# i. Abstract Wager’s Why: #### "Wager isn’t just another online gambling platform - it’s the premium sportsbook and casino experience players deserve. Built by industry leaders with 35+ years of Tier 1 expertise, we’re crafting a proprietary platform from the ground up, powered by AI-driven insights and web3 transparency. Targeting 10%+ of web3 casino gaming revenue by 2028, Wager bridges fiat and crypto, uniting casual bettors and high-stakes players in a dynamic, community-driven ecosystem." Abstract Wager isn't just redefining online gambling—it's delivering what players have been demanding: a truly premium sports betting experience backed by casino excellence. While traditional online casinos treat sports betting as an afterthought, we've built a platform with an unwavering focus on features and user experience, delivering real-time insights and dynamic betting strategies that adapt to player behavior—setting a new standard for innovation.\ \ Wager bridges fiat and cryptocurrency seamlessly, creating a platform where fair gaming complemented by **blockchain ensures transparency and trust**. With its customizable sportsbook and engaging social features, Wager sets a new standard for accessibility and player experience. Catering to all demographics, from casual bettors to high-stakes crypto players and everyone in between, the experience is at the core of what we are building, with **unlimited high speed deposits and withdrawals available daily.** Just a few of our further key differentiating features that us apart over competitors are: * **Wager’s AI Engine:** Powers a Sports Betting Assistant for tailored picks, a Casino experience that adapts to player tastes, and a CRM that predicts churn and boosts retention—all driving a 25% uplift in betting turnover. * **Crypto's First True Tier-1 Sportsbook:** The data clearly shows, only a fraction of crypto users sports bet on crypto casinos. Why? The sportsbooks lack what they need. Our bespoke sportsbook falls into the top 1% of global sports betting specific apps, built into our crypto casino. * **Blending Sports and Casino**: We've built an entirely new way to increase engagement and bet in a way that just makes sense. Stay tuned for the release of this new platform! * **Token Rewards Program:** Earn points toward our upcoming airdrop with every platform interaction. From social engagement through to deposits and wagering, every engagement increases your airdrop allocation.
The future for Wager empowers players and content creators to connect, compete, and profit in a dynamic ecosystem where streaming, social engagement, and integrated betting converge. We're pioneering a new category of entertainment that transcends traditional gambling, creating an engaging environment where community and innovation intersect. The foundations being laid now pave the way for meaningful collaboration between content creators and players, allowing unique profit sharing opportunities. Launching its presale on Ethereum in April 2025, the $WAGER token unlocks exclusive benefits like exclusive rewards, automatic VIP access, accelerated VIP progression and governance rights. Every token fuels Wager’s growth and innovation, ensuring the community remains at the heart of the platform's evolution. Join us in shaping the future of online betting. # ii. Market Analysis & Problems Addressed **Industry Landscape**\ The online gambling industry is experiencing unprecedented growth, with the global market size projected to reach USD 153.57 billion by 2030, growing at a CAGR of 11.7% (2023-2030) \[Grandview Research]. This explosive growth is driven by technological advancements, mobile gaming proliferation, and increasing acceptance of digital payment solutions.\ \ \ **Key Problems in the Market** 1. **Financial Privacy & Transaction Security:** Many online gamblers are concerned about financial privacy when using traditional banking for gambling transactions, with 54% reportedly worried about risks to mortgage applications, credit assessments, rental applications and insurance premiums. Additionally, many platforms require KYC verification, often leading to withdrawal delays of up to several days. **Wagers Solution:** * Compliance with global regulatory standards while prioritizing user privacy. * Integrated crypto & fiat payments, providing freedom to separate gaming transitions from traditional financial records, protect personal information and enjoy entertainment without repercussions. * Fast withdrawals, majority of crypto withdrawals processed instantly or up to 48 hours, reducing payout delays.
2. **Industry Trust & Security:** Endemic concerns about game fairness, data protection, and fund security. **Wagers Solution:** * Partnerships with industry-leading game providers * Transparent return-to-player rates * Provably fair gaming mechanics, allowing players to verify bet outcomes * Comprehensive regulatory compliance * Advanced security protocols * Transparent Affiliate tracking with real time dashboards and reports
3. **Market Integration Gap:** The online sports betting market ($60B) and online casino market ($70B) operate in isolation, creating inefficiencies. This data suggests that web3 casinos should have a fairly even revenue split between casino and sports, however the industry average is 20% sports revenue vs 80% casino \[periodic review of online dashboards available, sometimes as low as 10% sports], suggesting sports bettors are underserved by existing web3 sportsbooks. This gap solidifies Wager’s core offering of a sports betting solution rivaling global sportsbook leaders, tied to a premium casino platform: **Wager's Solution:** * Seamless integration of sports betting and casino gaming * Bespoke sportsbook with professional-grade features surpassing existing web3 sportsbooks * AI Trained sports betting, increasing bet frequency by up to 22% \[internal statistic]. * Real-time data integration and analytics
4. **Loyalty Program Fragmentation:** Approximately 70% of players prefer casinos with strong loyalty programs, yet most sportsbooks fail to offer integrated rewards. Wager aims to capture this gap with web3’s best sportsbook and a reward structure for both casino and sports customers. **Wagers Solution**: * Cross-platform rewards where users earn points, cashback, and VIP perks across all activities * Rewarding every player: Accumulate Wager Credits on every bet (win or lose), instantly redeemable on any casino games or sports bets * Referral and community-driven incentives * Premium VIP programs with market-leading rakeback and perks like Level Up Bonuses, VIP hosts and free spins.

Visual Analysis of VIP Progression when using Wager for sports betting and Casino gaming vs completing sports betting on third party platform over time. Uses industry standard metric of 65% casino/35% sports.

