Anti-Money Laundering, Anti-Terrorist Financing Statement

Company Business Model

Dogeladder (“Dogeladder” or the “Company”) is a company incorporated under Curaçao Law under the registration number 145203 and operates the website www.dogeladder.com under the licence n.º 1668/JAZ. Dogeladder presently supports users in more than 230 countries globally.

As part of its global operations, Dogeladder has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

Company Policy Statement

Dogeladder is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (“AML/CFT”) applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, Dogeladder expressly prohibits and rejects the use of Dogeladder products for any form of illicit activity, including money laundering, terrorist financing, or trade sanctions violations, consistent with various national anti-money laundering (“AML”) laws, regulations, and norms. Dogeladder continues to monitor norm-setting parameters promulgated by the Financial Action Task Force (“FATF”) and certain gaming trade groups in addition to the Curaçao Gaming Control Board and will take necessary action as it deems appropriate to reflect changes in law.

Dogeladder’s intention is to follow global best practices in guarding against Dogeladder products being used to facilitate such activities. Those best practices include:

• • Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing, and trade sanctions violations;
• • Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures, and controls;
• • Provision of related education and training to relevant personnel; and
• • Independent reviews, monitoring, and maintenance of the policy, procedures, and controls.

Definitions

The following defined terms are widely used in the industry:

Money Laundering:

The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering, and integration.

• Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.
• Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds, or purchasing assets.
• Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity:

Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions:

Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions. For example, they are used:

• • To encourage a change in behavior for a target country or regime;
• • To apply pressure on a target country to comply with set objectives;
• • As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or
• • To prevent and suppress the financing of terrorists or terrorist acts.

Governance and Oversight

Dogeladder has appointed a Chief Compliance Officer (“CCO”) that is responsible for coordinating the implementation of the AML Policy and policy program. The Chief Compliance Officer’s duties also include developing AML initiatives, working with other Dogeladder stakeholders to revise the AML policy, assessing new regulatory requirements, and investigating potentially suspicious or unusual activity. Dogeladder also provides AML training to all of its employees on a regular basis.

Know Your Customer and Transaction Monitoring

Dogeladder will apply appropriate user due diligence and ongoing monitoring measures required by law. Dogeladder will endeavor to prevent users from engaging in illicit or otherwise unauthorized activity. Dogeladder uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure compliance with applicable law.

Know Your Customer

Customer Due Diligence

Dogeladder has adopted a risk-based CDD to enable Dogeladder to understand the nature and purpose of the user relationship to the Dogeladder platform in order to develop a customer risk profile. In order to do so, Dogeladder collects certain documentary and non-documentary information at account opening commensurate with the nature of the type of account and services that Dogeladder offers. Dogeladder maintains different CDD for different accounts and services.

For instance, the CDD requires users to go through Dogeladder’s customer identification program (“CIP”). The CIP consists of procedures for:

• • Collecting baseline (e.g., wallet address, email address) information at account creation through Dogeladder’s user onboarding portal;
• • Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user’s account;
• • Maintaining records of the information used to identify the user; and
• • Determining if a user appears on any list of known or suspected terrorists or terrorist organizations provided to financial institutions based on the above information.

Identity and Age Verification

A third-party service provider will support Dogeladder’s ability to determine the legitimacy of the identification information or other KYC materials provided and will confirm that the user is permissible. The service provider also will confirm that the user does not appear to be located in a comprehensively sanctioned or otherwise prohibited jurisdiction and will search global sanctions lists to confirm that the user does not appear thereon using onboarding information such as wallet addresses.

Customer Information

Dogeladder will collect details on each user to form a reasonable belief that Dogeladder knows the identity of its users commensurate with the user’s risk profile. For instance, Dogeladder may collect such details as the wallet address, name, address, country, date of birth, or postal code (collectively, “KYC Information”). Dogeladder will collect any of the above KYC Information prior to issuing a Dogeladder funding address (e.g., QR code) to users. Dogeladder does not presently allow users who are non-natural persons. Dogeladder may, at its own discretion, rely on the performance by another institution of some or all of the elements of our CIP.

