Risk Based Approach

Chariot Interactive LLC uses a risk-based approach to AML compliance, assessing risks associated with customers, geographies, payment methods, and platform features. Higher-risk users or behaviors trigger enhanced due diligence (EDD) and additional monitoring protocols.

Customer Identification and Verification (CIP / KYC)

While sweepstakes participation may be exempt from traditional gambling regulations, Chariot Interactive LLC performs Know Your Customer (KYC) procedures for users who: – Redeem eCredits for prizes exceeding regulatory thresholds – Participate in promotions or activities deemed high risk – Are flagged through automated AML risk indicators KYC verification includes: – Legal name, date of birth, and physical address – Government-issued ID verification for high-risk or redemption cases – Sanctions and Politically Exposed Person (PEP) screening

Monitoring and Reporting

All transactions and user activities are monitored in real time and through post-event review using rule-based and behavior-based systems. Suspicious activity is escalated to the Compliance Officer. When required, a Suspicious Activity Report (SAR) is filed with the Financial Crimes Enforcement Network (FinCEN).

Prohibited Activities

Users may not: – Structure transactions to evade reporting thresholds – Use stolen or synthetic identities – Attempt to launder proceeds through repetitive or circular credit usage – Access the platform from sanctioned countries or jurisdictions

Recordkeeping

Chariot Interactive LLC retains AML-related records, including customer identification data, transaction records, communications, and SAR filings, for a minimum of five (5) years in accordance with BSA requirements.

Training and Governance

All relevant employees receive mandatory AML training annually. The Compliance Officer oversees policy enforcement, alert reviews, and regulatory reporting. This AML Policy is reviewed and updated annually or upon significant regulatory or business changes.

Redeem eCredits for prizes exceeding regulatory thresholds – Participate in promotions or activities deemed high risk – Are flagged through automated AML risk indicators

KYC verification includes:

• Legal name, date of birth, and physical address
• Government-issued ID verification for high-risk or redemption cases
• Sanctions and Politically Exposed Person (PEP) screening

Monitoring and Reporting

All transactions and user activities are monitored in real time and through post-event review using rule-based and behavior-based systems. Suspicious activity is escalated to the Compliance Officer. When required, a Suspicious Activity Report (SAR) is filed with the Financial Crimes Enforcement Network (FinCEN).

Prohibited Activities

Users may not: – Structure transactions to evade reporting thresholds – Use stolen or synthetic identities – Attempt to launder proceeds through repetitive or circular credit usage – Access the platform from sanctioned countries or jurisdictions

Recordkeeping

Chariot Interactive LLC retains AML-related records, including customer identification data, transaction records, communications, and SAR filings, for a minimum of five (5) years in accordance with BSA requirements.

Training and Governance

All relevant employees receive mandatory AML training annually. The Compliance Officer oversees policy enforcement, alert reviews, and regulatory reporting. This AML Policy is reviewed and updated annually or upon significant regulatory or business changes.