5. **Deposit and Withdrawals:** Crypto casinos often frustrate players with limited payment options and slow withdrawals, forcing a choice between preferred methods and play. Many online bettors \[67% per Statista, 2024] prefer fiat deposits over crypto. **Wager’s solution:** * Offers both fiat AND crypto payments * Wide range of crypto payments supported: 12 coins with regular additions * Processes withdrawals instantly in most cases (verification pending) - faster than most crypto-only platforms * Allows players to choose what works best for them # iii. Community In Web3, community isn’t just an add-on—it’s the backbone of long-term success. At Wager, we know that early adopters and engaged users drive real, lasting growth. While community can often be overlooked post-launch, Wager rewards participation, values user input, and ensures every member has a real stake in shaping the platform. Introducing Wager's Community-First Approach: 1. **Rewarding Early Adopters:** Few crypto casinos reward early adopters beyond basic referral programs, with few offering dedicated incentives. Wager addresses this with our Early Access Airdrop, distributing 9% of the total supply to early platform contributors. Points are earned through social engagement and platform activity (deposits, wagers), unlocking bonuses like free spins and credits. Plus, all players earn Wager Credits on every bet—win or lose—ensuring broad rewards, not just for VIPs. \ \ More information on Airdrop and points can be found [\[At this Link\] ](/whitepaper/ix.wager-airdrop)
2. **Platform Governance:** Many crypto casino users feel disconnected from platform development, with very few platforms offering meaningful governance. Wager bridges this gap by granting token holders direct voting rights on new feature implementation, development priorities, and rewards distribution modeling.
3. **Social Integration:** We hear the market when it expresses desire for more community-driven features. We understand that online gambling is rapidly shifting to a more social experience. We are implementing features from day 1 to cater to the social aspect, and have a heavy focus on building new and innovative social integrations. Included in day 1 functionality: * Share Bet URL feature for social betting: Share bets and wins with friends. One click bet placement on complex bets, with option to substitute selections. * Community Leaderboards * Engaging Tournaments * Roadmap includes a implementation of Wager's unique social gambling experience, more info TBA * Early access to new features for Discord members\ \ We have already started development on new products for periodic release, defining our place as a leader in social wagering. # iv. Platform **Players form their first impression of an online casino within 6-8 seconds** (NNGroup, 2024). A cluttered UI leads to frustration, with 29% abandoning platforms due to poor navigation and 73% preferring clean, intuitive layouts (iGaming Business, 2023). Typical online casinos/sportsbook utilize Cluttered, hard-to-navigate casinos and limited sportsbook functionality frustrate bettors, leading to poor conversion rates, missed opportunities and lower retention. At Wager Casino, we prioritize seamless navigation, useful features and AI sportsbook and casino betting integration to ensure that every user can place relevant bets without friction. This level of personalization extends beyond the sportsbook, ensuring that both sports bettors and casino players engage with content relevant to their interests—creating a faster, smarter betting experience. This leads to higher conversion rates, and up to 2.5x higher retention, and up to 22% higher betting volumes \[Juniper Research, 2023], allowing us to deliver on our objective, increasing conversion rates and moving swiftly towards our objective of surpassing market share of the leading Tier 1 crypto casinos. Wager has developed it's own platform with a team of 10 developers, UX/UI designers and designed by staff with over 35 years combined senior leadership roles in online casino and sports betting, incorporating all key requirements deemed essential to deliver the key features the web3 casino market lacks. Some key benefits of a bespoke platform are: * All source code owned by Wager * No IP leaks of proprietary tech to other casino builders customers * No platform revenue share = increased profit margins * Better deals with game providers due our existing relationships # Premium Casino Wager brings together over 1,000s of games from the industry's most popular and reputable providers, creating a complete gaming destination. You will find an immersive gaming experience with everything from classic slots to live dealer tables, all with the potential for million-dollar jackpots. We're also building something special with our own Wager Original games, including Crash Games, because we believe in creating unique experiences that differentiate. Classic slots Large selection of High RTP slots Table games Live dealers VIP Rooms and private lounges Multi-million dollar jackpots Wager site-wide jackpots Crash games Wager Original games under development * All the classic and new slots * Large selection of High RTP games * Table games * Live Dealers * VIP Rooms and private lounges * Multi-million dollar jackpots * Site wide jackpots * Crash games * Wager Originals under development
# Live Betting Wager partners with the world’s leading odds and sports data provider, Sportradar, to deliver market leading odds, data, insights and settlements. This is a critical advantage for live betting, including exclusive livestreaming rights to the NBA, delivering: * AI driven bet suggestions based on current match conditions * Real-time market data * Comprehensive match analytics * Live streaming integration * Same Game Parlay Betting * Player Props betting
# Early Payout Get instant payouts on moneyline bets when your team gets ahead by the target margin, regardless of the final score. * Applies to moneyline bets * Can be added to Same Game Parlays * Instant Settlement depending on market * Available on major sports markets * Automatic payout - no action required by user
# Wager Credits **No VIP status? No problem.** At Wager, we believe every bet should be rewarded – win or lose. As the Web3 casino that puts players first, we've revolutionized loyalty rewards by instantly crediting your account with Wager Credits on every bet you place, whether it's on the sportsbook or in the casino. These credits aren't just points – they're real value you can use immediately on any game or sports bet of your choice. \ \ Unlike traditional casinos that reserve rewards for high-rollers and VIPs, our Web3-native approach ensures every player is valued from their very first bet. This isn't just another rewards program – it's a fundamental shift in how online gaming should work, where loyalty isn't tied to VIP status but is rewarded across every level of play. Every bet, every spin, every game adds to your rewards, creating a truly inclusive gaming ecosystem where everyone wins, even when they don't. * Earn Wager Credits on every outcome, win or lose * Balance can be used immediately on any bet - casino or sports * Variable earnings depending on odds of sports bets, higher odds yield larger Wager Credits amounts * Applies to all casino games, sports betting singles and parlays
# Same Game Parlay Elevate your betting strategy with Wager's Same Game Parlay feature, allowing you to combine multiple bets from the same match into one high-value opportunity. Create your perfect parlay by mixing player props, game totals, and match outcomes – all while enjoying boosted odds and our industry-leading early payout terms. * Mix markets from the same game * Combine player props, team totals and match results * No restrictions on number of bets * Earn Wager Credits on all bets * Share bet URL for social parlay sharing
# Bet Progress Tracking Enjoy real time granular tracking of progress of exotic bets. Useful for keeping updated on in-play bets and reassessing strategies. Track bets in greater level of detail for enhanced betting experiences. * Live scores * Player props * Spread in/out of the money
# Share Bet Share winning picks with friends or followers in seconds. This feature has been designed with the typical bettor in mind. May get picks for the day from a tipping service which can take up to 10 minutes to input all selections. This process cuts bet time down by up to 90%, allowing users to place bets and move on with their day. * Bet is shared via SMS or social as a URL * One click populates draft betslip within Wager Sports * Adjust any selections before placing bets * Eliminates any manual input errors * Incentive for tipping service owners to join our affiliate program, increasing revenue
# Quick Props Experience the future of prop betting with Wager's single-page Quick Props interface, where every available player prop is instantly accessible without the endless clicking through individual games. This allows effortless scroll through all available points, assists, rebounds, and other prop markets across the entire league on one dynamic page – saving serious bettors valuable research time and ensuring you never miss value opportunities. View all league props without game-by-game navigation Quick-filter by bet type (points, assists, rebounds, etc.) Instant market comparison across all games No more back-and-forth between events * View all league props without game-by-game navigation * Quick-filter by bet type (points, assists, rebounds, etc.) * Instant market comparison across all games * No more back-and-forth between events
# Points Tracking Track your journey to rewards in real-time with Wager's intuitive Points Dashboard. Watch your points accumulate, giving you clear visibility of your progress toward securing your token supply in airdrops * Track points accumulated * Progress towards next tier unlocking additional perks * Points unlock and activate free spins and other bonuses * Track VIP progress and claim rewards * Sync Discord to display points generated externally
# Parlay Boost Parlay Boost system – where bigger parlays mean bigger rewards. As you build your multi-bet selections, watch your potential winnings soar with our dynamic odds enhancement technology. Our intelligent boost system automatically increases your odds with each additional selection added to your parlay. This means the more legs you add to your bet, the higher your potential payout becomes. It's not just about betting more – it's about earning more for your strategic plays. * Automatic boost application - no complex opt-ins required * Transparent boost calculations shown in real time * Progressive boost scaling - the more selections, the higher the boost * Available on all sports and markets * Up to 10% odds boost available
# v. Design Philosphy At Wager, we believe that exceptional user experience isn't just a feature—it's the foundation of everything we build. While the Web3 casino space has historically prioritized technology over usability, we've taken a radically different approach. Our platform is engineered with a singular focus: to provide the most seamless betting experience possible in the online gaming space. Every feature, click, and process is meticulously crafted to minimize user interactions and maximize efficiency. We measure our success not in complicated metrics, but in the seconds saved and steps eliminated from each user's journey. This relentless pursuit of simplicity drives every decision we make, from our unified betslip technology to our AI-powered personalization. Our philosophy is beautifully simple: the less time our users spend navigating the platform, the more time they can spend enjoying their gaming experience. This commitment to user-centric design isn't just about making things easier—it's about fundamentally transforming how people interact with Web3 gaming platforms.\ \ Some comparison insights on reduction in user interactions required \[based on internal testing, March 2025] to complete common bets and actions: * **Claim Bonus:** \ **83% fewer steps** than the global sports betting market leader
* **Standard Parlay:** \ **50% fewer steps** than the web3 market leader
* **Parlay with Singles:** \ **70% fewer steps** than the web3 market leader
* **Player Prop Parlay:** \ **70% fewer steps** than the web3 market leader