Geo-blocking for Prohibited Jurisdictions

Dogeladder will require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.

Geo-blocking for Sanctioned Jurisdictions

Dogeladder also will require contractual client certifications that such users are not subject to United States, European Union, or other global sanctions or watchlists, including individuals or entities associated with the United States’ comprehensively sanctioned jurisdictions, Iran, Cuba, North Korea, Syria, and the Crimean region of Ukraine. Dogeladder will rely on various risk-based measures to verify these representations, including the below-described know-your-user (“KYC”) measures and through IP address-based geo-blocking.

Enhanced Due Diligence and Ongoing Monitoring

Dogeladder performs ongoing monitoring on its users in order to detect any behaviors or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, Dogeladder has implemented a set of red flag indicators that help it determine such behaviors and require further action from Dogeladder in assessing the customer information.

Whenever one of those red flags is triggered, the user account will be suspended, and Dogeladder will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limited to, the provision of:

• 1. Full legal name;
• 2. Country of citizenship;
• 3. Permanent address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office, or other physical location);
• 4. Identification number (either a taxpayer identification number, or, if unavailable, a passport number and country of issuance, alien identification card number, or number and country of issuance of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);
• 5. Identification document; and
• 6. Source of funds and source of wealth.

Dogeladder may use third-party service providers to verify any of the above information as determined to establish a reasonable basis to know the true identity of the user where the user’s activity warrants such action.

Acceptance Policy

Dogeladder will not accept and will block the users that:

• 1. Do not provide the identification information requested by Dogeladder;
• 2. Provide fake identification documents;
• 3. Try to use different means to deceive about their location;
• 4. Are from restricted or prohibited jurisdictions;
• 5. Are subjected to United States, European Union, or other global sanctions or watchlists;
• 6. Are gambling addicted or have mental health issues;
• 7. Whose source of funds originates from restricted jurisdictions.

Dogeladder reserves the right to block and suspend players for any other reasons at its own discretion.

Transaction Monitoring

Dogeladder is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose, Dogeladder established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring.

Dogeladder will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review user history and patterns of activity to detect and report any unusual activity as required and to develop and implement any additional controls or limits in its platform.

Dogeladder implemented procedures addressing the following two key components of unusual or suspicious activity management:

• • Identification of unusual activity through methods of identification may include employee and customer identification, law enforcement inquiries, other referrals, or transaction and surveillance monitoring system reports; and
• • Alert management that focuses on processes used to investigate, evaluate, and document identified unusual or potentially suspicious activity.

Transaction Monitoring for Sanctioned or Prohibited Jurisdictions

Dogeladder may in its reasonable discretion impose certain due diligence requests at user balance withdrawal. Dogeladder presently conducts a mixture of manual and automated transaction monitoring processes to identify “red flag” behavior. Where such red flag behavior is identified, Dogeladder may refuse to process any withdrawal attempts or collect additional information from the recipient. Dogeladder will further endeavor to limit any attempted user account funding from prohibited jurisdictions (which are identified in the Dogeladder user-facing disclosures and updated from time to time internally) where the associated wallet address indicates that the user or the user’s funds are located in such a prohibited jurisdiction. For instance, Dogeladder may prohibit a user from funding their Dogeladder account using a known U.S.-based exchange wallet as such assets indicate that the user is a U.S. person. Users will have the ability to rebut any suspension with additional information as part of Dogeladder’s ongoing transaction monitoring and user due diligence standards.

Screening for Sanctioned Parties

Prior to issuing a Dogeladder funding address to a user, Dogeladder will screen a user’s wallet address against applicable sanctions databases. Such screening measures will rely on third-party blockchain forensics vendors such as Chainalysis. Dogeladder will periodically rescreen wallet addresses against such databases.

