Regulatory Compliance

Anti-Money Laundering & Know Your Customer Policies

Nova88‘s commitment to combating financial crime, money laundering, and terrorist financing — in full compliance with applicable regulations.

AML / CFTFull Compliance

Risk-BasedApproach Applied

KYCAll Players Required

CDD / EDDTiered Due Diligence

Nova88 (the “Company”) is subject to anti-money laundering and counter terrorist financing (AML) legislations, rules and regulations, which require the Company to have adequate policies, procedures and controls that will identify, assess, and mitigate the risk of money laundering and terrorist financing activities. The Company hereby expresses its commitment to combat any potential abuse of its Services and the Website for the purpose of money laundering (ML) and terrorist financing (TF) activities.

Section 01

Our Commitment to AML/CFT

It is the declared policy of the Company to comply with existing and relevant anti-money laundering and counter terrorist financing legislations and regulations, as well as provisions and guidelines regarding customer due diligence and the reporting of threshold and suspicious transactions.

The Company shall adopt and establish policies and programs consistent with relevant regulations for Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT), that will effectively identify, assess, monitor and control risks associated with ML and TF activities in the regulated jurisdiction.

Legislative Compliance

Full adherence to all applicable AML/CFT laws, regulations, and directives issued by the relevant regulatory agencies.

Risk-Based Program

Adoption of a Risk-Based AML program that actively prevents and mitigates money laundering and terrorist financing risks.

Institutional Oversight

Management and senior officers ensure business is conducted in conformity with all relevant legislations, best practices, and industry standards.

Full Cooperation: The Company commits to fully cooperate with the relevant regulatory agency and other enforcement agencies within lawful restrictions and regulations. Adequate procedures and actions shall be taken when there are reasonable grounds to believe that money laundering and/or terrorist financing activities are being conducted.

Section 02

Know Your Customer (KYC) Requirements

Since the Company is prohibited from keeping anonymous accounts or obviously fictitious names, it shall ensure that effective procedures for securing Player information and verifying the true identity of Players are in place, and that it is not in any way used as an instrument to facilitate money laundering and terrorist financing activities.

The Company will establish and verify the true identity of its Players, including the validation of the truthfulness of the information and the authenticity of the Identification Documents presented, by checking reliable and independent sources and available online databases.

Player Information Collection

The Company collects information from all customers who avail of products and services, emphasizing measures taken to identify and continuously monitor Players engaged in gaming activities.

Identity Verification

Validation of the truthfulness of information and authenticity of Identification Documents through reliable, independent sources and available online databases.

Ongoing Monitoring

Continuous monitoring of Players who are engaged in gaming activities, with documentation of how each customer was profiled and what standard of due diligence was applied.

Document Refusal Policy

The Company shall not enter into business relationships with individuals who refuse to provide required Identification Documents. Business relationships shall be terminated with Players who, after several requests, unreasonably fail and refuse to submit documents.

Section 03

Customer Due Diligence & Risk-Based Approach

The Company shall apply a Risk-Based Approach in performing Customer Due Diligence (CDD) measures for all its customers regardless of their economic standing, whenever applicable in the regulated jurisdiction.

Risk Level	Classification	Due Diligence Standard	Key Measures
Low Risk	Standard players with low-risk profiles	Simplified CDD (SCDD)	Basic identity verification; standard monitoring
Normal Risk	General player population	Standard CDD	Full KYC documentation; periodic review
High Risk	Politically Exposed Persons (PEPs), high-value transactions, flagged activity	Enhanced Due Diligence (EDD)	In-depth background checks; source of funds verification; intensified ongoing monitoring

Documentation Requirement: On all occasions, the Company shall document how a specific customer was profiled and what standard of customer due diligence measure was applied — ensuring a complete and auditable compliance trail for all accounts.

Section 04

Suspicious Transaction Reporting

If the Company suspects or has reasonable grounds to suspect that funds are linked or related to or are to be used for money laundering or terrorism activities, or for funding terrorist acts or terrorist organizations, it shall promptly report its suspicion to the relevant regulatory agencies.

The Company shall likewise be responsible for the identification and reporting to the relevant regulatory agency of transactions that will be qualified as suspicious.

Suspicious Activity Detection

Identification of transactions or behaviors that give rise to reasonable grounds of suspicion of ML or TF activities.

Prompt Reporting Obligation

Timely reporting of suspicious transactions to the relevant regulatory agencies without delay upon detection.

Threshold Transaction Reports

Identification and reporting of all transactions that meet or exceed the threshold defined by relevant regulatory guidelines.

Section 05

Training & Awareness

To ensure awareness, competence and compliance with existing and relevant legislations, rules and regulations relating to AML and CFT, the Company shall provide its management, officers, authorized representatives and employees based in the regulated jurisdiction, to be adequately informed of relevant basic AML/CFT legislations and regulations.

Ongoing Education: All relevant personnel — including management, officers, authorized representatives, and employees — shall receive adequate and up-to-date training on AML/CFT legislations, regulatory obligations, and best practices to ensure a culture of full compliance throughout the organization.

Promoting Full Regulatory Compliance

With these policies and programs, the Company hopes to promote full compliance with all the relevant legislations, rules and regulations regarding anti-money laundering and countering terrorist financing, which are at the same time complemented by its KYC policies on its Players.

Nova88 — Committed to Safe & Responsible Gaming