1.1. BOOTH.com LTD. (" paradise.com " or the " Company ") is a company incorporated under COUNTRY NAME that was established in DATE and operates the online casino paradise.com under the LICENSENUMBER.

As part of its global operations, paradise.com has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

2.1. paradise.com is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (" AML/CFT ") applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, paradise.com expressly prohibits and rejects the use of paradise.com products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering (" AML ") laws, regulations and norms. paradise.com continues to monitor norm setting parameters promulgated by the Financial Action Task Force (" FATF ") and certain gaming trade groups in addition to the Curaçao Gaming Control Board and will take necessary action as it deems appropriate to reflect changes in law.

2.2. paradise.com's intention is to follow global best practices in guarding against paradise.com products being used to facilitate such activities. Those best practices include:

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler's checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets. Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions.For example, they are used:

4.1. paradise.com will apply appropriate user due diligence and ongoing monitoring measures required by law. paradise.com will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity. paradise.com uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.

4.2. Customer Due Diligence

paradise.com collects certain documentary and non-documentary information commensurate with the nature of the type account and services that paradise.com offers. This includes:4.3. Identity and Age Verification . A third-party service provider will support paradise.com's ability to determine the legitimacy of the identification information other KYC materials or information provided and will confirm that the user is permissible. The service provider also will confirm that the user does not appear to be located in a comprehensively-sanctioned or otherwise prohibited jurisdiction and will search global sanctions lists to confirm that the user does not appear thereon using onboarding information such as wallet addresses.

4.4. Customer Information . paradise.com will collect details on each user to form a reasonable belief that paradise.com knows the identity of its users commensurate with the user's risk profile. For instance, paradise.com may collect such details as the wallet address, name, address, country, date of birth, or postal code (collectively, " KYC Information "). paradise.com will collect any of the above KYC Information prior to issuing a paradise.com funding address to users. paradise.com does not presently allow users who are non-natural persons.paradise.com may, at its own description rely on the performance by another institution of some or all of the elements of our CIP.

4.5. Geo-blocking for Prohibited Jurisdictions . paradise.com will require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.

5.1. paradise.com performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, paradise.com has implemented a set of red flag indicators that help it determine such behaviours and require further action from paradise.com in assessing the customer information.

5.2. Whenever one of those red flags is triggered, the user account will be suspended and paradise.com will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of:paradise.com may use a third party service provider to verify any of the above information as determined to establish a reasonable basis to know the true identity of the user where the user's activity warrants such action.

6.1. paradise.com will not accept a and will block the users that:6.2. paradise.com reserves the right to block and suspend players for any other reasons at its own discretion.

7.1. paradise.com is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose paradise.com established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring.

7.2. paradise.com will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review user history and patterns of activity to detect and report any unusual activity as required and to develop and implement any additional controls or limits in its platform.

8.1. paradise.com is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity to the regulator.