Identification of Unusual Activity

Dogeladder will monitor account activity for unusual size, volume, pattern, or type of transactions, taking into account risk factors and red flags that are appropriate to its business. Monitoring will be conducted by running regular reports of unusual, high-risk, or suspicious user activity.

Anti-Mixing Measures

Dogeladder will utilize software designed to detect other suspicious deposit or withdrawal patterns. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform.

Chainalysis Review

Every single crypto deposit or withdrawal, both indirect and direct, will run through Chainalysis and be reviewed for signs of fraud or suspicious behavior. A user’s account will be suspended and reviewed upon alert of potential illicit behavior. Sufficient proof of wealth may be requested from high-risk accounts. Dogeladder may refuse to withdraw to certain “high-risk” addresses as determined in consultation with Chainalysis risk scoring.

Withdrawal Threshold KYC

Additionally, and independently, every account, wherever or with whomever associated, will be suspended until adequate KYC diligence occurs once that account reaches a withdrawal threshold dependent on the account’s risk characterization over the life of the account.

Other Ongoing Monitoring Controls

In addition to the above-mentioned controlling procedures, Dogeladder has also implemented the following procedures to complement its know-your-customer and ongoing monitoring procedures:

• Ban Evasion Detection: Dogeladder will utilize third-party service provider software designed to detect the use by one user of multiple accounts. This software relies on detecting links between the same devices used to access multiple accounts. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform.
• Time Zone Monitoring: Dogeladder has implemented time zone controls that detect the user’s device information and cross-check it with restricted jurisdictions to understand if they are using geo-location software to hide their jurisdiction.
• Products and Services Review: Dogeladder will establish additional procedures to avoid facilitating user attempts to exploit the Dogeladder platform. Dogeladder has a robust set of user-facing terms that users attest to in order to utilize the Dogeladder platform. Dogeladder will establish certain additional safeguards to mitigate against the risk of misuse. For instance, Dogeladder may establish policies or procedures for limiting which user assets can be onboarded to the Dogeladder platform. Dogeladder lists the assets that are available for use on the platform. Dogeladder does not allow the use of anonymity-enhancing technologies such as mixers, tumblers, or certain coins and tokens. Where Dogeladder becomes aware that an anonymity-enhancing technology is being used on the Dogeladder platform, Dogeladder will disallow such use.
• Vendor Management: Dogeladder works with reputable third-party service providers as part of its compliance infrastructure. Dogeladder will periodically assess the strength of its key third-party service providers to determine if additional services are needed, the third-party service provider is not performing consistent with its contractual obligations, or if other remedial action is necessary for Dogeladder to comply with this policy. Dogeladder may request information from any third-party service provider as part of its vendor review process.
• Compliance Innovation: In addition to vendor management, Dogeladder will continuously monitor any non-documentary compliance mechanisms to determine their viability for the Dogeladder program. Dogeladder may run test or trial programs on a limited basis with such compliance vendors to determine the effectiveness of such programs. Blockchain native compliance tools include fraud prevention services, on-chain KYC providers, and other tools designed to reflect the technological features associated with blockchain platforms.

Education and Training

Dogeladder, with the assistance of its legal counsel and under the oversight of its CCO, may provide employees with AML, anti-terrorist financing, and trade sanctions compliance training on a periodic basis, as deemed appropriate.

Reporting

Dogeladder is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers identified as being on a sanctions list, linked to money laundering, terrorism financing, or other criminal activities will be reported as suspicious activity to the regulator.

Coin Mixing Policy

Primedice has a strict anti coin mixing policy. This is in accordance with our AML procedures outlined in our terms of service.

If deposits & withdrawals are suspected of being attempts to mix coins we reserve the right to hold withdrawals until completion of one of the following procedures

• Withdrawal is refunded to the address in which the deposit was made from
• Withdrawal is sent after full completion of account verification & KYC
• Withdrawal refunded & sufficient gameplay is reached

Dogeladder will always try to ensure every matter is resolved & the above can be modified to suit specific situations.