BSA/AML Policy:  

Purpose 

 

It is the policy of Worldwide Gaming LLC d/b/a Dogg House Casino (“Worldwide Gaming”) to comply with all requirements of the Bank Secrecy Act (“BSA”), regulations (Title 31 Chapter X), section 352 USA PATRIOT Act. fully and continuously, sanctions issued by the Office of Foreign Assets Control (“OFAC”), and all other applicable U.S. laws, regulations, and guidance (collectively the “Acts”).  

This Policy applies to all the Worldwide Gaming officers, directors, employees, temporary employees, independent contractors, consultants, third-party vendors (to the extent that they operate under or support the Worldwide Gaming’s BSA/AML and Sanctions Program), advisors and/or other similar non-permanent personnel. Worldwide Gaming is committed to developing adequate program controls to assure adherence to the applicable AML and Sanctions laws, rules, and regulations.

This policy will be reviewed periodically to ensure it remains current. It will be submitted to the Board of Directors (“Board”) at least annually for re-adoption. 

Definition of Money Laundering 

 

Money Laundering is the introduction of assets derived from illegal and criminal activities (predicate offences) into the legal financial and business cycle. Offences may include, for example, forgery of money, extortionate robbery, drug crime as well as fraud, corruption, organized crime, or terrorism etc. and any other predicate offences for money laundering which are defined by local law. The money laundering process consists of three “stages”:  

• Placement: The introduction of illegally obtained monies or other valuables into financial or non-financial institutions. 

• Layering: Separating the proceeds of criminal activity from their source through the audit trail, disguise the origin of funds and provide anonymity. 

• Integration: Placing the laundered proceeds back into the economy in such a way that they re-enter the financial system as apparently legitimate funds. 

These “stages” are not static and overlap broadly. Financial institutions may be misused at any point in the money laundering process.

Requirements

 

Worldwide Gaming is fully committed to the implementation and maintenance of an enterprise wide BSA/AML Program. Furthermore, it is the policy of Worldwide Gaming to ensure the BSA/AML Program is commensurate with the size, complexity and risk of Worldwide Gaming’s operations. 

It is the policy of Worldwide Gaming that the BSA/AML Program shall include the five main pillars: 

• Establish and maintain an internal control structure to ensure compliance with the Bank Secrecy Act; 

• Provide for periodic independent testing of the BSA/AML Compliance Program; 

• Designation, by the Board of Directors, of a Bank Secrecy Act & Anti-Money Laundering Officer (“BSA Officer”) who shall be responsible for oversight of the BSA/AML program; 

• Provide for an on-going training program for all personnel and the Board of Directors; and

• Implement Customer Due Diligence (“CDD”) Standards and Know Your Customer (“KYC”) Profile, inclusive of Beneficial Ownership. 

 

Designation and Duties of a BSA/AML Officer 

 

The Board of Directors is responsible for Worldwide Gaming’s overall BSA/AML Program and shall, in conjunction with company officers and senior management, appoint a BSA/AML Officer to oversee the Program. Upon appointment, the Board of Directors has empowered the BSA/AML Officer with the necessary authority to serve in this capacity. 

The appointed BSA/AML Officer shall develop and implement a Board approved, program (the BSA/AML Program) for Worldwide Gaming. The BSA/AML Program will incorporate procedures to ensure compliance with all applicable aspects of the regulations.  The BSA/AML Officer will be responsible for coordinating and monitoring daily BSA/AML compliance. The BSA/AML Officer may delegate daily monitoring activities to other employees, as necessary and appropriate. 

At least annually, the BSA/AML Officer shall provide a report to the Board of Directors, or its designated committee, on the administration and effectiveness of the BSA/AML Program. The report shall include, at a minimum: 

• Recommend changes to the BSA/AML Program, including internal controls and approval of the BSA/AML Policy; 

• The status of any open action items identified in any audit, review, or exam; and 

• A summary of any staff and/or Directors who have not completed the mandatory training. 

 

Training 

 

It is the policy of Worldwide Gaming to require, at least annually, all employees, officers, and senior management to attend BSA/AML training. The BSA/AML Officer or designee shall oversee the training which shall be targeted to the employee’s specific job function. The training program shall inform employees of the Worldwide Gaming’s required conduct and procedures for compliance with the BSA/AML regulations. 