# vi. Tokenomics The total supply of $WAGER is set at **888,000,000 tokens.** ### Presale Structure * **Price Strategy:** The presale adopts an incremental pricing model, rewarding early participants with lower token prices. * **Stages:** $WAGER will be sold through multiple presale stages before public release. * **Private Sales:** No private sales or token sales have been conducted, ensuring a fair and transparent sale process ### Presale Timeframe * **Timeframe:** The expected duration of the presale is yet to be announced
**Fund Usage:** Funds raised through presale will go towards treasury and acquisition marketing, ensuring our aggressive yet sustainable growth trajectory can be achieved.
### Token Distribution
**Community:** The largest allocation is reserved for our community. This supply includes Airdrops, staking rewards, platform rewards, paying out customer wins who have used the $WAGER token for bets, and other incentives provided from time to time that will benefit individual holders and the community alike. **Team:** Tokens shall be allocated to the founding Team members, with reserves allocated for future team expansion and incentivization. **Presale:** Presale tokens are reserved for presale participants. There are no private sales and all holders will have a fair and inclusive opportunity to purchase tokens early at discounted rates. **Liquidity:** Liquidity is broken into two allocations, with a Liquidity Pool to be paired with ETH for funding DEX trading liquidity, and the remainder to be used as liquidity on Centralized Exchanges. \ \ **Advisors**: Allocated for early platform contributors over the past 18 months who have helped Wager evolve into the market leading betting platform. \ \ **Strategic Partners:** Allocated for individuals that will spread awareness and provide brand global recognition. This is reserved for professional athletes, music personalities and other global household figures.
# vii. Token Utility **Overview:** $WAGER serves as the native token of Wager Casino, integrating rewards, governance, and VIP benefits into a unified gaming experience. With a fixed supply of 888,000,000 tokens, $WAGER creates alignment between players, token holders, and platform growth. \ **Core Token Utilities** **Prize Pools: Rewarding Active Participation** \ A percentage of protocol revenue will be dedicated to weekly prize pool to reward active community members. Token holders gain exclusive access to dedicated weekly raffles through their wagering within the protocol. These lottery tickets, coupled with daily performance-based multiplier races creates a dual-track system that ensures both casual players and serious gamers find meaningful reward opportunities.\ \ \ **Automatic VIP Access: The Core of Wager Casino's Token Economy** \ At the heart of Wager Casino lies an innovative VIP system driven by token staking. By locking $WAGER tokens, players unlock permanent access to an expanding universe of benefits that compound with deeper platform engagement. The journey begins with token staking, which automatically qualifies players for VIP 1 status and its foundational benefits. From here, VIP members earn enhanced rewards on every bet through our rakeback system, starting at 1% and scaling up to 12.5% at the highest tiers. This isn't just another rewards program - it's a carefully crafted ecosystem where token holdings accelerate progression through exclusive multipliers based on stake size. \ \ As VIP members climb through the tiers, they unlock increasingly valuable benefits: * Enhanced Platform Access opens doors to exclusive promotions and special betting opportunities * Priority Support ensures immediate attention from dedicated service teams * VIP Competitions offer access to high-stakes tournaments with premium prize pools Most importantly, VIP status locks permanently once achieved. This creates lasting value for early supporters while ensuring long-term alignment between token holders and platform success. The system naturally encourages increased token accumulation as players seek higher multipliers and deeper platform engagement.\ \ \ **Accelerated VIP Progression:** Supercharge your Bets\ When $WAGER tokens are staked, all sports and casino bets will have an XP multiplier attached. This provides a pathway to level up through VIP tiers at an accelerated rate, providing access to generous Tier up, rank up, weekly, monthly bonuses and more. \ \ \ **Governance Rights: Shaping Platform Evolution** \ Token holders participate directly in Wager Casino's development through governance rights over: Feature prioritization and implementation Platform upgrades and strategic decisions Development roadmap direction * Feature prioritization and implementation * Platform upgrades and strategic decisions * Development roadmap direction This creates true community ownership while ensuring platform evolution aligns with user needs. **Value Accrual Mechanisms** \ Wager Casino's tokenomics are designed to create a sustainable value accrual system that directly ties platform success to token holder value. As players engage with the platform, a portion of revenue is systematically allocated to token buybacks from the open market. Rather than burning these tokens, Wager Casino takes an innovative approach by redistributing purchased tokens through the community rewards program. This creates a virtuous cycle where: 1. Platform activity generates revenue 2. Revenue drives token buybacks from the market 3. Purchased tokens flow to active community members 4. Recipients can choose to hold for VIP benefits or trade 5. New players enter the exosystem seeking similar rewards The prize pool system amplifies this value loop, with pools expanding naturally as the platform grows. Early adopters who maintain their token position benefit from increasing utility as Wager Casino reaches new revenue milestones and unlocks additional reward tiers. The system is designed for long-term sustainability, focusing on reward distribution rather than token burns. This ensures a healthy token velocity while maintaining strong holder incentives through the VIP program and governance rights. By directly linking platform growth to token holder benefits through buybacks and reward distribution, Wager Casino creates natural demand for $WAGER while avoiding short-term price manipulation mechanics. # vii. $WAGER Airdrop Welcome to the comprehensive overview of The **Wager Bounty Airdrop & Community Rewards Program**. This page provides a detailed breakdown of our points system, reward tiers, and token distribution structure. At Wager, we understand that our community is the backbone of our success. That's why we're excited to announce our comprehensive Community Rewards Program, designed to recognize and reward the early supporters who help shape the future of Web3 gaming. ### **Program Highlights:** * **Points Campaign Start Date:** March 2025. * **Total Airdrop Allocation:** 9% of $WAGER token supply * **Instant rewards:** including cash prizes, free spins and bonus bets * **Top Performers Recognition:** Our leaderboard system rewards the most active community members with up to 2.5% of the total token supply for the #1 position, with attractive allocations for the top 10 participants, with remaining to be distributed amongst all participants. We believe in complete transparency and want our community to fully understand the opportunities available. Below, you'll find detailed tables outlining every way to earn points, from social engagement to platform participation, along with the corresponding rewards.
### Stage Overview Our program is structured across three main phases, with points and rewards accelerating as the campaign progresses: 1. **Awareness** 2. **Presale** 3. **Growth (Platform Usage)** Each phase offers unique opportunities to earn points, with rewards including: * **Free spins** * **Bonus bets** * **Deposit matches** * **Cash prizes**
Participate in social campaigns and referral programs to earn your first points and free spins with zero investment required. Weekly referral leaderboards offer a tangible opportunity to gain large points and rewards. **Earn up to 25 Free Spins for simply completing social quests.** \ \ Awareness [Quests can be completed by visiting Zealy.](https://zealy.io/cw/wagercasino/questboard/admin)
Presale participants receive exponentially increasing platform rewards and additional points. Offer is valid for all stages of the presale & private sale. **Earn up to 500 Free Spins for participating in the presale**\
Platform users earn further accelerated rewards through deposits and wagering volume, with opportunities to **earn guaranteed bonuses: up to 175,000 points and 600 free spins** for active players. Exciting multiplier challenges offering cash prizes up to $2,500, providing an equal opportunity for players with any bet size. Important Notes: * Platform rewards can be redeemed immediately upon platform launch * Referral competitions reset weekly * [Link to Airdrop Quests](https://zealy.io/cw/wagercasino/questboard/admin) (Awareness Phase) # ix. Legal & Compliance ### Regulatory Compliance Our Foundation for Trust At Wager, regulatory compliance isn't just a checkbox – it's fundamental to our operations. We've developed robust frameworks that meet and exceed industry standards for player protection and financial security. Our Comprehensive Compliance Framework: \ • Know Your Customer (KYC) \ • Anti-Money Laundering (AML) \ • Anti-Terrorism Financing (ATF) \ • Responsible Gaming Protocols \ • Data Protection & Privacy\ \ [\[View our compliance documentation\] ](https://docs.wagercasino.io/whitepaper/pages/vh7BOZwLlU8J5VSn83xA#id-1.-part-b-kyc-and-aml-atf-program)
### License and Registration Operating under our Anjouan gaming license, we've implemented stringent verification processes that protect both our players and platform integrity. Our policies align with global regulatory standards providing a safe and enjoyable environment for players. \ \ Wagercasino.io is owned and operated by Longhorn Capital Inc, registration number 2165538, registered address: Intershore Chambers, Road Town, Tortola, British Virgin Islands. Contact us at . Wagercasino.io is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros and operates under License No. ALSI-202502044-F12. Wagercasino.io has passed all regulatory compliance and is legally authorized to conduct gaming operations for any and all games of chance and wagering.
# x. Revenue Forecasts In an industry where experience and execution are paramount, Wager stands uniquely positioned to capitalize on the exponential growth of the online gaming market. Our financial projections for the next three years are built on concrete fundamentals: proven leadership, established networks, and battle-tested strategies that have consistently delivered billion-dollar results. Our executive team represents the elite of the online gaming industry, with each key position filled by veterans who have shaped the success stories of Tier 1 operators. Our sales and marketing leaders have each individually driven $1B USD in annual revenue through their respective channels, while our Chief Operating Officer has demonstrated the ability to scale sports betting operations to +$1B revenue within their first year. The foundation for immediate revenue generation is already in place. Our Head of Affiliates brings a forecasted network value of $200M USD once fully activated, enabling significant Day 1 revenue without heavy initial marketing investment. This network, combined with our team's expertise in SEO, PPC, and conversion rate optimization, creates a multi-channel approach that maximizes every marketing dollar. The following forecast demonstrates how our experienced leadership team will leverage these advantages to establish Wager as the next Tier 1 online casino, with projections that reflect both our ambitious vision and our proven ability to execute
# xi. Disclaimer This whitepaper is for informational purposes only and does not constitute investment advice. Participants should consult their financial advisors before making any investment decisions. Wager Token is a meme coin and not a security in any way, shape or form. \ \ Investing in cryptocurrency carries risk, particularly meme coins. Cryptocurrency regulations vary significantly from one jurisdiction to another. The legal status of cryptocurrencies, tokens, ICOs and other digital assets is currently undefined and/or changing in many countries. \ \ It is your responsibility to determine if you are permitted by law to invest in Wager Token and/or participate in the blockchain ecosystem based on your nationality, residency or any other consideration. \ \ The team behind Wager Token does not guarantee any profits and shall not be held liable for any price movements, whether increasing or decreasing in value, or any loss of investments. Participants shall only purchase $WAGER token with legal tender or other cryptocurrencies accepted in the Wager Token Presale. \ \ All entities and individuals are forbidden from using $WAGER token for any illegal activity. \ \ This whitepaper, along with its cryptocurrency token and website may not comply with UK Crypto Regulations, making it unsuitable for UK Investors or audiences. Readers from the UK should be aware of this restriction and take appropriate action. The offer to the public of $WAGER does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or \ other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law # KYC/AML/ATF Policy !\[A black and white logo Description automatically generated]\(; \ WagerCasino.io ### Know Your Customer, Anti-Money Laundering and Anti-Terrorist Financing Program 1. **Document Details** | Document Owner: | WagerCasino.io | | ------------------------------------------------- | ------------------------------------------------------- | | Document Number | 1.0 | | Approved by: | Brendon Dorff | | Any questions or suggestions about this document? |

