(Latest version, written on July 11, 2020)
Whiterock Leisure Performances N.V. (Whiterock) with its registered address at Abraham de Veerstraat 9 (PO Box 3421) Curaçao is regulated by the Jurisdiction of Curaçao (former The Netherlands Antilles) with its Registeration Number 153.656 and its Casino Sub-License Number GLH-OCCHKTW076112020 (for the Right to Use of Non-Exclusive Offshore Games of Chance and Wagering) and its Business Description, such as:
1. To organize, market, promote, manage, support and operate all types of remote gaming activities, comprising all types of games, betting and other operation of betting exchange, interactive casinos, bingos, lotteries, poker and other interactive games for clients established or residing outside of Curaçao. 2. The company has the power to perform every act and thing profitable or requisite to the accomplishment of its purposes or connected therewith or incidental thereto in the widest sense of the word.
Whiterock Leisure Performances N.V. confirms on the 4th day of July 2020 the following in accordance with the standards of a prudent professional and the applicable laws and regulations:
1. We maintain Anti Money Laundering & Counter Terrorist Financing (AML/CTF) policies applicable to all employees and an on-going training program. We have implemented related procedures and controls including a procedure on suspicious activity reports;
2. We perform a risk assessment of the underlying investor, mandates and proxy holders using a combination of relevant risk factors prior entering into a business relationship and obtain information on the purpose of the business relationship (Risk Based Approach);
3. We perform the identification and verification of the identity of the underlying investor based on the initial risk assessment. Where applicable, the identification and verification of the identity of our clients, beneficial owners, controlling parties and proxy holders is performed, such that the ownership and control structure of the underlying investors in particular legal persons, trusts and similar legal arrangements are understood and risks are assessed;
4. We perform enhanced due diligence on higher risk underlying investors and their beneficial owners, where applicable, including politically exposed persons and, where a relationship is established with countries or territories which do not or insufficiently apply AML-CTF measures;
5. We perform on-going monitoring of the business relationship to maintain KYC information current including detection of unusual transactions which are not consistent with the expected business activity, and where necessary, the origin of funds and origin of wealth;
6. We perform sanctions screening prior the account opening and on an on-going basis of the underlying investors, their beneficial owners, mandate and proxy holders where applicable. The sanctions lists are amongst others, the resolutions of the United Nations Security Council as welt as acts adopted by the European Commission regarding CTF /EU sanction list.
7. We retain investor due diligence documentation du ring a period of at least five years following the end of the business relationship and will make it available upon written request notwithstanding any applicable rules on confidentiality or local secrecy laws.
8. We do not enter into business relationship with shell banks or accept shell banks as underlying investors or beneficial owners.
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