Blitzwin

Company

InterStorm N.V. has an application (OGL/2024/106/0170) for a gaming license in progress with the Curaçao Gaming Authority. Until that process is concluded, based on a transitional arrangement outlined in the National Ordinance on Games of Chance (Landsverordening op de Kansspelen, P.B. 2024, no. 157), the company is permitted to continue its operations under this Certificate of Operation.

As part of its global operations, Blitzwin 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.

AML/CFT

AML

FATF

Blitzwin’s intention is to follow global best practices in guarding against Blitzwin products being used to facilitate such activities. Those best practices include:

(i) Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;

(ii) Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;

(iii) Provision of related education and training to relevant personnel; and

(iv) Independent reviews, monitoring and maintenance of the policy, procedures and controls.

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:

(i) To encourage a change in behaviour for a target country or regime;

(ii) To apply pressure on a target country to comply with set objectives;

(iii) As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or

(iv) To prevent and suppress the financing of terrorists or terrorist acts.

Blitzwin uses a fully decentralized automated licensing solution that is responsible for coordinating the implementation of the AML Policy and policy program. Together with government regulators Blitzwin developing AML initiatives, work with other stakeholders to revising the AML policy, assessing new regulatory requirements and investigating potentially suspicious or unusual activity. Blitzwin also provides AML training to all of its employees on a regular basis.

Blitzwin will apply appropriate user due diligence and ongoing monitoring measures required by law using an automated system. Blitzwin will endeavor to prevent users from engaging in illicit or otherwise unauthorized activity. Blitzwin 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.

Know Your Customer

A. Customer Due Diligence.

CIP

Collecting baseline (e.g., wallet address, email address) information at account creation through Blitzwin’s user onboarding portal;

(i) Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user’s account;

(ii) Maintaining records of the information used to identify the user; and

Determining if a user appears on any list of known or suspected terrorists or terrorist organizations provided to the financial institutions based on the above information.

The above steps are operationalized using the following measures:

Identity and Age Verification. A third-party service provider will support’s Blitzwin’s ability to determine the strength 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.

KYC Information

(ii) Geo-blocking for Prohibited Jurisdictions. Blitzwin 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.

(iii) Geo-blocking for Sanctioned Jurisdictions. Blitzwin will also require contractual client certifications that such users are not subject to United States, European Union, or other global sanctions or watch lists, including individuals or entities associated with the United States’ comprehensively sanctioned jurisdictions, Iran, Cuba, North Korea, Syria and the Crimean region of Ukraine. Blitzwin will rely on various risk-based measures to verify these representations including as in the below-described know-your-user (“KYC”) measures and through IP address-based geo-blocking.

(iv) Contractual Prohibitions on Users Onboarding from Prohibited Jurisdictions. Users are notified at onboarding that Blitzwin does not offer services in restricted jurisdictions. Blitzwin’s policy on restricting user activity stems from a combination of its risk, fraud prevention, and AML standards, as well as any assessments associated with the permissibility of its services in certain jurisdictions.

B. Enhanced Due Diligence and Ongoing Monitoring

Blitzwin 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, Blitzwin has implemented a set of red flag indicators that help it determine such behaviours and require further action from the User in assessing the customer information.

Whenever one of those red flags is triggered, the user account will be suspended or withdrawals will be suspended and Blitzwin will inform what actions are required to unblock the account or resume withdrawals. This may be additional verification of the crypto wallet by making the required deposit for the exact amount (more details in the Terms or from the Support Agent in Live Chat) or Enhanced KYC diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of:

(i) Full legal name;

(ii) Country of citizenship;

(iii) Permanent Address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office or other physical location);

(iv) Identification number (either a tax identification number, or, if unavailable, a passport number and country of issue, alien identification card number or number and country of issue of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);

(v) Identification Document; and Source of Funds and Source of Wealth.

(vi) Blitzwin may use 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.

C. Acceptance Policy

Blitzwin will not accept a and will block the users that:

Do not provide the identification information requested by Blitzwin;

(i) Provide fake identification documents;

(ii) Try to use different means to deceive about their location;

(iii) Are from restricted or prohibited jurisdictions; or

Are subject to United States, European Union, or other global sanctions or watch lists;

(iv) Are gambling addicted or have mental health issues;

(v) Its source of funds are originated or exchanges in restricted jurisdictions;

Blitzwin reserves the right to block and suspend player for any other reasons at its own description

Transactions Monitoring

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

Blitzwin 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.

Blitzwin implemented procedures addressing the following two key components of unusual or suspicious activity management:

identification of unusual activity through methods of identification may include employee and customer identification, law enforcement inquiries, other referrals, or transaction and surveillance monitoring system reports; andalert management that focuses on processes used to investigate, evaluate and document identified unusual or potentially suspicious activity.

