KYC Policy

KYC POLICY

PURPOSE

With the implementation of the Policy presented, the Company aims to achieve the following results:

• processes and controls are implemented to mitigate the risk arising from the Company being used, intentionally or unintentionally, for ML/TF purposes;
• risky potential customers are identified;
• the Company successfully complies with legal obligations related to AML/CTF and others and effectively implements its Anti-Money Laundering Policies and Procedures, Minors Policy, Customer Interaction Policy and Responsible Gaming Policy.

GRANTING CUSTOMER STATUS

A customer is understood to be any natural person who has formed a business relationship with the Company by creating an online account on br.meridianbet.com website. In this sense, the Company's operational or reputational risk is generally based on the economic activity and/or source of wealth of this individual, which can be evaluated based on the information available in the registration process.

The player may also be denied access to the site when deemed by the MLRO. Usually, the denial or termination of the business relationship occurs in the following cases:

• The player has connections to a jurisdiction that is high-risk to the company, either by ML/CFT or trading standards
• The client provided false documents in the CDD procedure
• The customer used fake credit/debit cards that resulted in chargeback requests from the payment provider
• There are indications that the customer is using multiple accounts to their advantage
• If the customer submits expired identification documents or submits a document that is torn or unclear in any way
• The client refuses to send the requested CDD documents
• If it is determined at the time of registration that the customer is a minor
• If the customer is a PEP, and the Board members do not allow the customer to continue the business relationship

KEY CONDITIONS OF CUSTOMER ACCEPTANCE

When initiating or evaluating and before concluding or terminating the business cooperation with the client (assigning or suspending player status), the Company performs the following checks:

 Age verification

No person under the age of 18 can be accepted as our customer, register and place bets on the br.meridianbet.com website. However, if, after registration, reasonable doubts arise or there is strong evidence indicating that the approved customer is underage, that user's customer status will be suspended.

Verification of geographical origin

The residence and place of birth of customers are taken into account in the registration process, as these data may indicate a substantial geographical risk arising from those natural persons. Potential clients originating from high-risk countries are considered a threat by the Company and as such are prohibited from granting the status of our clients.

Customer Risk Check

If, after registration, there is a reasonable doubt that points to some form of at-risk interaction with the player, namely:

- the player uses double accounts;

- the source of the staked funds may indicate an ML issue;

- The player may have a criminal record or adverse means

- the player is a PEP or a close relative of the player

- Occupation and employment status

The Company, in accordance with its legal obligations and internal corporate policies, aided by various CDD tools, reserves the right to refuse additional services to such customers, as well as freeze or suspend the customer's account until satisfactory feedback is obtained. In addition, the type of game the client on the site is also taken into account.

Product/interface risk check

The Company acknowledges that certain games offered may pose a major/minor ML/TF threat. br.meridianbet.com offers a variety of online casino games and online sports betting for players, and ranks risk by the game itself. In addition to gambling, the Company recognizes that risk may arise from the risk of delivery channels or interface risk, such as products or services offered to non-face-to-face customers or online services.

Payment/transaction risk

The Company has in its general offer on the website a variety of payment methods that a customer can use at all times. Methods range from credit/debit cards to e-wallets and coupons. Multiple use of all payment methods can point to higher risk behavior, given that the customer is trying to hide the trail of these transactions.

No bonus

In accordance with Federal Law No. 14,790/2023, art. 29, I, and art. 42, §1, II, of Ordinance SPA/MF No. 1,231/2024, and in compliance with Responsible Gaming practices, MeridianBet does not grant any form of advance, anticipation, bonus or prior advantage, even if for the mere purpose of promotion, disclosure or advertising, for the placing of a bet.