Anti-Money Laundering Policy

Effective date: November 10, 2025

1. Introduction

In order to continue its goal to provide a safe environment for players on its system, VOLTAPE INTERACTIVE TECHNOLOGY LIMITED ("VOLTAPE GAMES") crafted this Anti-Money Laundering and Counter-Terrorism Policy ("AML/CTF Policy").

This AML/CTF Policy is designed to comply with the applicable laws and regulations of VOLTAPE GAMES Eligible Jurisdictions and to support the implementation of a risk-based approach to anti-money laundering ("AML") and counter-terrorism financing ("CTF") activities within our organization.

VOLTAPE GAMES operates with Know Your Customer ("KYC") providers and Payment Service Providers (collectively, the "Providers") that are regulated entities and also comply with the applicable laws and regulations of VOLTAPE GAMES Eligible Jurisdictions.

2. Scope

This policy applies to all personnel, including employees, contractors, consultants, and other third parties, who are involved in AML/CTF activities. In particular, are targeted VOLTAPE GAMES employees involved with payments, fraud, customer support, and compliance.

3. Risk-Based Approach

Our organization is committed to implementing a risk-based approach to AML/CTF activities. VOLTAPE GAMES will identify, assess, and manage the AML/CTF risks associated with our activities, products, services, customers, customers’ transactions, and geographic locations.

4. Risk Assessment

VOLTAPE GAMES will conduct periodic risk assessments to identify, assess, and manage the AML/CTF risks associated with our activities and transactions. The risk assessment will consider the following factors:

  • The products and services offered by our organization;
  • The customers VOLTAPE GAMES serves;
  • The frequency, size, and complexity of customer transactions;
  • The geographic locations of our customers;
  • The jurisdictions in which VOLTAPE GAMES operates;
  • The risk of money laundering or terrorism financing associated with specific customers or groups of customers;
  • The flow of funds into and out of VOLTAPE GAMES organization;
  • Our organizational structure;
  • The effectiveness of our internal controls; and
  • Any other relevant factors.
  • 5. Policies and Procedures

    VOLTAPE GAMES will develop, implement, and maintain policies and procedures that will include:

  • Customer due diligence procedures;
  • Ongoing monitoring of customer transactions;
  • Internal reporting and record keeping requirements;
  • Training and awareness programs;
  • Sanctions screening;
  • Suspicious activity reporting;
  • Independent testing of internal controls;
  • Audit and compliance functions; and
  • Manual and automatic internal controls.
  • These policies and procedures are handled by both VOLTAPE GAMES and its Providers.

    7. Politically Exposed Persons (PEPs)

    Individuals who are or have been entrusted with major public tasks, as well as individuals linked with them, are considered PEPs. PEPs, like other high-risk customers, are subject to enhanced due diligence requirements to mitigate the AML/CFT risk they pose.

    VOLTAPE GAMES and its Providers will establish policies and procedures to identify and monitor Politically Exposed Persons (PEPs) in accordance with applicable laws and regulations.

    8. Sanctions Lists

    VOLTAPE GAMES and its Providers will screen customers and transactions against applicable sanctions lists, in accordance with applicable laws and regulations.

    By using VOLTAPE GAMES application, you represent that you are not on any Specially Designated Nationals or Blocked Persons list (”SDN”) maintained by the US Office of Foreign Assets Control.

    9. KYC Procedures

    VOLTAPE GAMES reserves the right to request users the following details:

  • First name;
  • Last name;
  • Live selfie;
  • Mailing street address;
  • Date of birth;
  • Email address;
  • Password;
  • Mobile telephone number.
  • VOLTAPE GAMES reserves the right to request additional documentation in the interest of security and compliance, notably

  • A Utility Bill no older than ninety (90) calendar days from the date of presentment;
  • A Bank or Credit Card statement no older than ninety (90) calendar days from the date of presentment;
  • A Voided check.
  • In the event that VOLTAPE GAMES requires documentation prior to approving a withdrawal, VOLTAPE GAMES will send a documentation request email to the customer. If no documentation is provided, a reminder email will be sent. If fourteen (14) calendar days have passed without receiving documentation from the customer, VOLTAPE GAMES will send a "24-hour notice" email to the customer's registered email address. If the customer fails to provide documentation at that point, VOLTAPE GAMES shall suspend the user's VOLTAPE GAMES account.

    9. Monitoring and Review

    VOLTAPE GAMES will monitor and review the effectiveness of its AML/CTF policy and procedures on an ongoing basis. VOLTAPE GAMES will also monitor and review changes in the AML/CTF standard industry best practices and adjust its policies and procedures in a proportionate matter.

    10. Reporting and Recordkeeping

    VOLTAPE GAMES and its Providers will report suspicious activities to the appropriate authorities, as required by law, and will maintain records of all AML/CTF activities in accordance with applicable laws and regulations.

    A VOLTAPE GAMES employee cannot disclose information when that team member knows or suspects a report has been made to the authorities and that the disclosure may prejudice an investigation (i.e., by law enforcement agencies). The offense of prejudicing an investigation occurs if you disclose information that you know or suspect may prejudice an investigation, or if you conceal, or otherwise interfere with information or material relevant to an investigation.

    However, there is nothing to prevent an employee from making normal inquiries to understand a transaction in the course of their work (especially those needed to determine whether an initial concern may amount to suspicion of money laundering). Employees are to contact the Legal compliance team as soon as an issue becomes apparent to minimize the risk of delay. If put under pressure by a customer to honor their request(s) or to explain delays, employees are to contact the Legal compliance team for assistance and take great care to avoid making any statement that may constitute tipping off.

    11. Training and Awareness

    VOLTAPE GAMES will provide annual training and awareness programs to ensure that its personnel and new hires understand its AML/CTF policies and procedures and are aware of the potential risks associated with AML/CTF activities.

    Furthermore, all VOLTAPE GAMES team members will be encouraged to use their judgment and report anything they consider potentially suspicious rather than leaving it to someone else more directly involved.

    Non-compliance with this policy may result in disciplinary action for any personnel including termination and potential criminal and civil penalties.

    12. Anti-Corruption and Anti-Bribery

    VOLTAPE GAMES is committed to the highest ethical standards in all of its business dealings and contacts. VOLTAPE GAMES has a zero-tolerance policy for any sort of bribery, corruption, fraud, or unethical behavior among workers, as well as between VOLTAPE GAMES and its employees and external parties. VOLTAPE GAMES likewise expects third parties acting on its behalf to adhere to the same criteria.

    13. Conclusion

    VOLTAPE GAMES is committed to implementing a risk-based approach to AML/CTF activities and to complying with the applicable laws and regulations of its Eligible Jurisdiction. VOLTAPE GAMES will periodically assess and review its AML/CTF policies and procedures to ensure that they are effective and up to date.