POLICY TO PREVENT AND COMBAT MONEY LAUNDERING, TERRORIST FINANCING, AND THE PROLIFERATION OF WEAPONS OF MASS DESTRUCTION 

ADMINISTRATIVE PROVISIONS

PURPOSE, VALIDITY, PRINCIPLES AND SCOPE OF APPLICATION

1. This Policy for Preventing and Combating Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction ("Policy") aims to consolidate the established guidelines, define roles and responsibilities, establish procedures and internal controls, as well as disseminate knowledge on the subject of Preventing and Combating Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction ("PLD/FTP") within the scope of Futuras Apostas' operations, in accordance with the requirements of Laws No. 9.613/1998, No. 12.846/13, No. 13.810/2019, No. 14.790/2023, SPA/MF Ordinance No. 1.143/2024 and other applicable laws and regulations.
2. This Policy reiterates the commitment of Futuras Apostas' senior management to ensure compliance with applicable laws and regulations, as well as the observance of high ethical and governance standards in the conduct of business.
3. This Policy is valid indefinitely and must be reviewed and approved by the Board of Directors periodically, in accordance with the provisions of this Policy, or in the event of changes in applicable legislation and regulations. 
4. This Policy has as its principles and guidelines the maintenance of ethics and legality in all the activities carried out by Futuras Apostas, the continuous improvement of its guidelines, collaboration with the Public Authorities in the dissemination of good practices and the promotion of PLD/FTP control mechanisms to mitigate the risks of illicit practices. 
5. This policy applies to all partners, administrators, employees, collaborators, partners, service providers, including third parties, Bettors and users of the Futuras Apostas platform.

TERMS AND DEFINITIONS 

For the purposes of this Policy, the following are considered:

1. Bettor: a natural person who places a bet.
2. Betting: an act whereby a certain amount of money is put at risk in the expectation of obtaining a prize.
3. Money Laundering: the process by which individuals or organizations attempt to give the appearance of legality to funds originating from criminal offences. This involves concealing the origin, ownership, location and nature of these resources, which are inserted into the economy on a temporary or permanent basis. The aim is to allow criminal agents to enjoy the economic benefits derived from illicit activities previously committed. The process takes place in three independent phases, which can occur simultaneously or individually: 
   1. Placement: consists of disguising the financial movements made with illicit funds, with the aim of preventing them from being traced. At this stage, the funds are moved through several complex and varied transactions, making it difficult to trace and identify their illegal origin.
   2. Concealment: this is the stage in which the agent carries out suspicious transactions that characterize the crime of Money Laundering. This phase consists of physically segregating the agent from the illicit money by means of various complex transactions to disassociate the illegal source from the money. 
   3. Integration: Integration is the final stage of the money laundering process, in which the "laundered" funds are made available to criminals in an apparently legal form. At this stage, the funds, after having passed through several layers of disguise, are reinserted into the formal economy through investments in legitimate businesses, the purchase of luxury goods or other assets, allowing criminals to enjoy these resources without raising suspicions about their illicit origin.
4. Terrorist Financing: consists of raising funds and/or capital to carry out terrorist activities. These funds can come from donations or earnings from various licit or illicit activities, such as crime in general. 
5. Financing the Proliferation of Weapons of Mass Destruction: consists of raising funds, in a licit or illicit manner, for the purpose of providing financial support for the proliferation of weapons of mass destruction, which can be biological, chemical or nuclear. 
6. Politically Exposed Person ("PEP"): in accordance with Coaf Resolution 40/21, politically exposed persons are those individuals who hold or have held relevant public positions, jobs or functions (such as heads of state, high-ranking politicians, members of the judiciary and executives of public companies) in Brazil or in foreign countries, territories and dependencies in the last five (5) years, as well as their representatives, family members and other people with close relationships up to the second degree. There are also examples of situations that characterize a close relationship and lead to a client being classified as a politically exposed person, such as direct or indirect control of a legal entity client.
7. Know Your Customer (KYC): Procedure for collecting and verifying customer identification information to assess their risk profile and ensure that the business relationship remains in compliance with integrity standards and Anti-Money Laundering legislation.
8. This Policy will also adopt the concepts defined in Article 3 of SPA/MF Ordinance No. 1,143 of July 11, 2024, as applicable.