AML/ATF Compliance Officer

KYC CRM Manager

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| 2. **Version Control** | Version | Date | Notes | | ----------- | ----------------------------------- | -------------- | | 0.1 |

September 1, 2024


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## 1. Part B KYC & AML/ATF Program ### 1.1 About this document This document comprises the Anti-Money Laundering & Anti-Terrorism Financing Program (KYC & AML/ATF Program) implemented by WagerCasino.io (“WagerCasino”). ### 1.2 Introduction WagerCasino offers online sports betting on market linked sporting events to registered users. ### 1.3 Designated Services WagerCasino provides the following ‘Designated Services’ which are covered by this KYC & AML/ATF Program | Item 1 | receiving or accepting a bet placed or made by an identified person, where the service is provided in the course of carrying on a business | | ------ | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Item 2 | placing or making a bet on behalf of a person, where the service is provided in the course of carrying on a business | | Item 3 | introducing a person who wishes to make or place a bet to another person who is willing to receive or accept the bet, where the service is provided in the course of carrying on a business | | Item 4 | paying out winnings in respect of a bet, where the service is provided in the course of carrying on a business or known individual. | | Item 5 |

accepting the entry of a person into a game, where:

(a) the game is played for money or anything else of value; and

(b) the game is a game of chance or of mixed chance and skill; and

(c) the service is provided in the course of carrying on a business; and

(d) the game is not played on a gaming machine located at an eligible gaming machine venue

| | Item 6 |

paying out winnings, or awarding a prize, in respect of a game, where:

(a) the game is played for money or anything else of value; and

(b) the game is a game of chance or of mixed chance and skill; and

(c) the service is provided in the course of carrying on a business; and (d) the game is not played on a gaming machine located at an eligible gaming machine venue

| | Item 7 |

in the capacity of account provider, opening an account, where: (a) the account provider is a person who provides a service covered by item 1, 2, 3, 4, 6 or 7; and

(b) the purpose, or one of the purposes, of the account is to facilitate the provision of a service covered by item 1, 2, 3, 4, 6 or 7; and

(c) the service is provided in the course of carrying on a business

| | Item 8 |

in the capacity of account provider for a new or existing account, allowing a person to become a signatory to the account, where:

(a) the account provider is a person who provides a service covered by item 1, 2, 3, 4, 6 or 7; and

(b) the purpose, or one of the purposes, of the account is to facilitate the provision of a service covered by item 1, 2, 3, 4, 6 or 7; and

