WEEZY VENTURES LTD

1. Company Business Model

Weezy Ventures Ltd ("Weezy" or the "Company") is a company incorporated under Anjouan Law and established in 2024. Weezy operates the online casino www.weezybet.com under the Certificate of Operation (Application no. ALSI-202412019-FI1) issued by the Gaming Board of Anjouan at Mutsamudu.

In addition to our core gaming services, Weezy has integrated advanced technology platforms designed to enhance fraud detection and AML/CFT compliance. These include:

• Artificial Intelligence (AI) and Machine Learning Tools: To detect unusual patterns in gameplay and transactions.
• Blockchain Analytics: For monitoring cryptocurrency transactions and tracing the flow of funds.
• Automated Fraud Detection Systems: Integrating real-time data analytics for rapid identification of irregular activities.

Our diverse product portfolio—including online casino games (slots, table games), sports betting, and interactive gaming platforms—presents varying risk profiles. Consequently, we employ product-specific controls and protocols to mitigate risks associated with each service.

2. Company Policy Statement

Weezy Ventures Ltd. ("WeezyBet" or the "Company") is committed to upholding the highest standards in anti-money laundering (AML) and counter-terrorist financing (CFT) compliance. Recognizing the inherent risks associated with online gaming and financial transactions, WeezyBet adopts a proactive, risk-based approach to prevent, detect, and report illicit activities.

Key Commitments Include:

Employee Obligations: All employees are mandated to adhere to AML/CFT protocols, report any suspicious activity immediately, and participate in regular training sessions. Internal procedures require that employees document any concerns and escalate them promptly to the Compliance Officer.

Alignment with Global Standards: Our AML/CFT program is designed in accordance with the Anti-Money Laundering Act of the Comoros, the regulations of the Anjouan Gaming Control Board, and international best practices as set by the Financial Action Task Force (FATF), EU AML directives, and other relevant bodies.

Comprehensive Controls: Our program includes robust customer due diligence, real-time transaction monitoring, sanctions compliance, proactive risk management, and continuous internal auditing.

The Company is dedicated to a culture of compliance, ensuring that every business decision reflects our commitment to ethical conduct and regulatory adherence.

3. Definitions

For clarity, the following key terms are defined as used in this manual:

Anti-Money Laundering (AML): A set of procedures, laws, and regulations designed to prevent, detect, and report money laundering activities.

Counter-Terrorist Financing (CFT): Measures aimed at preventing the financing of terrorist activities.

Blockchain Analytics: The analysis of data on a blockchain to identify suspicious transactions, trace fund origins, and detect potentially illicit activity.

Compliance Officer: The designated individual responsible for managing and overseeing WeezyBet's AML/CFT program, including policy development, risk assessments, and staff training.

Cryptocurrency: A digital or virtual currency that uses cryptographic techniques for secure transactions and operates independently of central banks.

Customer Due Diligence (CDD): The process of identifying and verifying customer identities, assessing their risk profiles, and continuously monitoring their activities.

Enhanced Due Diligence (EDD): Additional measures implemented for high-risk customers to scrutinize their source of funds and overall risk profile more closely.

Financial Action Task Force (FATF): An intergovernmental organization that develops international standards to combat money laundering and terrorist financing.

High-Risk Customer: A customer whose geographic location, transactional behavior, or source of funds indicates a heightened risk of money laundering or terrorist financing.

Know Your Customer (KYC): Processes that ensure customer identities are verified and their activities are understood and monitored to prevent financial crime.

Money Laundering: The process of disguising illegally obtained funds as legitimate through a series of complex transactions.

Politically Exposed Person (PEP): An individual in a prominent public role, or a close associate or family member of such a person, who may present an elevated risk of corruption.

Prohibited Jurisdiction: A country or territory where our services are not offered due to international sanctions or legal restrictions.

Sanctions: Legal restrictions or penalties imposed by governments or international bodies aimed at preventing transactions with targeted individuals, entities, or countries.

Suspicious Activity: Any activity or transaction that deviates from normal patterns and may indicate money laundering, terrorist financing, or other illicit conduct.

Suspicious Activity Report (SAR): A confidential report filed with relevant authorities when suspicious activity is detected.

Terrorist Financing: The provision of financial support to individuals or groups engaged in terrorist activities.

Transaction Monitoring: The continuous oversight of customer transactions to detect patterns or behaviors that may indicate illicit activity.

Layering: A process in money laundering involving a series of transactions aimed at obscuring the source of funds.

Shell Companies: Legal entities that may be used to disguise ownership of funds and conceal illicit activities.

