👮‍♂️AML Policy

Duel adheres to a variety of AML requirements in order to ensure a safe and compliant gambling experience.

Introduction: duel.win is a brand name of Duelana Games B.V., duel.win is operated by Duelana Games B.V., which has its office registered at Abraham de Veerstraat 9 in Curacao.

Objective of the AML Policy: We aim to provide the highest level of security to all our users and customers on duel.win. To achieve this, we have implemented a three-step account verification process to ensure the identity of our customers. This is done to verify that the registered person's details are accurate and that the deposit and withdrawal methods used are not stolen or being used by unauthorized individuals, as part of our overall framework for combating money laundering. We also recognize that different safety measures need to be taken depending on the nationality and origin of the customer, as well as the payment and withdrawal methods used.

duel.win also implements reasonable measures to control and mitigate the risk of money laundering, including dedicating appropriate resources.

duel.win is committed to upholding high standards of anti-money laundering (AML) in accordance with the EU guidelines and regulations, and requires its management and employees to enforce these standards to prevent the misuse of its services for money laundering purposes.

The AML program of duel.win is designed to comply with the following:

EU: "Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering"

EU: "Regulation 2015/847 on information accompanying transfers of funds"

EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE: "Law of 18 September 2017 on the prevention of money laundering and limitation of the use of cash"

Definition of money laundering:

• Money Laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such activity to evade the legal consequences of their actions;

• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such activity;

• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such activity;

• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions referred to in the points above.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for duel.win:

In compliance with AML legislation, duel.win has designated the highest level of management responsibility for the prevention of money laundering, which rests with the full management of Duelana Games B.V.

AML policy changes and implementation requirements:

Any significant changes to the AML policy of duel.win must receive approval from the general management of Duelana Games N.V.

Three-Step Verification:

Step one verification:

Every user and customer may be required to complete step one verification in order to make withdrawals. Regardless of the choice of payment, payment amount, withdrawal amount, and nationality of the user/customer, step one verification may be the initial requirement. Step one verification may involve the completion of a document by the user/customer themselves, providing information such as first name, second name, date of birth, country of usual residence, gender, and full address.

Step two verification:

Step two verification may be required for users who deposit over $2,000 (two thousand US Dollars), withdraw over $2,000 (two thousand US Dollars), or send another user over $1,000 (one thousand US Dollars). Until step two verification is completed, withdrawals, tips, or deposits may be held. Step two verification may involve the user/customer being directed to a sub-page where they are required to submit their ID. The user/customer may be asked to take a picture of their ID next to a piece of paper with a randomly generated six-digit number. Only an official ID may be used for ID verification, and the accepted variety of IDs may vary depending on the country. There may also be an electronic check to verify the data provided during step one verification. The electronic check is conducted through two different data banks to ensure the information matches with the provided document and the name on the ID. If the electronic check fails or is not possible, the user/customer may be required to provide confirmation of their current residence, such as a government-issued certificate of registration or a similar document.

Step three verification:

Step three verification may be required for users who deposit over $5,000 (five thousand US Dollars), withdraw over $5,000 (five thousand US Dollars), or send another user over $3,000 (three thousand US Dollars). Until step three verification is completed, withdrawals, tips, or deposits may be held. For step three verification, a user/customer may be asked to provide information on their source of wealth.

Customer identification and verification (KYC) for Duelana Games B.V. (operating online crypto casino Duel at www.duel.win)

Customer identification and verification are crucial elements in compliance with anti-money laundering (AML) regulations and our KYC policy at Duelana Games B.V.

Identification process:

To verify the identity of our users/customers, we require a copy of their passport, ID card, or driving license, along with a handwritten note displaying six randomly generated numbers. Additionally, a second picture of the user/customer's face is required. Users/customers may blur out certain information for privacy, except for date of birth, nationality, gender, first name, second name, and the picture.

Please note that all four corners of the ID must be visible in the same image, and all details must be clearly readable, except for the information mentioned above. We may request additional details if necessary. Our employees may conduct additional checks based on the situation.

Proof of Address:

Proof of address can be verified through electronic checks using two different databases. If the electronic test fails, users/customers have the option to provide proof manually.

