1. Policy Statement & Purpose

Betzy is committed to complying fully with all applicable anti-money-laundering (AML), counter-financing-of-terrorism (CFT), and know-your-customer (KYC) laws and regulations. This Policy establishes the framework Betzy uses to prevent, detect, and report money laundering, terrorist financing, and other financial crimes conducted through or facilitated by our Platform.

This Policy applies to all employees, contractors, officers, and agents of Betzy, and to all users who register for or use the Betzy Platform. Compliance is mandatory and non-negotiable. Violations may result in account suspension, termination, forfeiture of funds, regulatory referral, and/or legal action.

2. Regulatory Framework

Betzy's AML/CFT program is designed to comply with, among other authorities:

• Bank Secrecy Act (BSA), 31 U.S.C. §§ 5311–5336
• USA PATRIOT Act (Title III — International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001)
• OFAC (Office of Foreign Assets Control) sanctions regulations
• Internal Revenue Code (IRC) tax-reporting provisions
• Financial Crimes Enforcement Network (FinCEN) guidance for non-bank financial institutions
• Financial Action Task Force (FATF) Recommendations
• Applicable state money-transmitter and gaming regulations

3. Governance

4. Risk-Based Approach & Customer Risk Rating

Betzy applies a risk-based approach (RBA) to AML/CFT compliance. Each customer is assigned a risk rating at onboarding and periodically re-evaluated based on the following factors:

Risk ratings determine the level of due diligence applied to each customer account. Higher-risk customers are subject to enhanced monitoring, additional documentation requirements, and senior management review.

5. Customer Identification Program (CIP)

6. Customer Due Diligence (CDD)

7. Enhanced Due Diligence (EDD)

EDD is triggered automatically when a customer's activity crosses the thresholds in Annex B. EDD may also be applied at the MLRO's discretion for high-risk accounts.

8. Geofencing & Restricted Jurisdictions

Betzy does not permit gameplay or redemption from the following U.S. states, which have specific legal restrictions:

Additional jurisdictions may be restricted at counsel's determination. Users who attempt to circumvent geofencing controls (e.g., via VPN) will have their accounts suspended and any pending redemptions forfeited.

9. Transaction Monitoring & Red Flags

Betzy employs automated transaction-monitoring systems to detect suspicious patterns in real time. The following red flags trigger manual review and potential SAR filing:

See Annex A for the complete Red-Flag Indicator Catalog.

10. Suspicious Activity Reports (SAR) & Currency Transaction Reports (CTR)

Betzy will file a Suspicious Activity Report (SAR) with FinCEN for any transaction or pattern of activity that involves or aggregates $5,000 or more and for which Betzy knows, suspects, or has reason to suspect involves funds from illegal activity, is designed to evade reporting requirements, lacks a lawful purpose, or otherwise involves suspicious activity.

Betzy will file a Currency Transaction Report (CTR) for any currency transaction (or series of related transactions) exceeding $10,000 in a single business day.

SAR filings are confidential. Disclosing to any person that a SAR has been filed or is contemplated ("tipping off") is prohibited under 31 U.S.C. § 5318(g)(2) and may result in criminal liability.

11. Recordkeeping

Betzy retains all AML/CFT-related records for a minimum of five (5) years from the date of the transaction or account closure, whichever is later. Records retained include:

• Customer identification records and KYC documentation
• Transaction records (purchases, redemptions, reversals)
• SAR and CTR filings and supporting documentation
• Sanctions screening results and adverse-media reports
• SOF/SOW documentation collected during EDD
• Internal suspicious-activity reports and MLRO decisions
• Training records

12. Independent Testing & Audit

Betzy's AML/CFT program is subject to independent testing and audit at least annually by qualified personnel who are not responsible for day-to-day compliance operations. Audit findings are reported to senior management and remediated within documented timeframes.

13. Training

All employees and contractors who interact with customers, handle financial transactions, or have AML/CFT responsibilities receive mandatory AML/CFT training at onboarding and at least annually thereafter. Training covers:

• Applicable AML/CFT laws and regulations
• Betzy's internal policies and procedures
• Red-flag indicators and how to identify suspicious activity
• How to report concerns to the MLRO
• Tipping-off prohibitions and whistleblower protections

14. Sanctions Compliance

Betzy maintains a zero-tolerance policy for conducting transactions with sanctioned persons, entities, or jurisdictions. Betzy screens all customers against OFAC, UN, EU, and HM Treasury sanctions lists at onboarding and on an ongoing basis. Any positive match results in immediate account freeze and OFAC reporting as required.

Betzy does not accept transactions from, or make payments to, persons located in comprehensively sanctioned countries or territories, including but not limited to Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.

15. Reliance on Third-Party Verification

Betzy may rely on contracted third-party identity-verification and screening providers to perform certain CIP and CDD functions. Such reliance does not relieve Betzy of its AML/CFT obligations. Betzy retains ultimate responsibility for program compliance and will periodically audit its service providers' performance.

16. Law Enforcement & Subpoena Response

Betzy cooperates fully with law enforcement agencies and regulatory authorities. Betzy will respond to lawfully issued subpoenas, court orders, and formal requests for information within the timeframes required by law. All such requests are handled by the MLRO and legal counsel. Betzy will not tip off any subject of a law-enforcement investigation.

17. Tax Reporting Coordination

Betzy's AML/CFT function coordinates with its tax-reporting function to ensure consistency between transaction-monitoring records and IRS information-reporting obligations (Form 1099-MISC, W-9/W-8 collection, backup withholding). Any discrepancy between reported prizes and redemption activity is flagged to the MLRO.

18. Policy Review & Updates

This Policy is reviewed at least annually and updated as necessary to reflect changes in applicable law, regulatory guidance, FATF recommendations, and Betzy's risk profile. Material updates are communicated to all relevant personnel and reflected in the Policy version number and effective date.

Annex A – Red-Flag Indicator Catalog

The following indicators, individually or in combination, may trigger enhanced review and potential SAR filing:

• Transactions just below reporting thresholds, repeated multiple times in a short period (structuring).
• Rapid deposit-and-redemption activity with little or no gameplay.
• Multiple accounts appearing to be controlled by the same individual or group.
• Inconsistency between stated source of funds and actual deposit amounts.
• Use of numerous different payment methods in rapid succession.
• Requests to redirect redemptions to a third party or account not matching the customer's identity.
• Customer reluctance to provide KYC documentation or provides inconsistent information.
• Sudden unexplained increase in account activity inconsistent with prior behavior.
• Use of VPN, anonymizing proxies, or Tor to access the Platform.
• Cryptocurrency deposits or redemption requests from high-risk or flagged wallet addresses.
• Chargebacks or disputes filed immediately after purchases, while retaining promotional credits.
• Activity patterns consistent with bonus farming or promotion abuse across multiple accounts.
• Customer identified as a Politically Exposed Person (PEP) without adequate SOW documentation.
• Address, device, or IP address shared across multiple seemingly unrelated accounts.
• Transactions involving jurisdictions subject to U.S. sanctions or known high-risk geographies.
• Any transaction or pattern that, in the MLRO's judgment, lacks a plausible legitimate purpose.

Annex B – EDD Threshold Matrix