GUIDELINES

1. Futuras Apostas' Program to Prevent and Combat Money Laundering, the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction aims to prevent the involvement of Futuras Apostas' structure, products and services in illicit activities, in compliance with current legislation and regulations. 
2. It is the responsibility of all employees, partners, service providers, including contractors, and suppliers to know and understand the terms of this Policy, as well as to prevent and detect operations or transactions that have atypical characteristics in order to combat the crimes of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction. The laws and regulations that deal with these issues, as well as the rules and guidelines established by this Policy, must be complied with.
3. Futuras Apostas will periodically evaluate the products and services it offers from the perspective of the risks of misuse of such products and services for the practice of Money Laundering, Terrorist Financing, Proliferation of Weapons of Mass Destruction and related crimes, taking the necessary measures to mitigate such risks. 
4. Knowledge of any evidence of Money Laundering, Financing of Terrorism and the Proliferation of Weapons of Mass Destruction or any other illicit act must be reported to the Integrity and Compliance Department through the channels indicated in item 7.3 of this Policy, which is responsible for investigating the information reported and, if applicable, after an analysis process, reporting it to the regulatory bodies. 
5. Through this Policy, approved by its Board of Directors, Futuras Apostas undertakes to develop and maintain effective processes, procedures and controls to prevent, detect and combat Money Laundering, the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction, as well as other related crimes, which reflect the best national and international practices. 

ROLES AND RESPONSIBILITIES

The entire organizational structure of Futuras Apostas has specific duties in the fight against Money Laundering, Terrorist Financing, the Proliferation of Weapons of Mass Destruction and other related crimes, as described below:

1. Futuras Apostas Board of Directors
   It is the responsibility of the Futuras Apostas’ Board of Directors:
   i. Deliberate on the guidelines applicable to PLD/FTP issues involving the operation of Futuras Apostas, contemplated in this Policy, as well as provide the human, financial and technological resources to ensure the effectiveness and continuous improvement of the procedures aimed at this issue.
2. Integrity and Compliance Department
   It is the responsibility of the Integrity and Compliance Department:
   i. Implementing and monitoring compliance with this Policy, other applicable rules and their respective updates;
   ii. Comply with the determinations of the regulatory bodies for action in PLD/FTP;
   iii. Ensure compliance with legislation, rules, regulations and internal policies governing PLD/FTP;
   iv. To disseminate and act as a multiplier of the culture of preventing and combating the crimes of Money Laundering, Terrorist Financing, Proliferation of Weapons of Mass Destruction and other related crimes;
   v. Ensure that the registration of platform users and bettors is carried out from a PLD/FTP perspective, in order to mitigate risks for Futuras Apostas, ensuring procedures for the identification and monitoring of PEPs and platform users and bettors classified as being at high risk, in accordance with Futuras Apostas' internal policies and the institutional Know Your Customer (KYC) procedure; 
   vi. Interacting with regulatory bodies;
   vii. Implement procedures for identifying, monitoring and reporting to COAF, within the regulatory deadline, activities and/or operations suspected of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction; 
   viii. Prior analysis of projects to develop new products and services, including new technologies, in order to mitigate the risks of such products, services and/or technologies involving and/or being used to commit crimes of Money Laundering and the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction;
   ix. Preparing and keeping at the disposal of senior management, audits and regulators the reports and records of regulatory obligations relating to PLD/FTP, in compliance with the regulatory deadline;
   x. Implementing periodic due diligence processes for payment institutions and financial institutions with which Futuras Apostas maintains a relationship;
   xi. Prepare training and lectures for employees, partners and service providers, including contractors, to raise awareness of the crime of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction, and to help detect operations that are indicative of these crimes; and,
   xii. Review and evaluate the effectiveness of the implementation and controls provided for in this Policy.
3. Legal Department
   It is the responsibility of the Legal Department:
   i. Establish legal procedures for Futuras Apostas to ensure compliance with legal and regulatory requirements related to PLD/FTP; and,
   ii. Assisting and supporting responses to legal and regulatory requirements. 
4. Human Resources Department
   This is the responsibility of the Human Resources Department:
   i. Adopt controls regarding the knowledge of employees and collaborators before the start of their activities; and
   ii. Carry out a reputational analysis during the contracting phase and monitor the economic and financial situation of employees and collaborators, with a view to PLD/FTP.
5. Employees and collaborators
   It is the responsibility of all employees and collaborators of Futuras Apostas: 
   i. Inform the Integrity and Compliance Board if any conflict of interest is identified, in order to ensure the independent performance of their duties;
   ii. Monitoring atypical operations; and
   iii. Observe the necessary criteria to guarantee the legality of operations. 
6. Information Technology Department
   It is the responsibility of Information Technology Department:
   i. Ensure that the PLD/FTP monitoring systems are working properly, guaranteeing that any faults are resolved in the shortest possible response time.
    

