AML KYC Policy

Blackhole N.V.

Last updated: 10/14/2021

Introduction

Csgorun is operated by Blackhole N.V.

Blackhole N.V.

Objective of the AML Policy

We seek to offer the highest security to all of our users and customers on csgorun.run for that a three step account verification is done in order to insure the identity of our customers.

The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering.

Blackhole N.V.

Blackhole N.V.

The AML program of Blackhole N.V.

EU:

EU:

EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE:

Definition of money laundering

Money Laundering is understood as:

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for Blackhole N.V.

In accordance with the AML legislation Blackhole N.V.

Furthermore, an MLRO (Money Laundering Reporting Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general Management.

AML policy changes and implementation requirements

Each major change of csgorun.run AML policy is subject to approval by the general management of Blackhole N.V.

Three step Verification

Step one verification

Step one verification must be done by every user and customer to withdraw.

Regarding the choice of payment, the amount of payment, the amount of withdraw, the choice of withdraw and nationality of the user/customer step one verification must be done first.

Step one verification is a document that must be filled out by the user/customer himself.

The customer is also obliged to provide

Step two verification

Step two verification must be done by every user who wants to make a withdrawal to a card or electronic money wallet.

Until step two verification is done the withdraw, tip or deposit will be held.

Step two verification will lead the user or customer to a subpage where he must send the following confirmation:

If the user wishes to withdraw to a bank card, he will required to send a photo of the bank card he wishes to withdraw to.

If the card does not contain the name of the card holder, we would require a screenshot from the mobile banking profile.

If the users wishes to withdraw to an electronic money wallet, we would require a screenshot of the users electronic money wallet profile.

Step three verification

Step three verification must be done by every user which deposit over 5000 EUR (five thousand Euro) or withdraws over 5000 EUR (five thousand Euro) or sends another user over 3000 EUR (three thousand EUR) Until step three verification is done the withdraw,

Customer identification and verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers.

Also, a second picture with the face of the user/customer is required.

Please note that all four corners of the ID have to be visible in the same image and all details have to be clearly readable besides the named above.

An employee may do additional checks if necessary, based on the situation.

Sanctions list and PEP (politically exposed person) check

A Politically Exposed Person (PEP), is an individual who is in a notable public position such as a President, Politician, Mayor, etc.

Transactions involved with PEPs are considered as high-risk transactions, Blackhole N.V.

Foreign PEPs includes Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials in a foreign country.

Domestic PEPs like foreign PEPs are individuals who are or have been entrusted domestically with prominent public functions.

International organization PEPs are persons who are or have been entrusted with a prominent position by an international organization.

Family members are individuals who are related to a PEP either directly (consanguinity) or through marriage or similar (civil) forms of partnership.

Close associates are individuals who are closely connected to a PEP, either socially or professionally.

Sources of information for PEPs databases are almost exclusively official government websites (presidency, government, legislative bodies, supreme courts of justice, military administration etc.) and official gazettes where laws, decrees, investments and depositions are published.

The lists we check you comprise the following sanctions lists:

United Nations;

European Union;

US Treasury Department;

The United Kingdom Ministry of Finance;

Switzerland SECO;

Australian sanctions.

PEP lists are always dynamic and are constantly being updated.

Blackhole N.V.

Proof of Address

Proof of address will be done via to different electronic checks, which use two different databases.

A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proofs your state of residence.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible, and all text is readable.

For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.

An employee may do additional checks if necessary, based on the situation.

Source of funds

If a player deposits over a five thousand euro there is a process of understandings the source of wealth (SOW)

Examples of SOW are:

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It is critical that the origin and dominance of that wealth is clearly understood.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this.

Blackhole N.V.

Basic document for step one:

The basic document will be accessible via the setting page on Blackhole N.V.. Every user has to fill out the following information:

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The document will be saved and created by an AI, an employee may do additional checks if necessary based on the situation.

Risk management

In order to deal with the different risks and different states of wealth in different regions on the earth Blackhole N.V.

Region one: Low risk:

For every nation from the region one the three-step verification is done as described earlier.

Region two: Medium risk:

For every nation from the region two the three-step verification will be done at lower deposit, withdraw and tip amounts.

Region three: High risk:

Regions of high risks will be banned.

Additional measurements.

In addition, an AI which is overseen by the AML compliance officer will look for any unusual behavior and report it right away to a employee of Blackhole N.V.

According to a risk based few and general experience the human employees will recheck all checks which are done before by the AI or other employees and may redo or do additional checks according to the situation.

In addition, a data scientist supported by modern, electronic, analytical systems will look for unusual behavior like: Depositing and withdrawing without longer Betting sessions.

