Anti-Money Laundering & Know Your Customer Policy

This policy applies to all users of the Eternel Games platform (“Platform”) and all services operated by Eternel Games Ltd (“Operating Entity”). Our AML/KYC program is designed in accordance with:

• The UK Proceeds of Crime Act 2002 (POCA)
• The UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
• EU Anti-Money Laundering Directives (where applicable to EU users)
• US Bank Secrecy Act (BSA) and FinCEN regulations (where applicable to US users)

Eternel Games Ltd, as the Operating Entity, is responsible for implementing and maintaining these procedures.

We apply a risk-based approach to customer due diligence, assigning risk levels based on multiple factors:

Provider-backed sanctions screening is a release prerequisite for withdrawals and is not represented as active until that integration is configured. The selected provider must support the applicable lists, which may include:

• UK HM Treasury sanctions list
• EU consolidated sanctions list
• US OFAC Specially Designated Nationals (SDN) list
• UN Security Council sanctions list

The timing, geographic coverage, match-review process, and any reporting obligations will be documented when the provider is selected. The Platform may suspend paid features while a lawful compliance review is pending.

We maintain a complete balance, transaction, settlement, and accounting audit trail. Operational review may consider:

• Deposit-withdrawal patterns — Flagging accounts that deposit and withdraw with minimal gameplay activity
• Velocity checks — Detecting unusual frequency or volume of transactions
• Threshold and pattern review — Reviewing transactions that may be structured to avoid product or provider limits
• Payment review — Reviewing hosted checkout events, chargeback indicators, and payout details for sanctions, fraud, and misuse signals

All transactions are recorded with a full audit trail, including timestamps, amounts, transaction type, and resulting balance. This audit trail is maintained in the Platform’s transaction ledger.

Where we identify or suspect money laundering, terrorist financing, or other financial crime, we will:

• File a Suspicious Activity Report (SAR) with the UK National Crime Agency (NCA) as required under POCA
• File a Suspicious Transaction Report (STR) with relevant authorities in other jurisdictions where required
• Freeze or suspend the account pending investigation, without prior notice to the player
• Cooperate with law enforcement and regulatory authorities

Under UK law, we are prohibited from informing a player that a SAR has been filed or that their account is under investigation for suspected financial crime (“tipping off” offence under POCA s.333A).

In accordance with MLR 2017 and applicable AML regulations, we retain:

• Future KYC records — Retained only if and when collected, for the period required by applicable law and the disclosed provider arrangement
• Transaction records — Complete financial transaction history for a minimum of 5 years after the transaction date
• Risk assessments — Customer risk profiles and due diligence records for a minimum of 5 years
• Correspondence — All compliance-related communications for a minimum of 5 years

Records may be retained for longer periods where required by law or where ongoing legal proceedings or regulatory investigations necessitate retention.

By using the Platform, you agree to:

• Provide accurate and truthful information during registration and any future verification process
• Promptly provide additional documentation when requested for due diligence purposes
• Not use the Platform for money laundering, terrorist financing, or any other illicit purpose
• Not allow any third party to use your account or deposit funds on your behalf
• Notify us immediately if you become aware of any suspicious activity involving your account

Failure to comply with these obligations may result in account suspension, termination, and forfeiture of account balance in accordance with our Terms of Service.

For questions about our AML/KYC procedures, contact us at [email protected]. Do not email identity documents; a secure provider flow will be supplied if verification becomes necessary.

For compliance and regulatory inquiries: [email protected].