TH Gambling N.V., trading as Boomzy, is committed to maintaining the highest standards of integrity and transparency in its operations. We recognise that online gaming may be exposed to money-laundering or terrorist-financing risks and have therefore implemented a comprehensive AML/CTF compliance framework designed to prevent and detect such activities. Boomzy is operated by TH Gambling N.V., incorporated in Curaçao and licensed and regulated by the Curaçao Gaming Authority (CGA) under licence number OGL/2024/1468/1024.

This Policy is established in accordance with the laws and regulations of Curaçao and aligned with international AML/CFT standards, including: Curaçao Legislation & Guidance:

• National Ordinance on the Reporting of Unusual Transactions (LvMOT)

• National Ordinance on Identification when Rendering Services (LvID)

• Sanctions Ordinance and Kingdom Sanctions Act

• Landsverordening op de Kansspelen (LOK 2024)

• AML/CFT Policy Guidance issued by the Curaçao Gaming Authority (CGA)

• Reporting and Monitoring Standards issued by the Financial Intelligence Unit (FIU Curaçao)

This Policy aims to:

• Prevent the use of Boomzy's services for money-laundering or terrorist- financing purposes.

• Ensure compliance with applicable AML/CFT laws and regulatory obligations.

• Establish and maintain a strong culture of compliance and awareness across the organisation.

• Protect the integrity and reputation of TH Gambling N.V. and the Curaçao iGaming sector.

A Compliance Officer / Money Laundering Reporting Officer (MLRO) has been appointed to design, implement, and oversee the AML/CTF framework, report unusual transactions to the FIU, and act as liaison with the CGA. All employees must understand and comply with this Policy and immediately escalate any suspicious activity to the Compliance Officer. Independent reviews and audits are performed periodically to test the effectiveness of AML/CTF controls.

We conduct CDD on players when accepting and serving players and on an ongoing basis thereafter. The process includes:

• Verifying the customer’s identity, age, and address using reliable, independent documents or data.

• Determining whether the customer acts on their own behalf or for a third party.

• Where appropriate, obtaining information on the source of funds and source of wealth.

• Maintaining up-to-date customer records throughout the relationship.

No player is permitted to deposit, wager, or withdraw funds until minimum CDD requirements have been satisfied.

Enhanced procedures are applied when a customer or transaction presents higher risk, including but not limited to:

• Customers from countries identified by the FATF as high-risk or subject to sanctions.

• Politically Exposed Persons (PEPs) and their close associates or family members.

• Complex or unusually large transactions with no apparent economic purpose.

• Use of crypto-assets, anonymising services, or third-party payment instruments inconsistent with the player's profile.

EDD measures may include additional verification, corroboration of source- of-funds documentation, and senior management approval.

Boomzy continuously monitors player activity to identify unusual or suspicious patterns, including:

• Rapid deposits and withdrawals with minimal play.

• Frequent use of multiple payment instruments or wallets.

• Activity inconsistent with the player's historical behaviour.

• Attempts to circumvent jurisdictional or account limits.

All transactions and CDD records are retained for at least five (5) years following the end of the relationship or completion of the transaction, in accordance with statutory requirements

• All customers and counterparties are screened against international sanctions and PEP lists (UN, EU, OFAC, UK HMT).

• Access from, or transactions involving, sanctioned or prohibited jurisdictions are blocked.

• We employ IP geolocation, payment-method controls, and manual review to enforce these restrictions.

• Use of VPNs or anonymising technologies to bypass geo-restrictions is prohibited and treated as a risk indicator.

If internal review determines that a transaction or activity is unusual or suspicious, the Compliance Officer will: 1. File a Report of Unusual Transaction (RUT) with the Financial Intelligence Unit (FIU Curaçao); and 2. Record the decision-making process and supporting documentation. Employees are prohibited from informing customers that a report has been filed ('tipping-off').

All relevant employees receive AML/CTF training upon hiring and on a recurring basis thereafter. Training covers:

• Legal obligations and internal procedures.

• Recognising and reporting suspicious activity.

• Customer due diligence and escalation protocols.

• Data protection and confidentiality requirements.

Attendance is documented and forms part of staff competency assessments.

The AML/CTF framework is subject to regular independent audits to assess adequacy and effectiveness. Findings are reported to senior management and corrective measures are tracked to completion.

Boomzy cooperates fully with the CGA, FIU Curaçao, and other competent authorities in their efforts to combat financial crime. We may request identification or verification documents from customers at any time. Refusal to provide such information may lead to account suspension or termination.

All personal and financial data obtained for AML/CTF purposes is handled confidentially and stored securely in compliance with applicable data- protection legislation. Access is restricted to authorised personnel only.

This Policy is reviewed annually or whenever significant regulatory, operational, or technological changes occur to ensure continued compliance and effectiveness.

hello@boomzy.com TH Gambling N.V. – Committed to Integrity, Transparency, and Regulatory Excellence.