Anti-Money Laundering & Counter-Terrorism Financing Policy

Thrillz by Big Ape SAS

Effective: 09/04/2025

1. Introduction & Purpose

Big Ape SAS ("the Company"), headquartered in France and operating the Thrillz gaming application in the United States, is committed to maintaining a comprehensive, dynamic, and enforceable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) framework. This policy ensures compliance with applicable laws and international best practices, safeguarding both the financial ecosystem and the integrity of our real-money skill-based gaming platform.

This document formalizes our approach to preventing the Thrillz platform from being misused for illicit purposes, including but not limited to money laundering, terrorist financing, and other financial crimes. Our compliance structure adheres to the requirements set forth by:

• The U.S. Office of Foreign Assets Control (OFAC)
• Financial Crimes Enforcement Network (FinCEN)
• Financial Conduct Authority (FCA) and Office of Financial Sanctions Implementation (OFSI) in the UK
• Recommendations from the Financial Action Task Force (FATF) and other global regulatory bodies

Thrillz is built on the core principles of transparency, accountability, and user protection, and this policy reflects those values in actionable, enforceable procedures.

2. Scope

This AML/CTF Policy applies comprehensively across our organization, including all Thrillz employees, contractors, consultants, advisors, platform partners, affiliates, and third-party payment processors. It governs every aspect of interaction with the platform, from user onboarding to payout disbursements, and encompasses the following areas:

• User Verification: Mandatory Know Your Customer (KYC) and identity verification procedures
• Transactions: Monitoring of deposits, withdrawals, in-app purchases, and prize winnings
• Sanctions Checks: Screening users against global watchlists
• Data Retention: Maintenance of AML-relevant records in compliance with regulatory timelines
• Training and Reporting: Regular staff training and reporting protocols for suspicious activity