Acceptable documents for proof of address include a recent utility bill issued within the last three months, or an official government document that proves the state of residence. To expedite the approval process, please ensure that the document is sent with a clear resolution, where all four corners of the document are visible, and all text is readable. Examples of acceptable documents include electricity bills, water bills, bank statements, or any other governmental correspondence addressed to the user/customer.

Our employees may conduct additional checks if necessary based on the situation.

Source of Funds:

If a player deposits over five thousand euros, we have a process in place to understand the source of wealth (SOW).

Examples of SOW include ownership of a business, employment, inheritance, investment, or family. It is crucial for us to clearly understand the origin and legitimacy of the wealth. If this is not possible, our employees may request additional documents or proof.

The user/customer's account may be frozen if they deposit this amount in one go or through multiple transactions that amount to this. An email will be sent to the user/customer manually to provide the necessary information and documents on our website.

In addition to the above, Duelana Games B.V. may also request a bank wire/credit card to further verify the identity and financial situation of the user/customer.

Basic document for step one:

The basic document for step one verification will be accessible via the setting page on Duel's website (www.duel.win). Every user may be required to fill out the following information:

• First name

• Second name

• Nationality

• Gender

• Date of Birth

The document will be saved and checked by an AI, and our employees may conduct additional checks if necessary based on the situation.

Sanctions, Persons and Entities of Special Interest (PEPs)

To comply with regulations related to money laundering and our KYC policy, we utilize the www.opensanctions.org database for screening open sanctions. This global database contains information on persons and companies of political, criminal, or economic interest, and combines various sanctions lists, databases of politically exposed persons (PEPs), and other public information into a single dataset. It cross-checks leaks and public databases to identify possible conflicts of interests and signs of illicit activity, tracks political conflicts, compares worldwide sanctions policies, and checks potential customers and partners in international dealings. The database includes sanctions lists, lists of politicians, ban lists used in government procurement, lists of known terrorists, and other relevant data sources for journalistic research and due diligence.

In order to streamline the use of this database, Duel has implemented a script on our website, www.duel.win, that incorporates the OpenSanctions search engine. When a user signs up on our website, they may be required to provide their name, address, and email address. Before proceeding to the next stage of checks, the script extracts the user's name and scans it through the OpenSanctions database to ensure that they are not a listed person or entity of special interest. If the results come back negative, the customer may be denied entry to the site, and we may inform the authorities accordingly. This measure helps us comply with AML regulations and mitigate the risk of engaging in transactions with sanctioned individuals or entities.

Risk Management for Duelana Games B.V.:

In order to effectively manage the risks associated with operating an online crypto casino, Duelana Games B.V. has implemented a risk-based approach. Nations around the world are categorized into three regions based on risk levels.

Region One: Low Risk

For nations in Region One, Duelana Games B.V. implements a three-step verification process, as described earlier.

Region Two: Medium Risk

For nations in Region Two, Duelana Games B.V. may implement a three-step verification process with lower deposit, withdrawal, and tip amounts. Step one may be done as usual. Step two may be required after depositing $1,000 (one thousand US Dollars), withdrawing $1,000 (one thousand US Dollars), or tipping another user/customer $500 (five hundred US Dollars). Step three may be required after depositing $2,500 (two thousand five hundred US Dollars), withdrawing $2,500 (two thousand five hundred US Dollars), or tipping another user/customer $1,000 (one thousand US Dollars). Additionally, users from low-risk regions who exchange cryptocurrency with any other currency may be treated similarly to users/customers from medium-risk regions.

Region Three: High Risk

High-risk regions may be banned by Duelana Games B.V. These regions will be regularly updated to keep up with the changing environment of a fast-changing world.

Additional Measures

Duelana Games B.V. utilizes an AI system overseen by the AML compliance officer to detect and report any unusual behavior to employees of the company. Based on a risk-based and experience-based approach, human employees may recheck the results of AI checks or perform additional checks as per the situation. Moreover, a data scientist supported by modern, electronic, analytic systems monitors for unusual behaviors such as depositing and withdrawing without longer betting sessions, attempts to use a different bank account to deposit and withdraw, nationality changes, currency changes, behavior and activity changes, as well as account usage by the original owner.