In addition to the annual training provided to employees, the BSA/AML Officer and appropriate employees, whose duties are specific to the BSA/AML Department, shall periodically receive training relevant to regulatory changes and program enhancements. 

Customer Due Diligence and Know Your Customer, inclusive of Beneficial Ownership

 

Know your customer (KYC) is the customer due diligence (CDD) that Worldwide Gaming must perform to identify their customers. KYC should not be thought of as a form to be filled; it is a process to be undergone from the start of a customer relationship to the end. 

Suspicious Activity Reporting 

 

It is the policy of Worldwide Gaming to comply with all regulatory requirements for suspicious activity monitoring, detection, reporting, and recordkeeping. 

The Board of Directors has appointed the BSA/AML Officer with Program oversight responsibility. The Board of Directors further recognizes that suspicious activity monitoring, detecting, and internal reporting is the responsibility of all employees. 

Identification/Detection  

 

The BSA/AML Officer shall implement a program which establishes procedures to identify, through various methods, potentially suspicious activity. Various identifying methods include: 

• Employee Identification; 

• Law Enforcement Inquiries and Requests; 

• Transaction/Surveillance Monitoring (Manual and Automated); and 

• Third Party and Non-Employee Reports. 

 

All suspicious activity must be reported to the BSA/AML Officer or designee immediately upon detection. Employees are encouraged to contact the Compliance Department through the Compliance email (compliance@rebet.com) and provide significant information to the BSA/AML Officer or designee in a timely manner. The BSA/AML Officer or designee is responsible for completing an investigation of all reported activity. 

Monitoring  

 

The BSA/AML Officer shall also implement a monitoring program that includes procedures to detect potential suspicious activity. These procedures shall incorporate both manual and, when available, automated monitoring. When automated monitoring systems are used, the program shall establish and maintain appropriate staffing and experience levels to manage the alerts produced by the automated monitoring system. The system parameters shall be periodically assessed for appropriateness and adjusted in accordance with risk levels associated with the individual parameters. 

Investigation  

 

The BSA/AML Officer along with their staff shall be responsible for the investigation of possible SARs.  After potential suspicious activity has been identified and discussed a determination will be made on the reporting or not reporting of the Suspicious Activity. All decisions made will be documented, including non-file decisions.  

Reporting  

 

It is the policy of Worldwide Gaming to file a SAR when potential criminal violations are detected. Worldwide Gaming recognizes the following, aggregated, amounts require filing: 

• Insider abuse in any amount; 

• Elder abuse in any amount; 

• $5,000 or more when a suspect is identified; and •     $25,000 or more regardless of a potential suspect.

 

The BSA/AML Officer will provide notification, in a timely manner, to the Board of Directors or an appointed committee thereof regarding all SAR filings and investigations resulting in a non-file. 

All Personnel must report any potentially suspicious activity (i.e., “Red flags”) observed through the regular course of business to the Compliance Team. See the AML Policy Basics for more information on Red flags. The Compliance Team must use a risk-based approach for monitoring appropriate Payment Services as set forth in applicable procedures. Potentially suspicious activity referred to or detected by the Compliance Team must be reviewed in accordance with applicable procedures. Activity determined to be suspicious must be reported by the Compliance Team in accordance with the Suspicious Activity Reports (“SARs”) Procedure. SARs and any information that might reveal the existence of a SAR, are highly confidential and should never be shared outside of Worldwide Gaming without expressing prior authorization of the BSA Officer or the Chief Risk & Compliance Officer, as applicable.  

Record Retention 

 

It is the policy of Worldwide Gaming to maintain all reports and committee meeting documentation in accordance with the retention requirements set forth in the BSA/AML. The regulation mandates that supporting documentation be maintained for five years from the date of filing the SAR. The BSA/AML Officer shall be responsible for ensuring the documentation is maintained in an appropriate manner to protect the confidential nature of the documentation. All requests for supporting documentation will be directed to the BSA/AML Officer, who shall ensure the request is legitimate and appropriate. 

Confidentiality

 

In accordance with the safe harbor provision provided by the BSA, all employees, directors, and agents of Worldwide Gaming will be informed and periodically reminded of the confidential nature of suspicious activity reporting. 