(c) the service is provided in the course of carrying on a business

| | Item 9 | in the capacity of account provider for an account, allowing a transaction to be conducted in relation to the account, where: (a) the account provider is a person who provides a service covered by item 1, 2, 3, 4, 6 or 7; and (b) the purpose, or one of the purposes, of the account is to facilitate the provision of a service covered by item 1, 2, 3, 4, 6 or 7; and (c) the service is provided in the course of carrying on a business | As an agent of Anjouan, WagerCasino has obligations under the Proceeds of Crime Money Laundering and Terrorist Financing Act (PCMLTFA) to comply with the AML/ATF Act. As well as KYC (Know Your Customer) requirements as set by the Financial Action Task Force (FATF) as well as local jurisdictions. Any reference to the reporting entity, ‘WagerCasino or ‘we / us / our’ in this Program is a reference to WagerCasino and any party discharging WagerCasino’s obligations under the KYC & AML/ATF Act on behalf of WagerCasino. ### 1.4 Customer Due Diligence WagerCasino users are all individuals. WagerCasino verifies user identity via iD3Global & GBG verification software or many other intentionally approved services, approved by the jurisdiction we are operating in. Customer Due Diligence (CDD) has two elements: * Collection of information about the user; and * Verification that the user is the person named in the information material (KYC) The CDD procedures must enable WagerCasino to: * be reasonably satisfied that an individual user is who he or she claims to be; and * establish whether and to what extent any additional CDD information needs to be collected and /or verified; and * determine what kind of electronic data is reliable and independent for verification purposes; and * respond to discrepancies which may arise when verifying information about a user. ## 2. Procedures ### 2.1 Risk assessment Objective of Player Risk Assessment: * To assess a Player's ML/TF risk * To determine the level of due diligence required with identified level of risk * To determine frequency for ongoing monitoring and player information update * To ascertain the level of management approval required * To help Regulator manage risk mitigation strategies for sector WagerCasino has adopted a four-tiered risk classification of users and transactions: * low risk * moderate risk * high risk * extreme risk WagerCasino uses the local government and jurisdiction ‘Player risk-scoring methodology’ for Player Risk Assessments where appropriate. Risk factors are based on the Player information, behaviour, transactional and investigative data on the account. WagerCasino completes the Player Risk Assessment Scoring Model for each player to substantiate the rating assigned at the point of Player Account Registration and on an ongoing periodic basis to verify any potential changes. WagerCasino assigns a risk rating of **extreme, high, moderate or low** based on the player profile information provided and through the assessment of preconditions and other risk factors relevant to each player. Based on this information, the Player Risk Assessment Scoring Model generates a risk score and assigns a corresponding risk rating for each player. A user is automatically identified as “high risk” if: * user is a Foreign Politically Exposed Person (PEFP) * user is a resident of a high-risk country * user has an association to a high risk occupation and lifetime deposits are greater than €5000 * user has 2 or more Suspicious Transaction Reports (STR) submitted to FINTRAC, AUSTRAC or appropriate agency. A user is automatically identified as “extreme risk” if: * user is barred from local casinos for money laundering and/or terrorist financing reasons * user is considered to be a public safety risk * user is known to be affiliated with organized crime as confirmed by law enforcement * user is a positive match to a sanctions or terrorist list Any user identified as ‘high risk’ or ‘extreme risk’ by meeting any of the above criteria and any user relationships terminated by WagerCasino due to ML/TF concerns will be reported to the appropriate government body via the “Player High Risk List”. Furthermore, when a new ‘extreme risk’ user is identified, WagerCasino will notify the governing body in an appropriate agreed time frame. In identifying its Money Laundering/Terrorism Financing (ML/TF) risk WagerCasino will consider the risk posed by the following factors: * its user types; including:\ \- any politically exposed persons; * its users’ sources of funds and wealth; * the nature and purpose of the business relationship with its users, including, as appropriate, the collection of information relevant to that consideration; * the types of designated services it provides; * the methods by which it delivers designated services ### 2.2 Customer identification requirements Customer identification consists of two elements: 1. collection of identity information; and 2. Verification of information. The procedures set out in this document apply to the collection and verification of user identity information of new users. The procedures must be undertaken before the provision of a Designated Service to the user. ### 2.3 Customer type WagerCasino only provides Designated Services to individuals and therefore these procedures only cover that customer type. ### 2.4 Appointment of Agents From time to time, WagerCasino may appoint agents to assist us with discharging our obligations under the KYC & AML/ATF Acts. Our appointed agents will be responsible for the conduct of all their staff (regardless of the nature of the relationship between the agent and the staff member) ### 2.5 Procedure for the collection and verification of customer identification information * WagerCasino collects data at the account registration stage to confirm the "user type" is an individual as per 2.3 above. WagerCasino only deals with individual clients. * The WagerCasino registration process collects the information as set out in Section 3.1.1 and records the information. * The information recorded is then checked and verified using iD3Global, GBG or equivalent. * If the user is assessed as being of ‘high’ or ‘extreme’ risk, the enhanced customer due diligence requirements (collection and verification) as set out in Section 4 must be undertaken. Unconditional approval to allow the user commence betting will not be given until WagerCasino are satisfied that the user's identity has been satisfactorily verified. ### 2.6 Retaining documentation WagerCasino will retain a copy of: 1. a record of the procedure to identify a user; and 2. any information obtained in the course of identifying or attempting to identify a user for at least:\ \- seven years after the document is provided if no Designated Service is provided to the user (e.g. if the user does not engage in trading); or\ \- seven years after the end of the last Designated Service provided to the user (e.g. seven after a product is traded). Any agents appointed by us may also retain a copy of the information obtained in the course of identifying a user. ## 3. Player Identification ### 3.1 Collection of information by WagerCasino WagerCasino will collect the following information about individuals at the time of account registration. If the Player’s identity is not verified in a manner that complies with WagerCasino policy, the account cannot be created. WagerCasino will retain all the records in the Player Account. #### 3.1.1 Collection of information (KYC)
### 3.2 Verification of individuals WagerCasino will undertake electronic verification using approved identification company id verification software integrated with the WagerCasino platform and will risk rate all players within 30 days of player registration using the player risk assessment methodology. **3.2.1 Procedures for Electronic Verification** a) The WagerCasino platform will collect the information as set out in Section 3.1.1 and verify the information using the dual-process method. b) Information will be collected and verified from any of the 2 categories and must match the information provided by the Player at registration (see Section 3.1.1);\ (i) Documents that contain Player name and date of birth\ (ii) Documents that contain Player name and address or\ (iii) Documents that contain Player name and confirms they have a deposit account, credit card or other loan account with a financial entity c) The sources of information must be: \ (i) Valid and current\ (ii) Reliable, trustworthy and well-known such as federal, provincial, territorial or municipal levels of government, crown corporations, federally regulated financial institutions or utility providers\ (iii) The two sources of information must be different and independent of each other\ (iv) An electronic scanned copy of document can be used d) Where required the user may be required to enter additional information that may include passport number, drivers license and other information or a scanned copy of such document. e) Users must accept using these databases. WagerCasino has outlined the use of Electronic Verification in Terms and Conditions. f) The on-line electronic identification verification provider will either:\ (i) confirm the identity of the individual from at least two separate data sources\ (ii) advise WagerCasino that they are unable to verify the player identification of the individual and account registration will be denied g) WagerCasino will retain a record of the original response from the electronic verification provider used to identify the individual for seven years and will make the following information available upon request to the appropriate body:\ (i) Player’s full name\ (ii) Date of identity verification\ (iii) Name of the 2 different sources used to verify identity\ (iv) Type of information referred to (e.g. utility statement, bank account info, marriage certificate, etc.)\ (v) Account or reference number associated with each independent source\ \ **3.22 Third Party Determination** WagerCasino will not allow any third party transactions including opening an account OR conducting a transaction on behalf of a third party. WagerCasino will make a third party determination by taking the following steps: a) At the time of account registration, Player must confirm whether they are acting on behalf of another individual b) Player must confirm whether they are acting on behalf of another individual at the time of a transaction trigger including:\ (i) Making a disbursement of €10,000 or more to the player that requires a Casino Disbursement report (CDR)\ (ii) Receipt of cash of €10,000 or more for deposit into the player’s igaming account that requires the submission of a Large Cash Transaction Report (LCTR)\ (iii) An International Electronic Funds Transfer (EFT) of €10,000 or more is made that requires the submission of an Electronic Funds Transfer Report (EFTR) Where applicable\ \ WagerCasino will continue to monitor player activities and transactions for any behaviour that is suspicious and is a potential indicator of ML/TF activity as outlined and requires the submission of a Suspicious Transaction Report (STR) where required. If a Third Party event is identified, WagerCasino will take reasonable measures to obtain and retain information on the third party including: 1. Full name including middle name or initial 2. Alias/preferred name 3. Full address (not a PO Box or general delivery mailbox) 4. Date of birth 5. Email address 6. Personal telephone number 7. Descriptive occupation 8. Country of residence 9. Citizenship 10. Employer’s name, telephone number and address 11. Relationship between player and third party 12. Person web address 13. Documentation to identify the person such as number associated with information; jurisdiction and country of issue of documentation; expiry date of documentation * WagerCasino will NOT allow player to open account or for transaction to proceed * WagerCasino will submit Suspicious Transaction Report (STR) * WagerCasino will retain all pertinent information relating to third party activity including description of reasonable grounds to suspect such activity #### 3.2.3 Politically Exposed Persons and Head of an International Organization See Appendix A for Definitions of PEP/HIO and Examples 3.2.3.A WagerCasino will take measures to determine whether a player is a PEP or HIO or related person (see Appendix A for definition) at the point of Player Registration and if any of the following events occur: 1. Initiation of an international EFT of €100,000 or more on behalf of a player 2. Receipt of an international EFT of €100,000 or more on behalf of a player 3. Periodic monitoring of existing igaming account holders 4. When WagerCasino detects a fact about an existing account holder that indicates a PEP or HIO connection WagerCasino will take the following reasonable measures to determine if a player is a PEP/HIO or related person: a) Player Attestation – WagerCasino requires all players to attest to whether they