Anti-Money Laundering Policy

Last updated: January 1, 2024

1. Introduction

DeepWater Stone OU is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines the measures we implement to prevent our platform from being used for money laundering, terrorist financing, or other financial crimes.

2. Regulatory Framework

Our AML program is designed to comply with:

• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) of Canada
• AGCO Registrar's Standards for Internet Gaming
• Kahnawake Gaming Commission Regulations
• Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) guidelines

3. Know Your Customer (KYC)

All customers must complete identity verification before withdrawals are processed. Verification requirements include:

• Government-issued photo identification (passport, driver's licence, or national ID)
• Proof of address (utility bill, bank statement, or government correspondence dated within 3 months)
• Proof of payment method (photo of credit card, screenshot of e-wallet, or bank statement)

Enhanced due diligence is applied to high-value customers and politically exposed persons (PEPs).

4. Transaction Monitoring

We employ automated systems to monitor all transactions for suspicious patterns, including:

• Unusually large deposits or withdrawals relative to player history
• Rapid movement of funds with minimal gaming activity
• Frequent deposits followed by immediate withdrawal requests
• Use of multiple payment methods without clear justification
• Deposits from high-risk jurisdictions

5. Suspicious Activity Reporting

When suspicious activity is identified, we take the following steps:

• The transaction or account is flagged for review by our compliance team
• The account may be temporarily frozen pending investigation
• A Suspicious Transaction Report (STR) is filed with FINTRAC where required
• Relevant information is shared with law enforcement authorities as legally mandated

6. Record Keeping

All customer identification records, transaction logs, and compliance documentation are retained for a minimum of five (5) years following account closure or the date of the last transaction, whichever is later.

7. Employee Training

All staff members receive mandatory AML/CTF training upon hiring and annual refresher courses. Training covers identification of suspicious behaviour, escalation procedures, and regulatory obligations.

8. Contact

For questions about our AML policy or to report suspicious activity, contact our compliance department at compliance@deepwaterstone.com.