Blitzwin will use the following processes to achieve both goals:

Transaction Monitoring for Sanctioned or Prohibited Jurisdictions. Blitzwin may in its reasonable discretion impose certain due diligence requests at user balance withdrawal. Blitzwin presently conducts a mixture of manual and automated transaction monitoring processes to identify “red flag” behavior. Where such red flag behavior is identified, Blitzwin may refuse to process any withdrawal attempts or collect additional information from the recipient. Blitzwin will further endeavor to limit any attempted user account funding from prohibited jurisdictions (which are identified in the Blitzwin user facing disclosures and updated from time to time internally) where the associated wallet address indicates that the user or the user’s funds are located in such a prohibited jurisdiction. For instance, Blitzwin may prohibit a user from funding their Blitzwin account using a known U.S. based exchange wallet as such assets indicate that the user is a U.S. person. Users will have the ability to rebut any suspension with additional information as part of Blitzwin’s ongoing transaction monitoring and user due diligence standards.

(i) Screening for Sanctioned Parties. Prior to issuing a Blitzwin funding address to a user, Blitzwin will screen a user’s wallet address against applicable sanctions databases. Such screening measures will rely on third party blockchain forensics vendors such as Chainalysis. Blitzwin will periodically re-screen wallet addresses against such databases.

(ii) Identification of Unusual Activity. Blitzwin will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to its business. Monitoring will be conducted running regular reports of unusual, high risk, or suspicious user activity.

(iii) Anti-Mixing Measures. Blitzwin will utilise software designed to detect other suspicious deposit or withdrawal patterns. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform.

(iv) Chainalysis Review. Every single crypto deposit or withdrawal both indirect and direct will run through Chainalysis and reviewed for signs of fraud or suspicious behaviour. A user’s account will be suspended and reviewed upon alert of potential illicit behaviour. Sufficient proof of wealth may be requested from high-risk accounts. Blitzwin may refuse to withdraw to certain “high-risk” addresses as determined in consultation with Chainalysis risk scoring.

(v) Withdrawal Threshold KYC. Additionally, and independently, every account, wherever or with whomever associated, will be suspended until adequate KYC diligence occurs once that account reaches a withdrawal threshold dependent on the accounts risk characterisation over the life of the account.

D. Other Ongoing Monitoring Controls

Additionally to the above mentioned controlling procedures, Blitzwin has also implemented the following procedures to complement its know your customer and ongoing monitoring procedures:

(i) Ban Evasion Detection. In addition, Blitzwin will utilise third-party service provider software designed to detect the use by one user of multiple accounts. This software relies on detection of links between the same devices used to access multiple accounts. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform. Blitzwin accounts are funded by users using local (non-custodial) or hosted (custodial) wallets. In addition to a Chainalysis screening, Blitzwin monitors user activity within the Blitzwin platform and any withdrawals must meet Blitzwin’s and its third-party service provider’s verification processes. Blitzwin further prohibits peer-to-peer account transfers within the Blitzwin platform infrastructure. Any attempts to circumvent this restriction will be treated as a red flag.

(ii) Time Zone Monitoring. Blitzwin has implemented time zone controls that detects the users device information and crosses it with restricted jurisdiction to understand if they are trying to use geo location software to hide the jurisdictions where they are connecting from.

(iii) Products and Services Review. Blitzwin will establish additional procedures to avoid facilitating user attempts to exploit the Blitzwin platform. Blitzwin has a robust set of user-facing terms that users attest to in order to utilise the Blitzwin platform. Blitzwin will establish certain additional safeguards to mitigate against the risk of such misuse. For instance, Blitzwin may establish policies or procedures for limiting which user assets can be onboarded to the Blitzwin platform. Blitzwin lists the assets that are available for use on the Blitzwin platform. Blitzwin does not allow the use of anonymity enhancing technologies such as mixers, tumblers, or certain coins and tokens. Where Blitzwin becomes aware that an anonymity enhancing technology is being used on the Blitzwin platform, Blitzwin will disallow such use.

(iv) Vendor Management. Blitzwin works with reputable third-party service providers as part of its compliance infrastructure. Blitzwin will periodically assess the strength of its key third party service providers to determine if additional services are needed, the third-party service provider is not performing consistent with its contractual obligations, or if other remedial action is necessary for Blitzwin to comply with this policy. Blitzwin may request information from any third-party service provider as part of its vendor review process.

Compliance Innovation. In addition to vendor management, Blitzwin will continuously monitor any non documentary compliance mechanisms to determine their viability for the Blitzwin program. Blitzwin may run test or trial programs on a limited basis with such compliance vendors to determine the effectiveness of such programs. Blockchain native compliance tools include fraud prevention services, on-chain KYC providers, and other tools designed to reflect the technological features associated with blockchain platforms.

Blitzwin, with the assistance of its legal counsel and under the oversight of its CCO, may provide employees AML, anti-terrorist financing and trade sanctions compliance training on a periodic basis, as deemed appropriate.

Blitzwin 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.