are a PEP/HIO or a related person at the point of account registration and at any point a trigger event takes place as per Section 3.2.3A b) Name Screening – WagerCasino will screen all player names against the Government Register PEP/HIO database at the point of player registration and on a monthly basis thereafterc c) Ongoing Monitoring – WagerCasino will review all players for a possible PEP/HIO match when there is an update in the specific government database or if the player updates his/her identification information. Furthermore, WagerCasino will monitor domestic and world events for information that may pertain to new/changed PEP/HIO and screen against existing player lists to identify. If WagerCasino has reasonable grounds to suspect that a player is a PEP/HIO or related person, additional checks will be performed as outlined as per Enhanced Due Diligence (Section 4). All documentation to support these measures will be retained by WagerCasino in the player’s account and will be available to the governing body upon request. **3.2.4 If PEP/HIO is Identified** If the Player is identified as a PEP/HIO (either domestic or foreign) or a related person, due to any of the above (Section 3.2.3 #1, 2 or 3), the following information will be collected and retained by WagerCasino: a) Source of Funds and Source of Wealth - to make this determination, the appropriate field is included at the point of self-identifying as a PEP/HIO. Further research will be conducted via public information portals to verify source of funds. b) Position Description of PEP/HIO c) Name of organization of PEP/HIO d) Description of nature of relationship – e.g. if related person, must define nature of relationship All players identified as PEFP or a related person, will be deemed High Risk and EDD measures in Section 4 will come into force. All players identified as PEP/HIO or related person, will be assessed using other factors in the Player Risk Assessment review (see Section 5). WagerCasino will maintain a database of players identified as PEP/HIO or related person and provide a list of all players identified as High Risk to iGO on a quarterly basis and of all players identified as Extreme Risk within 24 hours of identification. (See Appendix J for Regulatory Reporting Timelines)
**Senior Management Approval** WagerCasino will do the following upon identification of a PEP/HIO or related person: a. WagerCasino Senior Manager (CEO, CCO or COO) will approve/deny account registration for identified PEP/HIO or related person within 30 days of determination b. WagerCasino Senior Manager (CEO, CCO, COO) to review specific event as per 3.2.3 within 30 days All details regarding name of Senior Manager who provided approval/rejection of account and date of approval/rejection to be maintained in player record. ## 4. Enhanced User Due Diligence ### **4.1 Procedure** Enhanced user due diligence procedure will be applied where: * it has been determined that the level of KYC & ML/TF risk associated with the provision of a designated service to the user is ‘high’ or ‘extreme’; * where the user is a PEP/HIO or related person; * where there is a discrepancy in the information provided by the user (or a discrepancy between the information provided by the user and the information revealed by our independent verification processes and cannot be reconciled with additional requests); * where a ‘suspicious matter report’ has been made about the user (within 14 days from when the suspicious reporting obligation first arose); or A more detailed analysis of the player’s information including, where appropriate, * clarifying or updating or re-verifying information already collected; or * collecting and verifying additional information including, where appropriate taking reasonable measures to identify A more detailed analysis of the player’s transactions – both past and future, the expected nature and level of transaction behaviour. For players identified as Extreme Risk, a member of WagerCasino Senior Management (one of CEO/CCO/COO) will approve the termination of the business relationship immediately upon Extreme Risk identification. All information pertaining to this transaction will be retained by WagerCasino. For players identified as High Risk either at registration or during periodic reviews, WagerCasino will conduct EDD and retain all documentation in the player account. High Risk players will be reassessed every 6 months as part of the ongoing monitoring procedure. See Section 6. #### **4.1.1 Enhanced Due Diligence Measures** For any player identified as Extreme or High Risk and where a balance of €100,000 or more is deposited into the player’s WagerCasino account, EDD must be conducted within 30 days of account registration the Head of Risk and Fraud, CFO or Equivalent EDD will consist of the following and will be documented on the EDD Checklist form: * date of EDD performed * player identification details (as per 3.1.1) * date the player was last reviewed and risk assessed * confirm player information is up to date * confirm that player activity on WagerCasino platform is continuously monitored * conduct oper source searches to confirm occupation (via social media, online news) and retain documentation * confirm source of funds (see Appendix H) * document any additional measures if taken Senior management approval (one of CEO/CCO/COO) must then be obtained before WagerCasino provides a designated service to the player and whether WagerCasino will continue to have a business relationship with the player. Continued monitoring of activity by players assessed as ‘high’ risk to take place every 6 months. All documentation pertaining to any EDD activity to be retained in the player account. ### 4.2 Sanctions Name Screening WagerCasino will conduct name screening of all registered players against the PEP list upon registration and then on a monthly basis for the duration of the relationship with the player and then for a period of 5 years from the date of account closure/termination. See appendix for databases of Sanctions List that WagerCasino will use to screen players. #### **4.2.1 Name Screening Process:** a. WagerCasino will use all of the identification information provided by the Player to identify positive matches to names on the Sanctions Lists (See Appendix C). See Appendix D for information to be considered to determine if the player's name is a match or not with name on Sanctions List. b. If not a match, WagerCasino will record rationale supporting determination c. If it is a positive match to PEP/HIO list, WagerCasino will follow the procedure described in Section 3.2.4 d. If it is a positive match to a terrorist list, WagerCasino will:\ i. Immediately freeze the account\ ii. Generate a Terrorist Property Report (TPR) for submission to FINTRAC or appropriate body.\ iii. Designate one of the CEO/CCO/COO whose authorization is required to unfreeze the account #### 4.2.2 Record Keeping for Name Screening: WagerCasino will maintain all records pertaining to the name screening process at the point of registration and on an on-going basis no matter the result (e.g. even if the result is not a positive match). All documentation and rationale for assessment will be retained in the player account.
#### **4.3 Ministerial Directives:** WagerCasino will comply with the Ministerial Directives currently in force and with any future Ministerial Directives issued by the Minister of Finance under the provision of the local jurisdiction. WagerCasino will be notified by the CAMLO at iGO of the issuance of a new directive by the Minister of Finance and comply with all measures indicated in a timely manner as specified by CAMLO. Current Ministerial Directives in force include: * Every financial transaction originating or bound from either Islamic Republic of Iran or Democratic People’s Republic of Korea to be identified as HIGH RISK and will follow all mitigating measures provided See Appendix E for Mitigating Measures for all current Ministerial Directives ## 5.0 Risk Assessment Framework: Player Risk Assessment: Using the appropriate Player Risk Assessment methodology, WagerCasino will assess and risk rate all players within 30 days of account registration and periodically throughout the existence of the players’ account with WagerCasino. See Section 6 for frequency of ongoing monitoring. The objectives of Player Risk Assessment are: 1. To assess risk of ML/TF 2. To determine level of due diligence required for player’s identified level of risk 3. To determine frequency for ongoing monitoring including updating of player information 4. To determine level of management approval required 5. To help the Regulator manage risk mitigation strategies with WagerCasino
### **5.1. Automatic Extreme Risk Players** The following factors trigger an automatic Extreme Risk rating: 1. Players with history that indicates previous ML/TF activity from local casinos 2. Players confirmed by law enforcement to be part of or affiliated with Organized Crime 3. Players positively matched to a Sanctions List or Terrorist List Any player identified as Extreme Risk as per the above will be evaluated by WagerCasino Senior Management (one of CEO/CCO/COO) for direction to terminate the player account upon execution of Enhanced Due Diligence, within 30 days of the date of knowledge of this information. The name of any player identified as Extreme Risk will be added to the Player High Risk List report and submitted to the local regulator immediately (within 24 hours of identification). WagerCasino will retain all supporting documentation for determination of risk assessment, senior management decisions and provide to iGO upon request.
### **5.2 Automatic High Risk Players** The following factors trigger an automatic High Risk rating: 1. Foreign Politically Exposed Person, their family and/or close associate (see Appendix A for list of PEP/HIO) 2. Connection to high risk country (see Appendix F for list of countries considered high risk)\ i. If player is resident of or associated with high risk country\ ii. Funds sourced from or sent to high risk country 3. Player associated with high-risk occupation such as cash intensive businesses (see Appendix G for non-exhaustive list of high risk occupations) 4. Players where 2 or more Suspicious Transaction Reports (STRs) have been filed to FINTRAC. If this occurs after player account has been operational, then player risk assessment must be automatically changed to High Risk
### **5.3 Extreme and High Risk Player Assessment Reporting** WagerCasino will report all players identified and Extreme Risk, High Risk and accounts terminated due to KYC failure or ML/TF suspicions to iGO via the Player High Risk List. As per 5.1 all players automatically identified as Extreme Risk and those identified as Extreme Risk by the Player Risk Assessment will be reported to iGO within 24 hours of risk determination. WagerCasino will provide a complete list of all players identified as High Risk and Extreme Risk quarterly as per the local Regulators schedule (see Appendix J for Regulatory Reporting Timelines). ### **5.4 Enhanced Due Diligence (EDD)** WagerCasino will apply EDD for all players identified as Extreme or High Risk. For players identified as Extreme Risk, WagerCasino will follow the procedure as per section 5.1 and all documentation will be retained in the Player Account including EDD (see EDD Checklist in Section 5.5). For players identified as High Risk, WagerCasino will conduct EDD at registration and periodically (every 6 months as per Section 6.0) and all documentation will be retained in the Player Account including EDD (see EDD Checklist in Section 5.5). ### **5.5 Enhanced Due Diligence (EDD) Checklist** For all players identified as Extreme and/or High Risk, WagerCasino will complete the following checklist at registration and every 6 months thereafter ensuring all documentation is retained in the player account. EDD will also be conducted where a balance of €100,000 or more is transferred to the player's WagerCasino account within 30 days of transaction. Upon identification of a player as either Extreme or High Risk or where there is a transaction/transfer of €100,000 to a player account, a member of WagerCasino Senior Management (one of CEO/CCO/COO) will review EDD Checklist form and approve/deny account registration for players identified as High Risk. WagerCasino will deny account registration for any player identified as Extreme Risk The EDD Checklist will include the following: * Date of EDD performed * Player identification details (as per Section 3.1.1) * Date the player was last reviewed and risk assessment result * Confirm player information is up to date * Confirm player activities on WagerCasino are continuously monitored * Conduct open source searches to confirm player details and retain search details in player account * Confirm Source of Funds (see Section 5.6) * Document any additional information or measures taken
### **5.6 Source of Funds** For all players identified as Extreme and/or High Risk, as well as where a balance of €100,000 or more is transferred to the player WagerCasino account, WagerCasino will conduct EDD to determine source of funds. WagerCasino will: 1. Ask players to provide information regarding the source of funds. Section 3.1.1, question 5 asks the player’s occupation but for EDD purposes, WagerCasino requires more detailed information. If the explanation is not satisfactory, WagerCasino will request proof such as bank statement, pay stub, etc to support explanation/source of funds. 