Anti-money laundering policy

May 19, 2021

In order to continue its goal to provide a safe environment for players on its system, VLB crafted and adopted this Anti-Money Laundering (“AML”) Policy (the “Policy”) to monitor and mitigate the risks of funds derived by illegitimate means, as well as ensure compliance with legal and regulatory obligations. VLB will review this Policy annually in training with all personnel, and VLB will provide a copy of this policy to all new hires. This policy applies to all VLB employees, directors, managers, officers and consultants. Non-compliance with this policy will likely result in disciplinary action for any personnel including termination and potential criminal and civil penalties.

This policy of VLB has been adopted for the specific purpose of project Blitz which is a new iOS only mobile app focused on eSport competitions published by VLB in the following jurisdictions:

The purpose of this policy of VLB is to comply with US Money Laundering Control Act (Public Law 99-570) and others applicable AML laws and regulations and to use our commercially reasonable efforts to detect, prevent and deter money laundering, terrorism financing and related illegal activities. For purposes of this policy, money laundering is defined as: the process by which the financial proceeds of criminal activities are given the appearance of legitimacy, thereby concealing their origin and enabling criminals to reap the benefit of their crimes. Typically, illegally obtained cash is passed through legitimate financial institutions and businesses or converted into hard assets. These techniques make it difficult or impossible to trace the money to its illegal origins. The money launderer’s or terrorism financier’s goal is to make its financial transactions appear normal, which creates an apparent legitimate source for the illicit cash, while simultaneously enabling the criminal to evade payment of taxes on the unlawful proceeds. Due to the financial transactions involved in gaming activities, AML policies must be in place to ensure proper operations of the gaming operations. VLB must remain alert to threats of involvement in any money laundering activity, to which VLB might be exposed via its relationships with players, suppliers, partners or personnel behavior.

Apart from the more obvious offenses relating to drug trafficking, terrorism, fraud, theft, and false accounting, and such offenses as you may be aware from specific knowledge, consideration also needs to be given to other potential offences which may well be encountered in business. These include, but are not limited to: bribery, corruption and criminal breach of competition.

1. KYC

Knowing a customer is vital to real money gaming operations. All strategies implemented to identify customers are aimed at ensuring a level playing field and maximum fraud prevention.

VLB's customer acceptance procedures consist of a number of components, including but not limited to:

Set out below are notes on the AML procedures to be carried out as part of customer acceptance procedures:

1a. Account Registration Guidelines

Upon opening an account, VLB will request that customers enter the following details:

1b. Withdrawal Experience

Withdrawals will remain in a pending state until such point as (i) the customer account is confirmed by VLB, (ii) customer identity is verified and (iii) all requested documentation is provided.

(i) Account Confirmation

In order for the customer to be able to withdraw funds from its account, such account must first be officially confirmed by VLB which may request that customers provide the following details:

VLB reserves the right to request additional personal information in the interest of security and enhanced customer service.

(ii) Customer ID verification

In order for VLB to confirm his identity and residence, a customer will need to provide a Identification Document

(iii) Documentation Provision

VLB reserves the right to request additional documentation in the interest of security and compliance, notably

In the event that VLB requires documentation prior to approving a withdrawal, VLB will send a documentation request email to the customer. If no documentation is provided, a reminder email (or other communication mechanism) will be delivered/sent. If fourteen (14) calendar days have passed without receiving documentation from the customer, VLB will send a "24-hour notice" email to the customer's registered email address. If the customer fails to provide documentation at that point, the withdrawal will ultimately be cancelled, and the balance will be returned to the customer account.

As an on-going task, the Support Department completes routine manual withdrawal checks by following the procedure below:

2. Anti-Money Laundering Procedures

VLB will monitor both manually and through automated processes the deposit and withdrawal activity on an ongoing basis to check for unusual behavior. This monitoring includes, but is not limited to:

Any account which meets the criteria as per the system rules, or which staff considers unusual behavior, will have additional personal information requested as per the KYC procedures, and the action taken on the account will be the same.

2a. Money-Laundering Regulations

2b. Payout Management

All customer withdrawal requests must be reviewed and authorized prior to sending a withdrawal to the customer, ensuring all payment methods have been verified as belonging to the customer.

3. Employee Training

It is vital that all VLB team members are aware of the principles that underlie these procedures as well as the procedures themselves.