Additionally, Duelana Games B.V. requires users to use the same method for withdrawals as they used for deposits, for the amount of the initial deposit, to prevent any money laundering.

Enterprise-wide Risk Assessment

As part of its risk-based approach, Duelana Games B.V. has conducted an AML "Enterprise-wide Risk Assessment" (EWRA) to identify and understand risks specific to its business, including the services offered on the website. The AML risk policy is determined after identifying and documenting the inherent risks associated with its business lines and the users to whom services are offered, transactions performed by these users, delivery channels used by the company, geographic locations of operations, customers, and transactions, and other qualitative and emerging risks.

The identification of AML risk categories is based on regulatory requirements, regulatory expectations, and industry guidance, with additional safety measures in place to address the risks associated with the online environment. The EWRA is reassessed annually to ensure the risk management measures remain effective and up-to-date.

Ongoing transaction monitoring

Duelana Games B.V. ensures that an "ongoing transaction monitoring" is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

The First Line of Control:

Duel (www.duel.win) works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent most suspicious deposits from taking place without proper execution of Know Your Customer (KYC) procedures on potential customers.

The Second Line of Control:

Duel (www.duel.win) maintains an aware network to ensure that any contact with the customer, player, or authorized representative triggers due diligence on transactions related to the concerned account. This includes:

• Requests for the execution of financial transactions on the account.

• Requests in relation to means of payment or services on the account.

Additionally, our three-step verification process with adjusted risk management provides all necessary information about all customers of Duel (www.duel.win) at all times. All transactions are overseen by employees who are supervised by the AML compliance officer, who in turn is supervised by the general management. Specific transactions submitted to the customer support manager, possibly through their Compliance Manager, are also subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, considering the customer's KYC information, financial behavior, and transaction counterparty. An automated system conducts these checks, while an employee cross-checks them for additional security.

Transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds are rapidly considered atypical (as they are not directly justifiable). Any staff member of Duel (www.duel.win) must inform the AML division of any atypical transactions they observe and cannot attribute to a known lawful activity or source of income of the customer.

The Third Line of Control:

As a last line of defense against AML, Duel (www.duel.win) conducts manual checks on all suspicious and higher risk users to fully prevent money laundering.

If fraud or money laundering is identified, the authorities will be promptly informed.

Reporting of Suspicious Transactions on Duel (www.duel.win)

In our internal procedures, Duel (www.duel.win) describes in precise terms, for the attention of our staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and based on the information gathered, the AML team:

• Will decide whether it is necessary or not to send a report to the Financial Intelligence Unit (FIU), in accordance with the legal obligations provided in the applicable laws and regulations.

• Will decide whether it is necessary to terminate the business relationship with the customer.

Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the internal website (Intranet site) of Duel (www.duel.win).

Record Keeping

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended, in compliance with applicable laws and regulations.

Records Retention:

Duelana Games B.V. will retain records of all transaction data for a minimum of ten years, starting from the date of the transactions or the termination of the business relationship. These records will be securely stored using encryption technology, both offline and online.

Training:

Duelana Games B.V. has implemented a mandatory AML training program for all employees involved in financial activities, in compliance with the latest regulatory requirements. New employees also receive academic AML learning sessions. The content of the training program is tailored to the specific business operations and roles of the employees, and is conducted by an AML specialist from Duelana Games B.V.'s AML team.

Auditing:

Duelana Games B.V. conducts internal audits on a regular basis to assess and report on its AML activities.

Data Security:

All data provided by users/customers to Duelana Games B.V. is kept secure and will not be sold or disclosed to any third parties, except when required by law or to prevent money laundering, in which case the data may be shared with the relevant AML authorities of the affected jurisdiction. The company adheres to all guidelines and rules of the data protection directive (officially Directive 95/46/EC).

Contact Us:

If you have any questions regarding Duelana Games B.V.'s AML and KYC Policy, please contact us:

• By email: [email protected]