Attempts to use a different Bank account to for Deposit and Withdraw, nationality changes, currency changes, behavior and activity changes as well as checks, if an account is used by it

Also a User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.

Enterprise-wide risk assessment

As part of its risk-based approach, Blackhole N.V.

The identification of AML risk categories is based on Blackhole N.V.

The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML-Compliance ensures that an

This transaction monitoring is conducted on two levels:

1) The first Line of Control:

Blackhole N.V.

2) The second Line of Control:

Blackhole N.V.

Also, the three-step verification with adjusted risk management should provide all necessary information

Also, all transaction must be overseen by employees over watched by the AML compliance officer who is over watched by the general management.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behavior and the transaction counterparty.

These checks will be done by an automated System, while an Employee crosschecks them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).

Any Blackhole N.V.

3) The third Line of Control:

As a last line of defense against AML Blackhole N.V.

If fraud or Money Laundering is found the authorities will be informed.

Reporting of Suspicious transactions on csgorun.run

In its internal procedures, Blackhole N.V.

Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Depending on the result of this examination and on the basis of the information gathered, the AML team:

Procedures

The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of Blackhole N.V..

Record keeping

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.

Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

These data will be safely, encrypted stored offline and online.

Training

Blackhole N.V.

The training and awareness program is reflected by its usage:

- A mandatory AML training program in accordance with the latest regulatory evolutions, for all in touch with finances

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The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold.

Employees shall be instructed as following:

Definition

Suspicious transaction means a transaction conducted or attempted by, at, or through the Gaming Operation that the Gaming Facility Operator knows, suspects, or has reason to suspect.

Failure to comply with the requirements of this section may constitute a violation of the reporting rules of the Curacao (formerly Netherland Antilles) Gaming Authority and will result in immediate revocation of License.

How to identify a Suspicion?

An effective systemic approach to identifying suspicious financial activity may safeguard you from the risk of being involved with terrorist financing and money laundering crimes.

S:Screen

A: Ask customer

F: Find

E: Evaluate

Each of the four steps of the systemic approach to suspicious activity identification are discussed in more detail in the following paragraphs.

Screen: Screen the account for suspicious indicators

The recognition of an indicator, or better still indicators, of suspicious activity is the first step in the suspicious activity identification system.

Large or frequent cash transaction, either deposits or withdrawals.

Ask: Ask the customer appropriate questions

If your staff carries out a transaction or transactions for a customer, bearing one or more suspicious activity indicators then they should question the customer on the reason for conducting the transaction and the

On occasions some of the staff may be reluctance to ask questions of the type mentioned above.

Appropriate questions to ask in order to obtain an explanation of the reason for conducting a transaction

Another example is when a customer receives

Persons engaged in legitimate business generally have no objection to, or hesitation in answering such questions.

If a customer is unwilling, or refuses, to answer questions or gives replies which staff suspect are incorrect or untrue, this may be taken as a further indication of the suspicious nature of the financial activity.

Find: Find out the customer

The third stage in the systematic approach to suspicious activity identification is to review the information already known about the customer and his, or her, previous transactions and consider this information to decide if the apparently suspicious activity is to be expected from the customer.

Institutions, businesses or professions hold various pieces of information on their customers which can be useful when considering if the customers

Evaluate: Evaluate all the above information.

The final step in the suspicious activity identification system is the decision whether or not to make an STR.

Staff will rarely, if ever, encounter a situation in which a customer carries out apparently suspicious activity which they have reason to suspect is linked to a specific crime or type of crime.

to give a reasonable and legitimate explanation and inconsistency between the financial activity undertaken and that which is to be expected from the customer.

What to Report in an STR?

A STR should include the following details:

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security

All data given by any user/customer will be kept secure, will not be sold or given to anyone else.

Blackhole N.V.

Money Laundering Reporting Officer (MLRO)

Blackhole N.V.

Blackhole N.V.will ensure that the MLRO is of sufficient seniority within the company and has the relevant experience and understanding of AML/CTF to carry out their duties.

The MLRO, with the support of the Board, is responsible for ensuring that the Company meets its AML compliance requirements in accordance with applicable legislation.

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- establishing the basis on which a risk-based approach to the prevention of money laundering and terrorist financing is put into practice;

- supporting and coordinating senior management focus on managing the money laundering/terrorist financing risk in individual business areas;

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The MLRO is also required to produce reports for Board meetings including, but not limited to, the following items:

- Confirmation that adequate customer due diligence information is being collected and that ongoing monitoring is taking place;

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- Number of internal consents / Suspicious Activity Reports received from staff members;

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- Confirmation that all business records have been properly stored and are retained according to regulatory requirements;

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In accordance with our license requirements Blackhole N.V.

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