KYC-AML-CFT Policy

1. INTRODUCTION

Raw Entertainment B.V. (referred to below as “Roobet” or the “Company”) is a company duly established under the laws of Curaçao, registered under company number 157205, with its registered office at Korporaalweg 10, Curacao, Curaçao. The Company operates www.roobetcanada.net pursuant to licence OGL/2024/687/0427 issued by the Government of Curacao.

As a reputable international business and an established name within the gambling industry, Roobet explicitly condemns, forbids and rejects any use of its website or services for unlawful purposes, including money laundering and terrorist financing.

Roobet has introduced a range of safeguards and internal procedures designed to identify and discourage illegal activities on its website. These measures comply with applicable Curaçao regulations concerning Anti-Money Laundering and the Prevention of Terrorist Financing and reflect recognised industry best practices.

2. WHAT IS MONEY LAUNDERING AND TERRORISM FINANCING?

Money Laundering – Money laundering involves processing or “washing” the proceeds of criminal activity through the financial system to conceal their unlawful source. This process is divided into 3 stages:

a) Placement – At this stage, illicit funds are separated from the criminal activity that generated them and brought into the legitimate financial system.

b) Layering – After entering the legitimate financial system, the funds pass through a complicated network of financial transactions. These transactions make the trail connecting the money to the criminals and their unlawful activities more difficult to follow and identify.

c) Integration – This stage occurs when criminals return illegally obtained funds to the economy through an apparently legitimate source or transaction, making the illicit money seem lawful.

Terrorism Financing – Terrorism financing involves collecting or receiving funds with the intention or knowledge that those funds will be used to finance or carry out a terrorist act.

3. HOW DO WE FIGHT IT?

Roobet has developed a series of safeguards, internal procedures and policies to identify and prevent the use of its website and services for illegal activities, including money laundering and terrorist financing. These measures and procedures are organised into several layers:

a) Internal Policies & Procedures;

b) Know Your Customer;

c) Transaction Monitoring;

d) Governance & Training;

e) Reporting.

4. KNOW YOUR CUSTOMER

Roobet carries out appropriate due diligence on its players when they register and throughout the ongoing relationship. This process consists of several stages, which may be completed at different times according to the player’s activity on the website. As part of its due diligence procedures, Roobet will:

a) Verify the player’s identity, including their name, date of birth, address and other relevant details;

b) Conduct PEP and sanctions screening; and

c) Establish the origin of the player’s funds when and where appropriate.

5. TRANSACTION MONITORING

Roobet recognises that preventing money laundering and terrorist financing also involves examining the transactions carried out by its players. We have therefore introduced a transaction monitoring system combining internal and external software tools to identify, discourage and report potentially unlawful activity on the website through analysis of players’ gameplay patterns and account activity. The same information helps us assess player risk and review and strengthen our control systems.

6. GOVERNANCE & TRAINING

Roobet has designated an MLRO to oversee the implementation of its AML Policy and develop AML initiatives that strengthen internal procedures. The MLRO also works with other stakeholders to review the AML Policy, evaluate new regulatory obligations and investigate activity that may be suspicious or unusual.

Roobet is additionally committed to developing AML awareness throughout its organisation by providing annual AML training to every employee, irrespective of their level of seniority.

7. REPORTING & COLLABORATION

As an online casino regulated in Curaçao, Roobet has established appropriate procedures to identify and report unusual or suspicious transactions to the Curaçao Financial Intelligence Unit (FIU). Roobet is also willing to cooperate with government authorities conducting investigations into unlawful activities where assistance from Roobet may be required.