KYC Policy

KNOW YOUR CUSTOMER (KYC) POLICY

1. Introduction

The Know Your Customer (KYC) Policy sets out the principles, rules and guidelines that State77 adopts to identify and verify the identity of players and users of the platform, in order to ensure compliance with applicable legislation and to prevent illicit activities such as money laundering and the financing of terrorism.

2. Objective

The primary objective of this policy is to prevent illicit activities from occurring within our online betting and gaming environment, in compliance with legal, sectoral and ethical requirements, guided by the following principles:

● Regulatory Compliance: To ensure that all advertising communications are in accordance with applicable gaming and betting regulations, specifically AML/CFT (Anti-Money Laundering / Counter-Financing of Terrorism) legislation, applicable gaming and AML/CFT laws and regulations, regulatory orders issued by the gaming regulator, and normative instructions from the financial intelligence unit.

3. Scope

This policy applies to all staff and departments of State77 that are involved in interaction with players, including but not limited to registration, customer support, operational areas, and player and transaction monitoring.

4. Definitions

· Know Your Customer (KYC): A process used to identify and verify the identity of customers with the objective of preventing fraud, money laundering and other illicit activities.

5. KYC Process Guidelines

5.1 Player Registration

Upon registration, the player or user must provide the following information:

5.1.1 Basic Required Information

· Full name;

· Date of birth;

· Nationality;

· Full residential address;

· Identification number (national identity document, passport, or equivalent); and

· Contact information (telephone and email);

· Geolocation.

5.1.2 Banking Information:

· Registered bank account.

5.1.3 Required documents:

· Copy of a photo identity document; and

· Recent proof of address (utility bill).

5.2 Player or User Verification and Document Validation

All information provided is verified against the documents previously submitted, which are in turn authenticated using specific tools. State77 reserves the right to request additional documents if necessary.

5.3 Data Cross-Referencing

State77 cross-references data provided by players and users against third-party databases to identify the following:

· Politically exposed persons (PEP (politically exposed person)) or associations with PEPs (up to 2nd degree of relationship);

· Sportingly exposed persons (SEP (sportingly exposed person)) or associations with SEPs (up to 2nd degree of relationship);

· Existence of corporate or employment ties with other operating agents;

· Presence on national and international restricted lists (FBI, Interpol, OFAC, etc.);

· Employment history with regulatory bodies (gaming regulator, relevant ministry, financial intelligence unit, etc.);

· History of legal proceedings;

· History of criminal records;

· History of ludopathy / pathological gambling;

· Media exposure and profile.

Player profiles that may not be accepted:

· Persons under 18 years of age;

· Owner, administrator, director, person with significant influence, manager or employee of the operating agent;

· Public official with duties directly related to the regulation, control or supervision of the activity;

· Person who has or may have access to fixed-odds lottery betting computer systems;

· Person diagnosed with ludopathy / pathological gambling, evidenced by a report from a qualified mental health professional; and

· Persons located in, or holding bank accounts in, jurisdictions with a high risk of money laundering.

5.4 Risk Classification

Based on the information provided by the player or user, individuals are classified according to the level of risk they represent, so that State77 can apply appropriate control measures for each risk level.

5.5 Ongoing Monitoring

State77 will carry out ongoing monitoring of accounts to identify suspicious activity. This includes:

· Regular review of transactions;

· Analysis of betting patterns;

· Verification of possible indicators of fraud or illicit activity;

· Review of registrations to identify players or users potentially prohibited from playing.

5.6 Data Retention

State77 must retain records and documents related to compliance with the provisions of this Policy for a minimum of 5 (five) years. All information collected will be stored securely and in accordance with applicable data protection laws.

6. Responsibilities

● Registration Department: Responsible for managing player and user registrations;

● Governance and Compliance Department: Responsible for the implementation, review and update of this policy;

● Risk Department: Responsible for managing this policy, ensuring compliance with local and international regulations.

7. Policy Audit and Review

State77 will conduct periodic internal audits to ensure compliance with this KYC Policy and applicable regulations.

8. Training and Capacity Building

The company conducts regular training for all staff, particularly those directly involved in the processes of registration, verification, storage and monitoring of player or user data.

9. Penalties for Non-Compliance

Any breach of this KYC Policy will be treated with due seriousness by State77. Penalties may include:

· Formal warnings;

· Mandatory corrective training;

· Disciplinary action, which may range from suspension to dismissal, depending on the severity of the breach.

10. Contact

For any queries regarding this policy, please contact the Governance and Compliance Department.

Approval:

Compliance Director