Anti-Money Laundering (AML) Policy

1) Purpose & Scope

This Anti-Money Laundering Policy ("Policy") describes how Axis Platforms, Inc. works to prevent the Platform from being used for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime. It covers:

• The controls Axis applies to its own business, including the due diligence we perform on Operators.
• The minimum anti-money laundering standards every Operator must meet.
• How Axis monitors for, escalates, and acts on concerns.

This Policy applies to all Axis Personnel and to every Operator and Operator Platform. It supplements our Terms of Service, which require Operators to comply with anti-money laundering, identity verification, and sanctions laws.

2) Definitions

• Company, Axis, we, us: Axis Platforms, Inc.
• Platform: The software, templates, dashboards, APIs, and infrastructure Axis provides to Operators.
• Operator: A business that uses the Platform to launch and run an Operator Platform (a "Customer" under our Terms of Service).
• Operator Platform: An online gaming, betting, prediction-market, or related site or application that an Operator runs using the Platform.
• End User: A player, customer, or visitor of an Operator Platform.
• Personnel: Axis employees, contractors, and anyone else acting on Axis's behalf.
• Money Laundering: Concealing or disguising the origin of the proceeds of crime so that they appear to come from a legitimate source.
• Terrorist Financing: Providing or collecting funds, from any source, for use by terrorists or terrorist organizations.
• Sanctions: Economic and trade restrictions imposed by governments and international bodies, including those administered by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC").
• Customer Due Diligence: Identifying and verifying a customer, understanding the nature and purpose of the relationship, and monitoring it on an ongoing basis.
• Enhanced Due Diligence: Additional checks applied to higher-risk customers or activity.
• Beneficial Owner: Any individual who directly or indirectly owns 25% or more of a business, or who otherwise exercises significant control over it.
• Politically Exposed Person: An individual who holds or has held a prominent public position, and that individual's immediate family members and close associates.
• Suspicious Activity: Activity that gives reasonable grounds to suspect a connection to money laundering, terrorist financing, sanctions evasion, fraud, or other crime.

3) Our Role

• Technology Provider Only: Axis provides the software Operators use to run their Operator Platforms. Axis does not accept wagers, is not a party to any game, bet, or market position, and is not the house under any circumstances.
• Operator Responsibility: End User funds, deposits, withdrawals, and payouts are the responsibility of the Operator. Each Operator is responsible for its own anti-money laundering program, including End User due diligence, transaction monitoring, sanctions screening, record keeping, and reporting to the authorities in its jurisdictions.
• Axis Controls: Axis applies the controls in this Policy to decide which Operators may use the Platform, to protect the Platform from misuse, and to act on concerns we identify.
• Axis Review: Axis may review transactions, payouts, games, and markets on any Operator Platform. Any review is at Axis's discretion, is not an approval, and does not transfer responsibility from the Operator to Axis.

4) Legal Framework

Axis designs its program with reference to recognized anti-money laundering and sanctions standards, including:

• The U.S. Bank Secrecy Act and the USA PATRIOT Act, to the extent applicable.
• Sanctions administered by OFAC, and applicable sanctions of the United Nations, the European Union, and the United Kingdom.
• The Recommendations of the Financial Action Task Force ("FATF").

Each Operator must comply with the anti-money laundering and sanctions laws of every jurisdiction in which it is licensed or operates, including any requirements specific to gambling and virtual assets.

5) Governance

• AML Compliance Officer: Axis designates an AML Compliance Officer with the authority and resources needed to oversee this Policy. The AML Compliance Officer reports to Axis leadership.
• Leadership Oversight: Axis leadership approves this Policy and receives regular reports on financial crime risks, Operator reviews, and significant cases.
• Risk Assessment: Axis assesses the money laundering, terrorist financing, and sanctions risks of its business at least annually, and before launching new products, payment integrations, or markets.
• Review: This Policy and its controls are reviewed at least annually, including by independent reviewers where appropriate.

6) Risk-Based Approach

Axis applies more scrutiny where risk is higher. When assessing an Operator, Axis considers factors including:

• The jurisdictions where the Operator is organized, licensed, and offers its services, including jurisdictions identified by FATF as having strategic anti-money laundering deficiencies.
• The Operator's licensing status and regulatory history.
• The complexity and transparency of its ownership structure.
• The products it offers, such as casino games or prediction markets.
• The payment methods it accepts, including virtual assets.
• Its expected transaction volumes and End User base.
• Any adverse media, sanctions exposure, or involvement of Politically Exposed Persons.