It is the policy of Worldwide Gaming to require all employees, directors, and agents, who are subpoenaed or  otherwise requested to disclose a SAR or any SAR information, to decline to have knowledge of any information that would disclose that a SAR has been considered or filed. Immediately following the request for disclosure or information about a SAR, the employee, director, or agent must notify the BSA/AML Officer. 

Worldwide Gaming Know Your Customer (KYC) 

 

Know your customer (KYC) is the customer due diligence (CDD) that Worldwide Gaming must perform to identify our customers and ascertain relevant information pertinent to conducting business with them. KYC should not be thought of as a form to be filled; it is a process to be undergone from the start of a customer relationship to the end. 

Customer Due Diligence  

 

Our Customer Due Diligence requirements (CDD) requires Worldwide Gaming to establish procedures that enable the Worldwide Gaming to identify the beneficial owners of each customer at the time a new account is opened, unless the customer is otherwise excluded or the transaction is exempted.  The procedures must contain the elements required for verifying the identities of customers  that are individuals under applicable Customer Identification Program (CIP) requirements.  

At a minimum, the following information is collected and verified during initial due diligence screening: 

• Customer’s name

• Customer’s physical address, no PO Boxes 

• Customer’s taxpayer identification number or social security number

• Customer’s Beneficial Ownership. For each beneficial owner identified: o Name

  • Physical address, no PO Boxes

  • TIN

  • Date of Birth

 

 

BSA: Office of Foreign Assets Control Policy 

It is the policy of Worldwide Gaming to comply with all United States laws, rules, and regulations regarding doing business with, maintaining accounts for, or handling transactions or monetary transfers for foreign countries or foreign nationals on the Office of Foreign Assets Control (OFAC) list of Special Designated Nationals and Blocked Entities. 

OFAC is a division of the U.S. Department of the Treasury. OFAC administers and enforces economic and trade sanctions against targeted foreign countries, terrorism sponsoring organizations, and international narcotics traffickers based on U.S. foreign policy and national security goals. 

Worldwide Gaming must develop and maintain processes to ensure it does not engage in business with any known or suspected terrorist, or any terrorist organizations designated by the Department of Treasury pursuant to the Patriot Act, any person on the SDN List, or any entity or person located in, or that is a national of, countries subject to trade and economic sanctions as administered or enforced by OFAC (collectively, the “OFAC Prohibited Parties Lists”).  

As part of the Company’s Customer Due Diligence (CDD) process, all customers are screened against the OFAC Specially Designated Nationals (SDN) List and other applicable global sanctions lists.

Screening Process

• The Company utilizes a third-party KYC/IDV provider (currently: Plaid) to perform OFAC and sanctions screening at the time of onboarding and during any subsequent verification events (e.g., updates to customer information or re-verification).

• The provider’s system automatically cross-checks customer data (name, date of birth, and other identifiers) against OFAC’s SDN list and other watchlists to identify potential matches.

• Screening results and records are retained by the Company for audit and compliance review purposes.

Positive Match Procedure

In the event the third-party provider identifies a potential OFAC match:

1. The account will be immediately suspended pending review;

  

BSA Policy                                                                                                                                                                                                                          

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1. The Compliance Officer will verify the match through the vendor’s platform and independent validation; and

2. If a confirmed positive match exists (i) the account will remain frozen; (ii) a report will be filed with OFAC within ten (10) business days; (iii) Full documentation of the finding and actions taken will be maintained in accordance with AML recordkeeping requirements.

Independent Testing

The Company’s AML program, including the OFAC screening process performed by its third-party

vendor, is subject to independent testing on an annual basis. The review will assess the adequacy and effectiveness of procedures, recordkeeping, and vendor oversight.

Record Retention 

 

It is the policy of Worldwide Gaming to maintain all OFAC related records for a minimum of 10 years. This policy incorporates specific requirements for OFAC records within the identified section of the applicable policy. The BSA/AML Officer shall establish and maintain a record retention schedule for all other records, in accordance with state law document and record retention requirements. 

Worldwide Gaming recognizes the high level of confidentiality associated with OFAC records and will make every effort to ensure all confidential OFAC records are properly secured and stored to the fullest extent possible.