4. Governance and Oversight

WeezyBet has established a robust governance framework to ensure effective oversight of its AML/CFT program. This framework clarifies the roles and responsibilities of key personnel and departments, ensuring the integration of compliance into all aspects of our operations.

Board of Directors:

Oversight Responsibilities: The Board is ultimately responsible for approving and regularly reviewing the AML/CFT policies, risk management frameworks, and internal controls.

Resource Allocation: Ensures that the compliance function is appropriately staffed, and necessary technological and financial resources are allocated.

Performance Monitoring: Regularly reviews key performance indicators (KPIs), audit reports, and independent reviews to gauge the effectiveness of the AML/CFT program.

Board Training: Board members receive periodic AML/CFT training to remain informed on regulatory changes and emerging risks.

Compliance Officer and Team:

Policy Development: Drafts and maintains up-to-date policies and procedures in line with evolving regulatory requirements.

Risk Assessment: Conducts comprehensive and periodic risk assessments, incorporating changes in customer behavior, product offerings, and external risk factors.

Training & Awareness: Develops and oversees regular AML/CFT training for all employees.

Monitoring & Reporting: Implements and supervises transaction monitoring systems, investigates flagged activities, and prepares SARs as needed.

Advisory Role: Acts as the primary advisor to the Board and senior management on AML/CFT matters.

Internal Audit:

Independent Reviews: The Internal Audit Department conducts regular and ad-hoc audits to ensure compliance with internal policies and regulatory requirements.

Corrective Actions: Identifies deficiencies and works with the Compliance Officer to implement timely corrective measures.

5. Risk Assessment

A thorough risk assessment is integral to WeezyBet's AML/CFT program. This process involves the identification, evaluation, and prioritization of risks inherent in our operations.

Inherent Risk Identification:

Customer Base: We cater to both casual players and high-rollers, excluding individuals from jurisdictions identified as high-risk or subject to sanctions.

Product Risks: Each gaming product—whether online casino games or sports betting—carries unique risk profiles. For example, low-odds games may be exploited to obscure illicit funds, whereas sports betting may be vulnerable to matched betting schemes.

Payment Methods: Our acceptance of various payment methods, including credit cards, e-wallets, and cryptocurrencies (particularly privacy coins), requires differentiated due diligence measures.

Risk Assessment and Scoring:

We use a structured risk matrix to assess risks on two dimensions: likelihood and impact. For example:

Risk Factor Likelihood Impact Risk Level

High-roller customers: Likelihood: (M) Impact:(H) Risk: (H)

Customers from high-risk countries: Likelihood: (L) Impact:(H) Risk: (M)

Cryptocurrency transactions above [amount]: Likelihood: (M) Impact:(M) Risk: (M)

Third-party payment processor vulnerabilities: Likelihood: (L) Impact:(H) Risk: (M)

Note: This matrix is reviewed and updated regularly, and third-party/vendor risks are incorporated into our overall risk assessment.

Control and Mitigation Measures:

Enhanced Due Diligence: Implement EDD measures for high-risk customers, including source of funds verification and biometric identity checks.

Transaction Limits: Enforce deposit and withdrawal thresholds to prevent large-scale laundering schemes.

Periodic Reviews: Conduct regular reviews of high-risk customer accounts and adjust risk profiles as necessary.

Third-Party Management: Assess and monitor the AML/CFT practices of vendors and payment processors.

Independent Audits: Engage both internal and external auditors to verify the efficacy of controls.

Dynamic Review:

This risk assessment is revisited at least annually, or when there are significant changes in operations, customer profiles, or regulatory requirements.

6. Customer Due Diligence (CDD)

WeezyBet is committed to implementing robust CDD procedures to understand our customers and the nature of their transactions thoroughly.

Initial Onboarding: Upon registration, all customers must provide verifiable information including:

Full legal name
Date of birth
Residential address
Nationality
Government-issued identification (e.g., passport, driver's license)

Verification Methods:

Automated Verification: Utilizing Monotech KYC software for document verification, facial recognition, and address checks.
Manual Review: Conducted by our Compliance team for flagged cases or high-risk profiles.
Sanctions Screening: All customer identities are screened against recognized sanctions lists (e.g., OFAC, UN, EU).

Risk-Based Approach:

Customer Segmentation: Customers are categorized into three tiers:

Simplified Due Diligence: For low-risk customers.
Standard Due Diligence: For the majority, involving comprehensive identity verification and monitoring.
Enhanced Due Diligence: For high-risk profiles, which may include detailed source of funds checks and biometric verification.

