Know Your Business (KYB) and Know Your Customer (KYC) Policy

• Company: Tusitier Ltd
• Registration Number: 137952
• Registered Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960
• License: B2B License No. ALSI-202505043-FI2 (Autonomous Island of Anjouan, Union of Comoros)

1. Purpose

This document contains the Know Your Business (KYB) and Know Your Customer (KYC) policies for Tusitier Ltd (operating the brand pwp.bet), which outline the principles and procedures for verifying the identity and legitimacy of our clients. These policies are implemented by the Compliance Director to ensure full adherence to the regulatory requirements of the Autonomous Island of Anjouan.

2. Know Your Business and Anti-Money Laundering

Know Your Business (KYB) and Anti-Money Laundering (AML) is the process of verifying the identity and legitimacy of the companies who seek to engage with Tusitier Ltd as partners, suppliers, and buyers of online gaming software and B2B services. KYB aims to ensure that Tusitier Ltd only works with companies that have a genuine capability to produce or purchase such activity, and that are not involved in any illegal or unethical activities.

Acknowledging the differing levels of risk exposure, Tusitier Ltd applies a simplified KYB process to lower-risk client categories. Such approach is based on the understanding that these entities are subject to statutory reporting, continuous disclosure, and regulatory oversight, with ownership structures that are transparent and verifiable. Tusitier Ltd reserves the right to escalate any client to the full KYB procedure if risk factors emerge. Escalation may occur when screening indicates elevated money laundering or terrorist financing risks, sanctions exposure, or adverse media, or where ownership and control structures are complex, opaque, or cannot be sufficiently verified.

Tusitier Ltd applies the following KYB procedures to its clients:

• Registration: The client must provide information such as the name, registered address, company identification number, and other relevant contact details, as well as the name and email of the person who will act as the authorized representative on behalf of the client.
• Verification: The client must provide company-related materials, such as a copy of the company registration certificate, register of shareholders and other relevant documents depending on the level of risk exposure. Tusitier Ltd may also request additional information or documents to verify the nature and scope of the business, such as the annual report, financial statements, or third-party certifications.
• Screening: The client must undergo a screening process to check whether it is subject to any sanctions, restrictions, or adverse media coverage that may affect its eligibility or suitability. Tusitier Ltd may use external sources or databases to conduct the screening, such as the European Union's sanctions list, the United Nations' consolidated list, or the World-Check database.
• Approval: The client must receive formal approval from Tusitier Ltd before it can start operating and engaging in gaming services on the pwp.bet platform. Tusitier Ltd reserves the right to reject any application that does not meet its KYB criteria or standards, or that poses a potential risk to its reputation or operations.
• Monitoring: Tusitier Ltd monitors the organizations that have gone through the KYB process to ensure they are not entered to global sanctions lists and that their representatives are not on Politically Exposed Person (PEP) screening lists. If such event occurs, a representative of Tusitier Ltd will reach out to the organization and initiate contract termination procedure. Tusitier Ltd also requires its clients to promptly notify of any changes or updates in their information or status that may affect their eligibility or suitability to join or remain on the platform.

3. Know Your Customer

Know Your Customer (KYC) is the process of verifying the identity and legitimacy of the individuals who act as the representatives or agents of the companies who seek to join the Tusitier Ltd framework as partners, suppliers and buyers of online gaming software. KYC aims to ensure that Tusitier Ltd only works with individuals who have the proper authorization and capacity to act on behalf of their company, and that are not involved in any illegal or unethical activities.

Acknowledging the differing levels of risk exposure, Tusitier Ltd has opted to omit requirement of KYC for lower-risk client categories. However, Tusitier Ltd reserves the right to escalate any client to the full KYC procedure if risk factors emerge. Escalation may occur when screening indicates elevated money laundering or terrorist financing risks, sanctions exposure, or adverse media, or where ownership and control structures are complex, opaque, or cannot be sufficiently verified.

As part of its KYC process, Tusitier Ltd conducts an identification procedure that requires its clients providing details such as the name, email address, position of the individual designated as the client’s authorized representative, as well as proof of the individual’s authorized signatory rights. Tusitier Ltd also requires its clients to promptly notify of any changes or updates in their information or status that may affect their eligibility or suitability to join or remain on the platform.

4. Risk Assessment and Management

Tusitier Ltd employs a risk-based approach to assess and manage the AML/CTF risks associated with its clients. Clients are classified into risk categories (Low, Medium, High) based on factors such as geographic location, corporate structure, and the specific nature of their business. Enhanced Due Diligence (EDD) is mandatory for all high-risk clients, which includes obtaining additional identity documentation and establishing the source of wealth and funds.

5. Record Keeping

All records obtained through the KYB and KYC processes, including identification documents, corporate registries, and communication logs, are securely maintained by Tusitier Ltd for a minimum period of five (5) years following the termination of the business relationship or the date of the occasional transaction, strictly in accordance with Anjouan Gaming regulations and international AML standards.

6. Suspicious Activity Reporting (SAR)

If any transaction or client activity raises suspicion of money laundering, terrorist financing, or fraud, the Compliance Director is responsible for filing a Suspicious Activity Report (SAR) with the relevant regulatory authorities in the Autonomous Island of Anjouan. Tusitier Ltd strictly enforces a "no-tipping-off" policy, ensuring that the client is not informed that a report has been filed.

7. Data Protection and Privacy

All personal and corporate data collected during the KYC/KYB procedures is processed strictly in accordance with applicable international data protection standards. Tusitier Ltd implements robust technical and organizational measures to prevent unauthorized access, alteration, or disclosure of sensitive client information, ensuring that data is used exclusively for compliance purposes.

8. Implementation

Tusitier Ltd continuously monitors the status of Account Holders on the pwp.bet platform.

Tusitier Ltd may suspend or terminate the account of any client that fails to comply with its KYB and KYC policy and procedures, or that provides false, misleading, or fraudulent information or documents.

9. Review and Updates

Tusitier Ltd monitors and reviews its KYB and KYC policy and procedures at least biannually to ensure that they are effective, efficient, and compliant with the applicable laws and regulations of the Anjouan Gaming Board. In the interim, Tusitier Ltd may update or amend its KYB and KYC policy and procedures at any time, and will notify its clients of any changes or requirements.

10. Training

Tusitier Ltd is committed to providing adequate and appropriate training for all relevant people in the organization on its KYB and KYC policy and procedures. The Compliance Director ensures that the training ensures compliance and understanding of the purpose, scope, and implementation of the policies, as well as the roles and responsibilities of the staff involved. The training also covers the legal and regulatory framework governing the KYB and KYC requirements, the risks and consequences of non-compliance, and the best practices and standards for conducting due diligence and verification checks. The training is tailored to the different levels and functions of the staff, depending on their exposure and involvement in the KYB and KYC process.

For example, the frontline staff who interact directly with clients, such as the sales and marketing team, are required to undergo more in-depth and frequent training, as they are responsible for collecting and verifying the information and documents from clients. They are also trained on how to identify and report any suspicious or unusual activities or transactions that may indicate fraud, money laundering, or other criminal activities.