AML Policy

1. Introduction

In order to continue its goal to provide a safe environment for players on its system, BIG APE (”Thrillz”) crafted this Anti-Money Laundering and Counter-Terrorism Policy (”AML/CTF Policy”).

This AML/CTF Policy is designed to comply with the applicable laws and regulations of Thrillz Eligible Jurisdictions and to support the implementation of a risk-based approach to anti-money laundering (”AML”) and counter-terrorism financing (”CTF”) activities within our organization.

Thrillz operates with Know Your Customer (”KYC”) providers and Payment Service Providers (collectively, the “Providers”) that are regulated entities and also comply with the applicable laws and regulations of Thrillz Eligible Jurisdictions.

2. Scope

This policy applies to all personnel, including employees, contractors, consultants, and other third parties, who are involved in AML/CTF activities. In particular, are targeted Thrillz employees involved with payments, fraud, customer support, and compliance.

3. Risk-Based Approach

Our organization is committed to implementing a risk-based approach to AML/CTF activities. Thrillz will identify, assess, and manage the AML/CTF risks associated with our activities, products, services, customers, customers’ transactions, and geographic locations.

4. Risk Assessment

Thrillz will conduct periodic risk assessments to identify, assess, and manage the AML/CTF risks associated with our activities and transactions. The risk assessment will consider the following factors:

• The products and services offered by our organization;
• The customers Thrillz serves;
• The frequency, size, and complexity of customer transactions;
• The geographic locations of our customers;
• The jurisdictions in which Thrillz operates;
• The risk of money laundering or terrorism financing associated with specific customers or groups of customers;
• The flow of funds into and out of Thrillz organization;
• Our organizational structure;
• The effectiveness of our internal controls; and