Each Operator is assigned a risk rating of low, medium, or high, which sets the depth of its due diligence and how often it is reviewed.

7) Operator Due Diligence

Before an Operator Platform is enabled for real-money activity, Axis performs due diligence on the Operator, including:

• Business Identity: Legal name, registration number, registered address, tax identification number, and formation documents.
• Ownership & Control: Identifying each Beneficial Owner, director, and senior manager, and verifying their identities.
• Licensing: Confirming the licenses the Operator holds, and checking them against the regulator's public register where one exists.
• Screening: Screening the Operator, its Beneficial Owners, and its directors against sanctions lists, Politically Exposed Person databases, and adverse media.
• Operations: Understanding the Operator's intended jurisdictions, products, payment providers, and expected volumes.
• Compliance Program: Reviewing the Operator's own anti-money laundering and responsible gaming policies.

Enhanced Due Diligence applies to high-risk Operators, such as those involving a Politically Exposed Person, connected to a higher-risk jurisdiction, with a complex ownership structure, or relying heavily on virtual assets. It may include verifying source of funds and source of wealth, obtaining additional documents, and requiring senior management approval before onboarding.

Axis will not onboard, or will stop working with, an Operator that:

• Is a sanctioned person, is owned or controlled by one, or is located in a comprehensively sanctioned country or region.
• Cannot or will not provide the information needed to complete due diligence, or provides false or misleading information.
• Uses or intends to use the Platform for unlawful gambling or any other unlawful activity.
• Presents a level of risk that Axis cannot adequately manage.

Ongoing Due Diligence: Operator information and screening are refreshed at least annually for high-risk Operators, every 2 years for medium-risk Operators, and every 3 years for low-risk Operators, and whenever Axis learns of a material change.

8) Operator AML Standards

Every Operator must, at a minimum:

• AML Program: Maintain a written anti-money laundering program suited to its licenses, jurisdictions, products, and risks, and appoint a qualified person to be responsible for it.
• End User Due Diligence: Verify the identity and age of each End User before the End User withdraws funds, when the End User's transactions reach the thresholds set by its licenses or applicable law (and in any case at USD 3,000 or its equivalent, in line with FATF standards for casinos), and whenever money laundering is suspected or earlier identity information is in doubt.
• Enhanced Due Diligence: Apply Enhanced Due Diligence to higher-risk End Users, including Politically Exposed Persons, End Users connected to higher-risk jurisdictions, and End Users with unusually large or unexplained activity, including verifying source of funds or source of wealth where appropriate.
• Sanctions Screening: Screen End Users against applicable sanctions lists at registration and on an ongoing basis, and block access from comprehensively sanctioned countries and regions.
• Transaction Monitoring: Monitor deposits, wagers, market positions, and withdrawals for Suspicious Activity, using the Platform's fraud and risk tools or its own systems.
• Payment Controls: Accept funds only from payment methods in the End User's own name, and return withdrawals to the method used to deposit wherever possible.
• Reporting: Report Suspicious Activity to the appropriate authorities as required by law, and never tip off an End User that a report has been made or an investigation is underway.
• Virtual Assets: Where virtual assets are accepted, screen wallet addresses and transactions using blockchain analytics, refuse funds linked to sanctioned addresses, mixers, or illicit activity, and comply with applicable travel rule requirements.
• Record Keeping: Keep End User due diligence records for at least 5 years after the account is closed, and transaction records for at least 5 years after the transaction, or longer where required.
• Training: Train relevant staff on anti-money laundering and sanctions obligations when they join and at least annually after that.
• Cooperation: Respond promptly to Axis's requests for information, and notify Axis of any regulatory action, investigation, or loss of license affecting its Operator Platform.

9) Platform Controls

The Platform provides tools that help Operators meet their obligations, including:

• Configurable identity verification (KYC) levels, and the information required at each level.
• A fraud rules engine with alerts and End User risk scores.
• Country-level access restrictions.
• A transaction feed covering deposits, withdrawals, and adjustments.
• Deposit, wager, and loss limits.
• Role-based back-office permissions, with a written justification and an audit trail required for every manual balance adjustment.