PLD/FTP PROCEDURES

1. Internal Risk Assessment 
   i. The Internal Risk Assessment takes place in the light of the PLD/FTP rules, in order to mitigate financial, legal and reputational risks for Futuras Apostas, ensuring the identification and monitoring of suspicious operations. 
   ii. In addition, the adoption of qualification procedures for Bettors or users of the platform will have the purpose of identifying and monitoring the compatibility between the economic and financial capacity of the Bettor and the operations carried out by him, the identification of PEPs and users of the platform and Bettors classified as being in a high-risk situation, in accordance with the policies and procedures of Futuras Apostas and specific legislation, especially SPA/MF Ordinance No. 1,143/2024.
   1. Risk-based approach 
      i. Futuras Apostas adopts a risk-based approach, stipulated through the verification of categories and variables in its own risk matrix. This action ensures that the measures adopted to combat Money Laundering, the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction are proportional to the risks identified in the process of accepting, monitoring and maintaining Futuras Apostas' relationship with Bettors, platform users, employees, partners and third-party service providers. Likewise, it ensures that the measures adopted to combat Money Laundering, the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction are proportional to the risks linked to its activities in the operation of Betting, the contracting and development of products and its operations with financial and real estate assets. 
      ii. Futuras Apostas recognizes that the Betting sector presents specific and high risks for Money Laundering practices, Terrorist Financing and fraudulent activities due to the volume, complexity and nature of the transactions carried out on its platform. This Policy is designed to identify, monitor and mitigate these risks through specific procedures and advanced technological tools
      iii. Futuras Apostas adopts a prevention program focused on the following types of specific risks:
      a) Suspicious Credit and Debit Transactions: Strict control for transactions involving the movement of amounts between user accounts without clear economic justification.
      b) High Value Transactions or Splitting: Identification of users who place high value bets or deposits in a single transaction or split high values into several smaller transactions to avoid alerts.
      c) Use of microtransactions: Monitoring high-volume microtransactions, which can indicate attempts to launder money by moving small amounts around repeatedly.
      d) Odds manipulation: Identification of odds manipulation in bets, especially those involving sporting events suspected of organized fraud, with the aim of benefiting specific bettors.
      e) User's Financial Profile: Verification of the compatibility between the declared financial profile and the volume of bets placed.
      f) Geolocation and Area of Operation: Identification of users located in regions of high risk for Money Laundering or where gambling practices are commonly associated with illicit activities.
      g) Association with Other High-Risk Users: Checking for connections between accounts that indicate possible networks of users involved in fraud or Money Laundering."
      iv. Futuras Apostas, in compliance with Articles 24 and 25 of SPA/MF Ordinance No. 1,143/2024, undertakes to implement monitoring, selection, and analysis procedures that ensure the complete identification of bets and operations associated with them, including their characteristics, involved parties, amounts, betting modalities, and payment methods. The organization will pay special attention to bets and operations that lack economic or legal foundation, are incompatible with usual practices of the activity or market, or indicate signs of money laundering, terrorist financing, or other related crimes.
      v. Furthermore, operations involving persons suspected of money laundering or terrorist financing crimes, persons domiciled in jurisdictions considered high-risk, resistance or provision of false information by bettors, atypical financial contributions or transactions that indicate manipulation, concealment, or fraud, accounts linked to politically exposed persons or unauthorized intermediaries, prizes suspected of result manipulation or use in illicit activities, or any other characteristics that, due to their unusual nature, may indicate the practice of money laundering, terrorist financing, or other related crimes will be rigorously analyzed.
      vi. Futuras Apostas will review and update its risk matrix at least every six months or whenever significant changes in the sector risk profile are detected. These reviews will include analysis of new Money Laundering and terrorist financing methodologies adapted to the Betting sector.
