ANTI-MONEY LAUNDERING (AML) POLICY

Money laundering is defined as the process intended to mask benefits derived from serious criminal offenses or criminal conduct, as described under Anti-Money Laundering Act of 2001 REPUBLIC ACT NO. 9160, to make it appear that such benefits originated from a legitimate source. Generally, money laundering is composed of three (3) stages involving several transactions which could alert an intermediary such as the Company to the money laundering activity:

Placement – the physical act of disposing of the cash proceeds drawn from illegal activities

Layering – the act of separating illicit proceeds from their source by creating complex tiers of financial transactions in order to disguise the audit trail and provide anonymity

Integration – the act of providing an appearance of legitimacy to criminally- derived wealth. If the layering process is successful, the integration step places the laundered proceeds back into the economy in a manner that their re-entry into the financial system has the appearance of being normal business funds

1 BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING

WinZir endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and terrorist financing:

Established and duly appointed Compliance Office

Know-Your-Customer (CDD and EDD)

Reporting to AMLC

Ongoing Employee Training

Ongoing monitoring and Compliance Testing

Record Keeping and Data retention in accordance with AML laws and regulations

Internal Audit Function.

1.1 COMPLIANCE WITH LAWS

WinZir ensures that its business is conducted in conformity with the height of ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.

1.2 COOPERATION WITH LAW ENFORCEMENT AGENCIES

Within the legal constraints relative to client confidentiality, WinZir cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the applicable governing body.

The following links contain important policies and rules that apply to users who accept our general terms and conditions:

• Sportsbook Rules: https://winzir.ph/more/sportsbook-rules
• Terms & Conditions: https://winzir.ph/terms-and-conditions
• Privacy Policy: https://winzir.ph/privacy-policy
• Refund Policy: https://winzir.ph/more/regulatory/refund-policy
• KYC Policy: https://winzir.ph/more/regulatory/kyc-policy
• AML Policy: https://winzir.ph/more/regulatory/aml-policy
• Responsible Gaming: https://winzir.ph/more/regulatory/responsible-gaming

By accepting our general terms and conditions, users are bound by the content and provisions outlined in these policies and rules.