Therefore, VLB will implement an ongoing training regimen to ensure that all team members know the procedures and understand the rationale behind them. This will ensure they react in an appropriate manner if and when cases of fraudulent behavior arise. This training will be provided on an annual basis to ensure each team member's understanding.

Furthermore, all VLB team members will be encouraged to use their judgment and report anything they consider potentially suspicious rather than leaving it to someone else more directly involved.

4. Anti-Fraud Management Procedures

If personnel suspects any type of illegal money laundering activity, it must be reported to the Legal Compliance Team for consideration. When in doubt about any particular case or incident, it is mandated that team members contact the Legal Compliance Team.

The Legal Compliance Team will provide reports designed to identify potential suspicious activity. The Legal Compliance Team will review the activity and will ultimately decide whether to file a SAR for each incident. While in some cases VLB risk personnel may prepare preliminary reports, the Legal Compliance Team will ultimately be responsible for official filing of a SAR form for each incident determined to be suspicious within the federal requirement for filing of thirty (30) calendar days from the date of discovery.

VLB maintains a Support Department, with the objective of preventing abuses of the gaming system, collusion among customers, financial fraud and credit card abuse, underage play, excluded customer activity, and other occurrences that can result in financial losses.

The Support Department will perform identity checks on customers, investigate suspicious conduct and develop strategies to deal with fraudulent or dishonest customers by recognizing patterns.

All team members are expected to report any suspicious events they detect. Strategies incorporated in the fraud prevention plans address issues such as accountability, efficiency, and effective administration.

This policy covers the prevention, detection, and management of fraud and matters pertaining to fraud. It aims to raise the awareness of fraud and its prevention in the internet gaming environment and to give guidance to report suspected fraud, and how the investigation of that report will proceed.

All suspected behavior will be reported to the appropriate regulatory authorities. VLB Legal Compliance Team shall immediately notify the regulatory authority upon detecting any person participating in Internet or mobile real money gaming who is:

5. Sanctions and Politically Exposed Persons

5a. PEP Cross Reference/Anti-Fraud sanctions Procedures

VLB does not only rely on the personal details a customer has entered within the registration process. VLB must ensure that every customer is a legal adult in the regulated jurisdiction, and permitted to participate on VLB’s platform.

A "politically exposed person" (PEP) is a term describing someone who has been entrusted with a prominent public function, or an individual who is closely related to such a person.

These may be heads of state, members of ministries, courts, central banks, ambassadors, management of state-owned corporations, etc. and their relatives.

PEP's include the following:

In addition, VLB’s Payment Services Providers and KYC provider will also check the Office of Foreign Assets Control list on every customer withdrawal.

5b. PEP List Results

The Support Department will follow the below procedure if a customer of concern is encountered:

6. Anti-Collusion

Team members will be expected to manually monitor any suspicious play that may be coming from, for example, linked accounts playing on same tables (when applicable), with the same IP address, or from the same gaming device.

7. Environment and Culture

VLB is focused on creating an environment and culture in which customers believe that dishonest acts will be detected and investigated. To this end, team members must always be aware of the possibility of customers making fraudulent attempts. To ensure this environment is maintained, all team members must:

Measures to prevent fraud should be continually monitored, and developed, especially as new systems, programs, and contacting or arrangements are introduced or modified. VLB will thoroughly and carefully investigate all reports of suspected fraudulent behavior.

8. Requirements regarding SAR/investigation communication and reporting

A team member cannot disclose information when that team member knows or suspects a report has been made to the authorities and that the disclosure may prejudice an investigation (i.e., by law enforcement agencies). The offense of prejudicing an investigation occurs if you disclose information that you know or suspect may prejudice an investigation, or if you conceal, or otherwise interfere with information or material relevant to an investigation.

However, there is nothing to prevent a team member from making normal inquiries to understand a transaction in the course of their work (especially those needed to determine whether an initial concern may amount to suspicion of money laundering). Team members are to contact the Legal Compliance Team as soon as an issue becomes apparent to minimize the risk of delay. If put under pressure by a customer to honor their request(s) or to explain delays, team members are to contact the Legal Compliance Team for assistance, and take great care to avoid making any statement that may constitute tipping off.

9. Risk-Based Approach

VLB takes a risk-based approach, as permitted by guidance, to customer identification and KYC requirements. Money launderers are not generally conspicuous. On the contrary, they depend on appearing plausible and non-noteworthy. They will commonly be deceitful or attempt to provide the absolute minimum amount of information necessary. VLB and its team members will take care to subject all potential money laundering suspects to a proper and objective assessment.