      vii. Transactions automatically identified as suspicious will be analyzed by the compliance team to determine the need to report them to the regulatory bodies. Futuras Apostas will keep detailed records of these transactions and the analysis carried out, with a view to internal and external audits.
   2. Scope
      i. The internal assessment identifies and evaluates risks in terms of their likelihood of occurrence and the magnitude of the financial, legal and reputational impacts for Futuras Apostas.  
      ii. The methodology to be used in the internal risk assessment will cover the risk profile of platform users and bettors, the institution, including the business model and geographical area of operation, operations, transactions, products and services, covering all distribution channels and the use of new technologies, as well as the activities carried out by employees, partners and service providers, including outsourced ones.
      iii. Risk categories must be defined to enable the adoption of enhanced management and mitigation controls for the highest risk situations and the adoption of simplified controls in the lowest risk situations, with a risk rating being determined by algorithm model for the profiles assessed above.  In the internal risk assessment process, when available, the assessments carried out and made available by public entities in the country regarding the risk of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction should be taken into account.
      iv. The assessment must be documented and approved by the Integrity and Compliance Board, as well as being made available to the other Boards. The frequency of review of the internal risk assessment must be a maximum of one year, when significant changes occur in the risk profiles that support this assessment, with such situations being highlighted in the operating procedures described in the specific manuals. 
2. Evaluation of new products, services and technologies 
   i. Futuras Apostas has internal procedures for the prior approval of new products and services, including the use of new technologies for their offer, or for the offer of existing products and services. 
   ii. The Integrity and Compliance Department is responsible for analyzing and evaluating new products and services in advance, including new technologies, in order to mitigate the risks of such products involving and/or being used to commit crimes of Money Laundering and the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction.
3. Training and Capacity Building
   i. Futuras Apostas carries out acculturation actions through training and capacity building, which cover various topics relevant to the process of governance, integrity and the ESG agenda (environmental, social and governance), including PLD/FTP training.
   ii. When the relationship begins, Futuras Apostas uses an internal tool to carry out online training for all employees, collaborators and senior management, as well as for relevant third parties based on the internal risk assessment. Each year, the content of the training is submitted for review by the Integrity and Compliance Board, and all employees, collaborators, members of senior management and third parties, as applicable, must undergo mandatory retraining. 
   iii. Training consists of a conceptual part and another part dedicated to assessing the assimilation of the knowledge acquired. The human resources department must keep an up-to-date record of training, as well as keeping data on employees and collaborators who have not undergone such training, and those who have not reached the specified percentage of assimilation. 
   iv. Futuras Apostas also promotes specific training for the areas considered sensitive for PLD/FTP. 
4. Maintaining information 
   i. Documents and registration data relating to operations and services, including recordings and procedures aimed at getting to know your client, employee, partner and/or service providers, will be stored by Futuras Apostas for a minimum period of 5 (five) years, counting from the date of termination of Futuras Apostas' relationship with the respective client, employee, partner and/or service provider, in compliance with the rules of the General Data Protection Law (Law n. 13.709/18).
5. Reporting Suspicious Transactions to COAF 
   i. Transactions, situations or proposals with indications of Money Laundering and Combating the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction will be reported to the competent regulatory bodies, where applicable, in compliance with legal and regulatory provisions. 
   ii. All suspicious transactions must be reported to the Integrity and Compliance Department within 24 hours of identification. The initial analysis will be carried out within 48 hours to determine the need for referral to COAF, which should take place in 3 working days after the initial detection.
