AML POLICY

Last Updated: 19 Sept 2022

1. Company Business Model

PLAY888 VIP is operated by Vim Tech International S.A. and falls within the scope of the AML obligations according to Philippines legislations. Therefore, the senior management has implemented systems and procedures that meet the standards set forth by relevant AML legislation in Philippines.

2. Definition of ML

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 by 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 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.

3. AML (Anti-Money Laundering) policy

Vim Tech International S.A. is aware that offering services related to online gaming pose a risk for money laundering and terrorist financing. To identify, prevent, and limit the risks of money laundering and terrorist financing. Vim Tech International S.A. implemented measures, processes, and internal controls into its daily business operations, which consider the nature of the Vim Tech International S.A.’s clients and services carried out by Vim Tech International S.A.. With these measures, processes, and internal controls in place Vim Tech International S.A. meets all legal requirements related to measures preventing money laundering and terrorist financing, as required by applicable Philippines legislations. Vim Tech International S.A. has prepared AML Policy regarding the prevention of money laundering to prove its commitment for detection, prevention, and reporting to national authorities of all attempts of using Vim Tech International S.A.’s services for any kind of transaction which would meet the statutory definition of money laundering and/or terrorist financing, or which presents any other form of illegal financial transactions. AML Policy is modified and upgraded by changing legislation and good practice in the industry. The content of the AML Policy covers:

• the internal organization of processes related to prevention of money laundering;
• due diligence process (also known as “Know your customer or KYC”)
• money laundering risk assessment;
• non-eligible and eligible categories of clients;
• enhanced due diligence measures;
• reporting obligations (towards competent authorities).