Ongoing Monitoring: Customer profiles are reviewed periodically, particularly if there are significant changes (e.g., large transactions, relocation, adverse news).

Record Retention:

Detailed records of all CDD activities are maintained and stored securely for a minimum of five years, in accordance with applicable legal requirements.

7. Transaction Monitoring

Effective transaction monitoring is critical to detecting suspicious activity and mitigating risks associated with money laundering and terrorist financing.

Monitoring Mechanisms:

Automated Systems: Our transaction monitoring software automatically scans and evaluates transactions in real-time based on:

- Transaction size and frequency
- Deviations from established customer patterns
- Specific triggers, such as rapid deposits and withdrawals

Manual Oversight: The Compliance team reviews alerts generated by the system, performing an in-depth analysis of:

- Customer KYC data
- Historical transaction patterns
- Supplementary data including blockchain analytics for cryptocurrency transactions

Specific Procedures for Cryptocurrency:

Blockchain Analytics Tools: Used to trace the source and flow of funds, identify high-risk wallet addresses, and detect unusual transaction patterns.

Enhanced Verification: High-value or privacy coin transactions trigger enhanced due diligence procedures.

Escalation Process:

Investigation: If an alert is triggered, the Compliance team initiates a structured investigation that may involve:
- Contacting the customer for clarification
- Gathering additional information or documentation
- Consulting with law enforcement or external experts, if necessary

Reporting: Confirmed suspicious activities are documented and a Suspicious Activity Report (SAR) is promptly filed with the relevant authorities in Anjouan.

8. Sanctions Compliance

WeezyBet is fully committed to complying with all applicable sanctions laws and regulations to prevent its services from being exploited for illicit activities.

Key Procedures:

Customer and Transaction Screening: All new and existing customers, as well as transactions, are screened against current sanctions lists (e.g., OFAC, UN, EU).

Prohibited Jurisdictions: A regularly updated list of prohibited and high-risk jurisdictions is maintained. Customers from these regions undergo enhanced due diligence or are restricted from accessing our services.

False Positives Management: In cases of potential false positives, manual reviews are conducted to confirm matches before any action is taken.

Immediate Actions: Should a customer or transaction be flagged:
- The account is immediately frozen or restricted.
- A detailed investigation is initiated.
- The incident is reported to the relevant authorities following internal protocols.

9. Education and Training

WeezyBet recognizes that a knowledgeable workforce is central to the success of our AML/CFT program. Our training strategy is designed to ensure every employee understands their responsibilities and the regulatory environment.

Training Program Components:

Mandatory Training:
Onboarding: New hires receive comprehensive AML/CFT training during the onboarding process.
Refresher Courses: Annual refresher courses, with additional training sessions when regulations Training Methods:
- Online Modules and Webinars
- In-Person Workshops
- Case Studies and Simulated Scenarios
Assessment and Certification: Post-training assessments and feedback surveys are used to evaluate employee comprehension. Records of training outcomes are maintained for compliance reviews.
Specialized Training: Key personnel (e.g., Compliance Officers, risk management teams) receive advanced training tailored to their roles.

10. Reporting

WeezyBet maintains strict reporting procedures to ensure all suspicious activities are promptly and effectively escalated and reported to the appropriate authorities.

Reporting Protocols:

Identification of Red Flags: Employees are trained to recognize key indicators of suspicious behavior, such as unusual transaction sizes, rapid account activity changes, or discrepancies in customer information.

Internal Reporting Procedures: Employees must immediately notify the Compliance Officer via a designated internal reporting channel. A standardized internal report form is used to document the incident, including: - Date and time of the activity
- Nature of the suspicious activity
- Customer details and transaction history
- Any actions taken or communications made

Suspicious Activity Reports (SARs): Upon confirmation of suspicious activity following an internal investigation, a SAR is prepared and submitted confidentially to the Anjouan Gaming Control Board or other relevant authority within prescribed timeframes.

11. Record Keeping

WeezyBet is committed to maintaining detailed and secure records as part of its AML/CFT program.

Types of Records:
- Customer identification and verification documents
- Transaction logs and monitoring data
- Suspicious Activity Reports (SARs) and internal investigation files
- Audit reports and training records

Security and Confidentiality: All records are stored in secure systems with restricted access, ensuring data confidentiality and integrity. Electronic records are encrypted and subject to regular backups.

Retention Period: Records are retained for a minimum of five years in compliance with legal requirements, with provisions for secure disposal once retention periods expire.

Compliance with Data Protection: Our record-keeping practices are aligned with applicable data protection laws and regulations, such as GDPR where applicable, ensuring that personal data is handled with the highest standards of privacy.