   iii. The operations considered suspicious and the procedures for registering and reporting them to COAF will be set out in a specific Procedure.
6. Evaluating effectiveness 
   i. Every year (base date of December 31st), the Integrity and Compliance Board will prepare the Effectiveness Assessment report for the PLD/FTP processes established herein, to be sent to the Futuras Apostas Board of Directors for information (by March 31st of the following year). The report in question must contain information describing the methodology adopted in the effectiveness assessment, the procedures, controls and tests applied, the qualification of the assessors and the correction of any shortcomings identified. 
   ii. In addition, the Effectiveness Assessment report must include an assessment of the procedures for getting to know platform users and bettors (including the verification and validation of information from platform users and bettors and the adequacy of registration data), the procedures for monitoring, selection, analysis and reporting to COAF (including evaluating the effectiveness of the parameters for selecting operations and suspicious situations), the governance of the PLD/FTP policy, measures for developing the organizational culture aimed at PLD/FTP, periodic staff training programs and procedures for getting to know employees, partners and outsourced service providers.
7. Customer Identification and Identity Verification (KYC) Procedures
   i. Futuras Apostas will verify the identity of all new customers at the time of registration. This identification process will require the provision of complete information, including full name, date of birth, CPF or passport (in the case of foreigners), full address with supporting documentation, bank accounts, facial biometrics and contact information. Each customer must prove the authenticity of this information by means of valid and up-to-date official documents.
   ii. Futuras Apostas will adopt strict validation procedures to verify the authenticity of the documents submitted by customers. The platform will use optical character recognition (OCR) and biometric validation technologies to confirm that the documents presented are genuine and correspond to the account holder.
   iii. The identification of clients classified as Politically Exposed Persons (PEPs) or high risk will be carried out with additional verification, requiring complementary documents, where applicable, and validation of financial information. For these cases, an in-depth analysis of the financial history and source of funds will be carried out to ensure that the transactions are in line with the client's economic profile.
   iv. The Company is committed to preventing and combating money laundering and terrorist financing in compliance with applicable laws and international standards. As part of this commitment, the Company conducts regular checks against the United Nations Sanctions List and other applicable sanctions lists.
   v. If any individual or entity associated with this agreement is identified as a match on the United Nations Sanctions List or any equivalent sanctions list, the Company shall immediately freeze all related assets, accounts, or transactions, as required by law. The Company will promptly report the matter to the competent authorities and fully cooperate with any subsequent investigations or enforcement measures.

PENALTIES

1. Failure to comply with PLD/FTP legislation and/or regulations, including this Policy, will subject managers, employees, service providers, partners and\or suppliers to applicable penalties ranging from administrative to criminal penalties for Money Laundering, Terrorist Financing, Proliferation of Weapons of Mass Destruction and Fraud. Negligence and willful failure are considered non-compliance with this Policy and the Futuras Apostas Code of Ethics and Conduct.
2. Any proven violation, such as failure to report suspicious operations or failure to comply with KYC procedures, will result in disciplinary measures, which may include warnings, suspension and, in cases of recidivism or bad faith, termination of employment.
3. Failure to comply with this policy may be reported to the Integrity and Compliance Department through the following channels: [email protected].

ANNUAL REVIEWS

1. This Policy is reviewed annually, or at shorter intervals as necessary, to ensure that it is in line with best practice and applicable legislation. 

RESPONSIBILITY FOR POLICY

The Integrity and Compliance Department of Futuras Apostas is responsible for drafting, reviewing and implementing this Policy and is available to provide guidance and further information in relation to this Policy and the applicable legislation.