallet address against applicable sanctions databases. Such screening measures may rely on third-party blockchain forensics vendors such as Chainalysis or equivalent providers. Aslot may periodically re-screen wallet addresses against such databases.

• Identification of Unusual Activity. Aslot may monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags appropriate to its business. Monitoring may be conducted through regular reports of unusual, high-risk, or suspicious user activity.

• Anti-Mixing Measures. Aslot may utilise software designed to detect suspicious deposit or withdrawal patterns. Such instances may be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform.

• Blockchain Analytics Review. Crypto deposits and withdrawals may be reviewed for signs of fraud or suspicious behaviour. A user’s account may be suspended and reviewed upon alerts of potential illicit behaviour. Sufficient proof of wealth may be requested from high-risk accounts. Aslot may refuse withdrawals to certain high-risk addresses as determined under its risk-scoring procedures.

• Withdrawal Threshold KYC. Additionally, and independently, an account may be suspended until adequate KYC diligence occurs once that account reaches a withdrawal threshold dependent on the account’s risk characterisation over the life of the account.

D. Other Ongoing Monitoring Controls

Additionally to the above-mentioned controlling procedures, Aslot may implement the following procedures to complement its know your customer and ongoing monitoring procedures:

• Ban Evasion Detection. Aslot may utilise third-party software designed to detect the use by one user of multiple accounts, including links between the same devices used to access multiple accounts. Such instances may be dealt with on a case-by-case basis depending on the perceived level of risk. Attempts to circumvent restrictions, including prohibited peer-to-peer transfers within platform infrastructure, may be treated as red flags.

• Time Zone Monitoring. Aslot may implement time zone controls that detect user device information and cross-check it with restricted jurisdiction indicators to understand whether users may be attempting to use geolocation software to hide the jurisdictions from which they are connecting.

• Products and Services Review. Aslot may establish additional procedures to avoid facilitating user attempts to exploit the platform. Aslot may maintain user-facing terms and additional safeguards, including policies limiting which assets can be used on the platform. Aslot may prohibit anonymity-enhancing technologies such as mixers, tumblers, or certain coins and tokens where restricted by policy or law.

• Vendor Management. Aslot works with reputable third-party service providers as part of its compliance infrastructure. Aslot may periodically assess the strength and performance of key providers to determine whether additional services or remedial actions are necessary to comply with this policy.

Compliance Innovation

6Education and Training

Aslot, with the assistance of legal counsel and under the oversight of its CCO (where applicable), may provide employees AML, anti-terrorist financing and trade sanctions compliance training on a periodic basis, as deemed appropriate.

7Reporting

Aslot is obliged to report any unusual or suspicious transactions in accordance with applicable law and regulatory requirements. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing, or other criminal activities may be reported as suspicious activity to the regulator or competent authority.