2. Conduct open source searches to confirm player’s occupation such as social media (LinkedIn, Facebook, Twitter, TikToketc.) and any publicly available news/announcements. Results of all such searches will be retained in player account 3. For all players identified as High risk, continued monitoring and updating of player information, including EDD, will be conducted every 6 months automatically, and more periodically. But also manually when funding fluctuates outside the player norm and could be deemed suspicious.
## 6.0 Ongoing Monitoring After onboarding, WagerCasino will continue to monitor all players to ensure that all player information is accurate and up to date and also to monitor player activity to detect any unusual and/or suspicious activity. Players will be reassessed and profile will be updated on the following schedule: a) High-risk player – reviewed every 6 months b) Moderate-risk player – reviewed annually c) Low-risk player – reviewed every 2 years A notification will automatically appear at intervals a/b/c depending on player risk assessment for player to review profile information, make required updates, if necessary and confirm veracity of information. All information to be retained in the player account. WagerCasino must ensure any updates align with player risk assessment and re-assess if necessary. Periodic assessment review will include: * Any update in player identification information * Result of name screening scan * Details of any regulatory filings on player (UTR/STR/etc) * Ongoing transaction monitoring is being conducted on time * All open source searches conducted If a player is identified as Extreme Risk, immediate notification must go to a) WagerCasino Senior Management/Board of Directors and b) iGO AML Unit for review and determination of next steps. Once registered and approved by WagerCasino, all player names will automatically be screened monthly through approved id verification software to ensure PEPs/HIOs/sanctioned people are identified. If there is a positive match, procedure described in Section 3.2.4 to be followed. ### **6.1 Ongoing Transaction Monitoring** All Player information is verified upon signup through the stringent GBG process known as Green ID and meets International KYC requirements. Though the onus is on the customer to keep this information up to date, if WagerCasino are aware of any changes (email bouncing back, or call not connecting) we will suspend the account and contact the customer immediately. WagerCasino would be looking for suspicious transactions which may be greater than €10,000. But more significantly when a Player’s pattern changes. When a $10 bet Player moves to an average bet size of $100. Or when a Player pattern deviates from a deposit of $300 every Friday, suddenly shifting to $1,500 deposit or frequency of those deposits change. Player accounts are always monitored in real time, as well as periodically through process checks which could be daily (2am each day) as well as weekly.WagerCasino will exceed any Regulators expectations when it comes to assessing the level of risk for a Player, as we do this on a daily basis. As well as all transactions and activities of a Player’s. Again done in real time and on a daily basis as well as via reporting processes.
## 7.0 Training WagerCasino will use approved KYC & AML/ATF training modules administered virtually. Training is required for all WagerCasino employees associated with AML/ATF: * upon hire and prior to commencement of job duties * upon return from Leave of Absence (e.g. parental leave) * upon transfer to AML/ATF associated role * senior management and board of directors * as a refresher course annually thereafter for all AML/ATF associated roles and senior management/board of directors WagerCasino’s Chief Compliance Officer (CCO or COO) is responsible to ensure that all WagerCasino employees associated with AML/ATF, including senior management, fulfil the training program and achieve a minimum score of 80% on AML/ATF Training Test as provided by iGO. Culminating tests will be administered via email and reviewed/graded by CCO. Failure to complete the test successfully in 3 attempts will result in CCO assessing responses and identifying weaknesses to employees who will be required to take the test again until a passing score of 80% is achieved. Complete record of training and testing to be retained by CCO for 7 years including: * training dates * training materials used * length of training session(s) * method of delivery * employee name and job title * confirmation of attendance (signed acknowledgement by employee) * testing dates * testing scores * any other relevant information ## 8.0 Regulatory Reporting WagerCasino notes that all dollar amounts refer to Euro currency or its equivalent in foreign currency and will determine reportable thresholds based on current XE.com exchange rates. WagerCasino has appointed 3 Data Entry Officers (DEOs) responsible for compiling regulatory reports to be submitted to iGO who in turn will submit them to FINTRAC via the secure web reporting system (F2R). They are: * WagerCasino CEO * WagerCasino CFO * WagerCasino COO See Appendix J for summary of Regulatory Reporting Timelines and Method. ### **8.1 Suspicious Transaction Report (STR)** WagerCasino employees will be trained to identify suspicious activity upon hire using the Suspicious Indicators resource (see Appendix I). If a WagerCasino employees knows or suspects that a player is involved in ML/TF activity, they will generate an Unusual Transaction Record (UTR) which includes the following information: * Unique report identifier number for the UTR ∙ Date of UTR creation ∙ UTR creator name ∙ UTR creator position/job title ∙ Source of referral (e.g., transaction analysis, employee report, Player compliant, etc.) ∙ Unusual/suspicious indicator ∙ Indicator whether transaction was attempted or completed ∙ Transaction date, amount, currency, exchange rate ∙ Player first name, last name, igaming account number, AML risk rating ∙ Investigation steps - document what investigation actions were taken ∙ Supporting documentation - List documents supporting the investigation such as email correspondence, transaction analysis ∙ Resulting action of investigation (e.g., verified, no suspicious activity noted; Suspicious activity noted and STR created) ∙ Provide rationale for STR submitted or not submitted and the date of decision ∙ Assess whether Player risk level requires reassessment based on the decision and record if there was a change or not in the risk rating ∙ Document if an STR was created or not ∙ STR reference number (if applicable) ∙ STR creation date (if applicable) NOTE: All UTRs will be compiled in UTR log, maintained by the Compliance Officer and provided to iGO upon request. The WagerCasino employee will refer each UTR to one of the CEO/CCO/COO for review and they will determine if the case requires escalation to generate a STR. Factors to be considered in this determination are: * Assessing the facts and context surrounding the suspicious transaction * Linking ML/TF indicators to the assessment of the facts and context * Screening for and identifying suspicious transactions * Providing explanation for suspicion of STR If it is reasonable to suspect ML/TF activity, WagerCasino CEO/CCO/COO will create a comprehensive and complete STR as per local Regulator or Governing Body, this applies to both transactions and attempted transactions, and provide all necessary reports. WagerCasino CEO/CCO/COO will refer to “Suspicious Transaction Report (STR)”. See Appendix K for guidance on conducting investigation for UTR/STR. Given our experience in the highly regulated Australian Industry, our solid approach to KYV ML/TF indicators, WagerCasino are confident in identifying STRs of any monetary value no matter how small or large. We understand it's about looking at the whole picture and not just a single transaction. Given we are able to build a very clear profile of our customers, from average deposit, deposit time lines as well as betting averages, win rates and withdrawal sequences it means the moment a customer steps outside those norms we want to know from a Responsible Gambling perspective, Business perspective as well and just as importantly from a STR perspective which WagerCasino will immediately report to any Regulator as required. ### **8.2 Electronic Fund Transfer Report (EFTR)** WagerCasino will report all player requested EFTs that fall within the following: * Outgoing EFT in the amount of €10,000 or more leaving the jurisdiction either in a single transaction OR in multiple transactions that total €10,000 or more within a 24-hour period (gaming day)\ \- WagerCasino will generate an Electronic Funds Transfer Report (EFTR) \ \- All EFTRs will be kept for 7 years from date created * Incoming EFT in the amount of €10,000 or more outside of the jurisdiction either in a single transaction OR in multiple transactions that total €10,000 or more within a 24-hour period (gaming day)\ \- WagerCasino will generate an Electronic Funds Transfer Report (EFTR) \ \- All EFTRs will be kept for 7 years from date created WagerCasino will employ the EFT Travel Rule and ensure the following information is included with information sent or received in an International EFT (either outgoing or incoming). The travel rule information for EFTs includes:\ a) Name, address and account number of the player requesting the transfer (originator information)\ b) Name and address of the beneficiary\ c) If applicable, the beneficiary’s account number or other reference number If the Travel Rule information is not included with incoming or outgoing EFT, WagerCasino will contact registered players to obtain this information via email or phone. Transaction will be suspended by WagerCasino senior management (one of CEO/CCO/COO), if information is not made available. Record of incident will be retained in player account profile. If WagerCasino has grounds to suspect that EFTs could be related to ML/TF activity, a STR will be generated and submitted as per Section 8.1. See Appendices E & F for list high risk jurisdictions (EFTs to and from these jurisdictions require extreme caution) and Appendix I for indicators of suspicious activity regarding EFTs. ### **8.3 Casino Disbursement Report (CDR)** WagerCasino will report all disbursements to players that fall within the following: * A Single Transaction in the amount of €10,000 or more within a 24-hour period (gaming day)\ \- WagerCasino will generate a Casino Disbursement Report (CDR) \ \- All CDRs will be kept for 7 years from date created * Aggregated Transactions of 2 or more transactions that total €10,000 or more within a 24-hour period (gaming day)\ \- WagerCasino will generate a Casino Disbursement Report (CDR) \ \- All CDRs will be kept for 7 years from date created
### **8.4 Terrorist Property Report (TPR)** WagerCasino will not complete any transaction that is in any way known or believed to be associated with any form of Terrorist Property (e.g. cash, monetary instruments, igaming accounts, crypto etc). If in the course of account registration (e.g. match at name screening stage, open source search, etc), WagerCasino learns of any association with or the existence of property owned or controlled by a terrorist group, one of the CEO/CCO/COO will be notified immediately. The CEO/CCO/COO will in turn: * generate a Terrorist Property Report and provide it to the local Regulator. * STR will also be generated and submitted as per Section 8.1 WagerCasino will retain all TPR for 7 years from the date the report is generated and shared with iGO via Operator SharePoint site. ## **9.0 Player Account Termination** WagerCasino will terminate player account where: 1. Player is risk assessed as “Extreme Risk” 2. Suspicion that player is attempting to use account for ML/TF activity 3. Changes in customer details which fail KYC 4. The player account becomes too onerous to manage due to high level of STR reporting 5. If so directed by BetStop or other Regulatory bodies due to other factors (e.g. new information from other operator re: confirmed suspicious player activity) Detailed rationale for termination of account will be documented in player account records and provided to iGO with notification of account termination. All terminated accounts will be deactivated immediately and players will be banned from the ability to create another account on the WagerCasino platform. #### Appendix A |



