KYC POLICY INOUT GAMES

Effective date: June 1, 2025

Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros

IOGr B.V. (“Company”, “we” “our, or “us”), is the owner/provider of the website located at https://inout.games (the “Website”), and all subdomains, subpages and successor sites features, tools available thereon (the “Website”). We have created this Privacy Policy to inform you about how we manage, collect and use your information provided through your use of Website.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. Any information you may provide through your use the Website is subject to the terms of this Privacy Policy, as may be updated by us from time to time. Please read this Privacy Policy carefully before using the Website. This Privacy Policy does not apply to any third-party websites, services, providers, or applications, even if such are available or accessible through the Website. In this Privacy Policy you will read about:

1. Purpose and Scope

This Policy outlines the Know Your Customer (KYC) and Anti-Money Laundering (AML) measures applied by the Company to all B2B clients in accordance with applicable laws and international standards. It is aimed at preventing the use of the Company’s services for money laundering, terrorism financing, or any other criminal activity.

This policy applies to all corporate clients, including operators, resellers, and service integrators who engage with the Company on a commercial basis

2. Risk-Based Approach

The Company adopts a risk-based approach (RBA) to client onboarding and ongoing monitoring, including:

• Client risk profiling based on jurisdiction, ownership structure, and business model.
• Assignment of appropriate due diligence level (CDD or EDD).
• Ongoing risk review at least once every 12 months or upon material change in the Client’s status.

3. Due Diligence Levels

3.1. Customer Due Diligence (CDD)

• Certificate of Incorporation / Trade Register Extract (recent, dated within 3 months)
• Articles of Association or Memorandum of Association
• Proof of business address (utility bill or bank statement of the entity)
• Corporate structure chart identifying shareholders and ultimate beneficial owners (UBOs)
• Identification documents for directors and UBOs (>25% ownership threshold)
• Proof of identity: Government-issued photo ID (passport or national ID card)
• Proof of residence: Recent utility bill or bank statement (dated within 3 months)

3.2. Enhanced Due Diligence (EDD)

• EDD is conducted in cases where the Client:
• Operates from a high-risk or non-cooperative jurisdiction (e.g. FATF blacklist)
• Has complex ownership structures (e.g. nominee shareholders or offshore holdings)
• Is owned or controlled by Politically Exposed Persons (PEPs)
• Presents other high-risk indicators (e.g. history of regulatory penalties)

EDD may include:

• Source of Funds / Source of Wealth documentation
• Third-party AML audit reports
• Proof of gaming licenses, where applicable
• Additional background checks

4. Ongoing Monitoring

• All B2B clients are reviewed periodically for changes in risk status, ownership, or location.
• Any suspicious activity may result in temporary suspension pending further investigation.
• Clients are obliged to notify the Company of any changes to their legal or ownership structure.

5. PEP and Sanctions Screening

• All directors and UBOs are screened against global sanctions and PEP lists using trusted databases (e.g. Dow Jones, Refinitiv, ComplyAdvantage).
• Clients with unresolved matches may be subject to rejection or EDD procedures.

6. Recordkeeping

The Company retains all KYC records (digital or physical) for at least 6 years after the end of the business relationship, in accordance with AML regulations of Anjouan.

7. Restricted Jurisdictions

The Company does not onboard B2B clients registered in, or beneficially owned by individuals from:

• FATF High-Risk or Non-Cooperative Jurisdictions
• Countries sanctioned by the UN, EU, or OFAC
• Union of Comoros (for white-label clients targeting the same jurisdiction)
• Any other jurisdictions prohibited by the Anjouan Offshore Financial Authority

8. Failure to Comply

Failure to provide accurate and timely KYC documentation may lead to:

• Rejection of onboarding request
• Suspension of services
• Termination of business relationship
• Reporting to relevant authorities

9. Amendments

The Company reserves the right to update this Policy to comply with changing regulatory requirements. Clients will be notified of any material amendments in advance.

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