Operators are responsible for configuring and using these tools appropriately. The tools support an Operator's anti-money laundering program but do not replace it.

10) Red Flags

Examples of activity that may indicate money laundering or other financial crime include:

End User Activity

• Deposits followed by withdrawals with little or no gambling activity.
• Deposits or withdrawals structured to stay just below verification or reporting thresholds.
• Payment methods in a name other than the account holder's, or many payment methods on one account.
• Multiple accounts linked by shared devices, IP addresses, payment methods, or personal details.
• Opposing positions on the same market, or coordinated play between accounts, that appear designed to move value rather than to win.
• Trading on non-public information, or on events the End User is able to influence.
• Virtual asset transfers linked to mixers, sanctioned addresses, or high-risk exchanges.
• Access from blocked or sanctioned locations, including through tools used to hide location.
• Refusal to provide identity information, or documents that appear altered or false.
• Activity that is inconsistent with the End User's known profile or means.

Operator Activity

• Unexplained spikes in volume, or volumes inconsistent with the Operator's stated business.
• Manual balance adjustments without a credible justification.
• Offering services in jurisdictions the Operator did not disclose, or after losing a license.
• Payments routed through unrelated third parties.
• Resistance to providing due diligence information or answering Axis's questions.

11) Monitoring, Escalation & Reporting

• Monitoring: Axis monitors activity across the Platform for signs of misuse, and may review transactions, payouts, games, markets, and administrative actions on any Operator Platform.
• Internal Escalation: Personnel who notice potential Suspicious Activity must report it promptly to the AML Compliance Officer, and must not discuss it with the Operator or End User involved.
• Investigation: The AML Compliance Officer reviews each escalation, documents the facts and the decision reached, and decides what action to take.
• Actions: Depending on the findings, Axis may request information from the Operator, require it to fix issues within a set time, restrict features or integrations, or suspend or terminate its access under our Terms of Service.
• Reporting to Authorities: Where required by law, or where Axis otherwise considers it appropriate and lawful, Axis reports Suspicious Activity to the relevant authorities and cooperates with lawful requests from regulators and law enforcement.

12) Sanctions Compliance

• Axis does not do business with anyone on OFAC's Specially Designated Nationals and Blocked Persons List or other applicable sanctions lists, with entities 50% or more owned by listed persons, or with anyone located, organized, or ordinarily resident in a comprehensively sanctioned country or region.
• Operators, their Beneficial Owners, and their directors are screened at onboarding and on an ongoing basis.
• Potential matches are escalated to the AML Compliance Officer, and onboarding or activity is paused until the match is resolved. Confirmed matches are blocked and reported as required by law.
• Operators must block access to their Operator Platforms from comprehensively sanctioned countries and regions, and Axis may apply Platform-wide restrictions that Operators cannot override.

13) Virtual Assets & Payment Integrations

• Payment processors, on-ramps, and other payment providers connected to the Platform operate their own compliance programs, and Operators that contract with them directly must meet those providers' requirements.
• Operators that accept virtual assets must meet the standards in Operator AML Standards.
• Axis may restrict or disable a payment integration for an Operator, or across the Platform, if it presents unacceptable financial crime risk.

14) Record Keeping

• Axis keeps Operator due diligence records, screening results, risk assessments, investigation files, and any reports made to authorities for at least 5 years after the Operator relationship ends or the matter is closed, as set out in our Data Retention & Deletion Policy.
• These records are stored securely, with access limited to those who need it, in line with our Information Security Policy.

15) Training

Axis Personnel involved in Operator onboarding, support, payments, and compliance complete anti-money laundering and sanctions training when they join and at least annually after that. Training covers this Policy, red flags, escalation procedures, and the prohibition on tipping off.

16) Confidentiality

Information about investigations and reports to authorities is strictly confidential. Axis will not disclose that a report has been made or that an investigation is underway where doing so is prohibited by law or could prejudice the investigation.

17) Disclaimer

18) Changes to This Policy

We may update this Policy from time to time by posting a revised version on this page with a new effective date. We will notify Operators of material changes by email or through the Platform.

19) Contact

For questions about this Policy, or to report suspected financial crime involving the Platform, email the AML Compliance Officer at support@axis.inc with "AML" in the subject line.