Politically Exposed Persons

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Foreign Politically Exposed Person (PEFP)

A PEFP is an individual outside of the country who holds an office or position in a foreign jurisdiction.

All PEFP and related people are automatically identified as HIGH RISK clients and thereby subject to Enhanced Due Diligence (EDD)

Examples of PEFP include:


Domestic Politically Exposed Person (PEDP)

A PEDP is an individual who holds or has held in the last 5 years an office or position on behalf of the federal, a provincial or municipal government. After 5 years, a person ceases to be a PEDP. If PEDP or family members are identified as high risk, EDD measures must be applied.

Examples of domestic offices include:



| | ---------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | |

Head of an Inter-national Organi-zation

(HIO)

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Head of an International Organization (HIO)

An HIO is a person who holds or has held within the last 5 years a specific office or position of head of an international organization and it is either established by the government of states OR is an institution established by an international organization. The HIO is the person who leads this organization such as the CEO or President. If an HIO or family member is identified as high risk, EDD measures must be applied.

Examples of HIO include:


Family Members of PEDP/PEFP/HIO include:

Examples of Close Associate of PEDP/PEFP/HIO

| #### Appendix C Sanctions Lists for All Player Registrations\ Note we have referenced Canada, for ease. a)Public Safety Canada - Listed Terrorist Entities \ ; b) United Nations Resolutions on the Suppression of Terrorism \ ; c) Justice for Victims of Corrupt Foreign Officials Regulations \ ; d) Justice Laws - Regulations Establishing a List of Entities \ ; e) Consolidated Canadian Autonomous Sanctions List ; f) Freezing Assets of Corrupt Foreign Officials (FACF) g) Sanctioned Countries \ #### Appendix D How to Match Player Name to Sanctions Lists
| NAME |
  • if only part of name matches, not a valid match
  • check all former names/aliases on sanctions list – if a match check against other data such as birthday, address, nationality, etc to determine match
| | ----------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | DATE OF BIRTH/AGE |
  • if significantly different in year, month and day, then not a match
  • if year is same but month/day is different, look for another detail to verify match
| | NATIONALITY |
  • if nationality doesn’t match, not a match
| | ADDRESS |
  • ensure not multiple addresses and if address does not match, look for another detail such as nationality/date of birth to verify match
| | OTHER FACTORS |
  • photograph (if available)
  • background of player known
  • open media search
| #### Appendix E **July 25, 2020: Islamic Republic of Iran** This Ministerial Directive requires every financial transaction originating from or bound from, regardless of the amount, to be treated as a high-risk transaction. Mitigating measures include: ∙ Ensuring that the Player requesting or benefitting from such a transaction, has been identified as per Player identification requirements, including asking for the source of the funds, purpose of transactions and that the information is up to date; ∙ Keeping records of all the above actions; and ∙ Reporting all such transactions to FINTRAC. Note: While the Ministerial Directive on Iran is not directly applicable for casinos, iGO requires each Operator to adhere to this directive.
**December 9, 2017: Democratic People’s Republic of Korea (‘DPRK’)** This Ministerial Directive requires that all transactions to and from North Korea be treated as high risk, regardless of the dollar amount of the transactions. Mitigating measures include: ∙ Keeping a record of all transactions to and from North Korea, regardless of the dollar amount. This record must include details such as the Player's name, address, date of birth, descriptive occupation and transaction details such as dollar amount, currency, date and type of transaction. These details must specify whether the funds are coming from, or destined to North Korea; ∙ Ensuring that the Player conducting the transaction has been identified as per Player identification requirements, including asking for the source of the funds, purpose of transactions and that the information is up to date; ∙ Conducting enhanced ongoing monitoring of the Player and/or the business relationship and/or the account involved in the transaction; ∙ Keeping records of all the above actions; and ∙ Reporting suspicious transactions to FINTRAC (if applicable). #### Appendix F High-Risk Countries 1. Albania 2. Barbados 3. Botswana 4. Burkina Faso 5. Cambodia 6. Cayman Islands 7. Haiti 8. Jamaica 9. Malta 10. Mauritius 11. Morocco 12. Myanmar 13. Nicaragua 14. Pakistan 15. Panama 16. Philippines 17. Senegal 18. South Sudan 19. Syria 2 20. Uganda 21. Yemen 22. Zimbabwe
#### Appendix G High Risk Occupations Examples 1 Jeweler 2 Pawnbroker 3 Convenience store owner 4 Restaurant Owner 5 Tobacco distributor 6 Foreign exchange 7 Money transmitter 8 Automotive dealer 9 Real estate broker 10 Retail store owner 11 Liquor store owner 12 Cannabis store owner 13 Vending machine operator 14 Privately owned automated teller machines (ATM) #### Appendix H Source of Funds 1. Obtain source of funds. WagerCasino collects player occupation information upon registration. For EDD, WagerCasino will directly ask players to add information regarding source of funds. If information provided is not satisfactory, WagerCasino will require documentation to prove explanation (e.g. bank statement, pay stub, etc) 2. WagerCasino will conduct open source searches to confirm player’s occupation and to determine any other information via online news sources such as industry regulators, law enforcement, news media, social media, etc 3. Ongoing monitoring for all High Risk players will be conducted every 6 months including confirmation of up to date EDD #### Appendix I ML/TF Suspicious Indicators
#### Appendix J
Summary of Regulatory Reporting Timelines \ As Canada is one of our initial jurisdictions we want to enter, this is only an example of the benchmarks we set ourselves. This will be localised for each country we enter. | Data Requirement | Method/Frequency of Transmission to iGO | | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------- | |

STR:

Operators will create the STR in F2R within 5 days after establishing that a transaction or attempted transaction is or may be related to the commission of a money laundering or a terrorist activity financing offence and iGO will submit to FINTRAC.

iGO must send an STR to FINTRAC as soon as practicable.

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Method: F2R

Frequency: Within 5 days from detection of suspicion

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EFTR – Incoming/Outgoing:

Operators will create the EFTR in F2R within 1 day after the day of the transmission of the instructions and iGO will submit to FINTRAC.

iGO must send an EFTR to FINTRAC within 5 working days after the day of the transmission of the instructions.

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Method: F2R

Frequency: Within 1 day from transaction date

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CDR and LCTR:

Operators will create the CDR/LCTR in F2R within 5 days from the transaction date and iGO will submit to FINTRAC.

iGO must submit a CDR/LCTR to FINTRAC within 15 days from the transaction date.

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Method: F2R

Frequency: Within 5 days from transaction date

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TPR:

iGO and the Operators must disclose immediately to the RCMP or CSIS the existence of property in their possession or control that they know or believe is owned or controlled by or on behalf of a terrorist group.

The Operator must immediately notify iGO and iGO will file the TPR to FINTRAC (via fax or mail) without delay.

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Method: Completed template sent to iGO (via SharePoint) for submission to FINTRAC/RCMP via paper/fax

Frequency: Immediately

| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | --------------------------------------------------------------------------------------------------------------------------------------------------- | #### Appendix K – Guidance for Conducing Investigation As Canada is one of our initial jurisdictions we want to enter, this is only an example of the benchmarks we set ourselves. This will be localised for each country we enter. | # | Action |


| Remarks | | ----------- | ---------------------------------------------------- | ----------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | 1 | Complete UTR Log |  | Complete the UTR Log and ensure all data fields are considered and completed. | | 2 | Review FINTRAC filing history |  | Search for prior UTRs and STRs that have been filed on the Player. | |


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|  | Exercise additional due diligence when reviewing Player’s that have had previously filed UTRs and STRs. | | 3 | Provide a summary of the unusual/suspicious activity |  | Describe the activity or circumstances surrounding the suspicion. | | 4 | Review Player information |  | Review the Player identification information to ensure it is up to date and that the transaction information aligns with the Player information such as occupation. | | 5 | Conduct online searches |  | Conduct online searches on the Player for relevant news or other publicly available information (Use quotations around names to search the full name, add city/country to narrow the search results if the names are generic). | |


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|  | Check for negative news (e.g. arrests or convictions) and any information that might explain the unusual activity. | |


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|  | Use the name screening tool to search for negative news and/or relevant information. | | 6 | Review transaction history |  | Review the account activity and assess previous transaction history. | |


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|  | Summarize the type/volume of transactions, source of incoming funds, method of disbursement and note the unusual/suspicious activity observed. | | 7 | Conclusion |  | No suspicious activity noted – Log the details of the investigation in the UTR that led to this conclusion and close the UTR. | | ----------- | ---------------------- | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | |


|


|  |

Suspicious activity noted – Provide brief explanation to support the decision and prepare to submit an STR in F2R.

Record the STR number in the UTR Log.

| | 8 | Player Risk Assessment |  | Assess whether Player risk level requires reassessment based on the above decision. |