OTB Interactive Inc. KYC & AML Policy

1. Purpose & Scope

This policy sets out the procedures OTB Interactive Inc. follows to comply with the KYC and AML requirements under the Anjouan Online Gaming Act, 2005 and the License Conditions 2025. It applies to all customers, staff, and agents involved in the operation of our gaming services.

2. Customer Identification Requirements

Prior to any payout of any amount, OTB Interactive will gather, review, and confirm:

• A recently issued, valid government photo ID
• A recently issued utility bill in the player's name

This KYC will be done via a service provider such as SumSub.

When cumulative deposits reach USD 10,000 (or equivalent), OTB Interactive will again gather, review, and confirm these documents.

Prohibited Customers:

• No under-aged players.
• Customers from prohibited jurisdictions (Australia, Austria, Comoros, France, Germany, Netherlands, Spain, UK, USA, sanctioned or FATF-blacklisted countries) are geo-blocked.

3. Monitoring & Reporting

OTB Interactive will take all possible steps to prevent use of its services for money laundering.

Suspicious Transactions:

• Any suspicious activity must be identified, logged, and reported internally to the appointed Money Laundering Reporting Officer (MLRO).
• The MLRO will submit reports to the Anjouan Offshore Authority as required.

Ongoing Monitoring:

• Accounts will be monitored for activity inconsistent with player profile, attempts to bypass geo-blocking, and sudden or unusual deposit/withdrawal patterns.

4. Recordkeeping

All KYC documents, transaction records, and internal reports of suspicious transactions will be retained for a minimum of 5 years (or longer if required by law).

5. Roles & Responsibilities

Money Laundering Reporting Officer (MLRO):

A senior staff member is appointed to act as MLRO, responsible for reporting suspicious activity to the Anjouan Offshore Authority.

Compliance Officer:

A separate senior staff member will serve as Compliance Officer, responsible for overall regulatory reporting and compliance oversight.

6. Player Protection

Procedures are in place to identify and assist players at risk of compulsive gambling, including providing access to counselling resources. Self-exclusion requests will be honored promptly.

7. Staff Training

All relevant employees will receive training on this KYC policy, AML obligations, and how to identify and escalate suspicious activity.

Conclusion

This policy fulfills the minimum KYC/AML requirements imposed by the Anjouan Offshore Financial Authority under the License Conditions 2025. OTB Interactive Inc. commits to maintaining these standards and updating the policy if the regulator issues further procedures or requirements.