Anti-Money Laundering

1. Company Policy Statement

Froze is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (“ AML/CFT ”) applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, Froze expressly prohibits and rejects the use of Froze products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering (“ AML ”) laws, regulations and norms. Froze continues to monitor norm setting parameters promulgated by the Financial Action Task Force (“ FATF ”) and certain gaming trade groups in addition to the Curaçao Gaming Control Board and will take necessary action as it deems appropriate to reflect changes in law.

Froze’s intention is to follow global best practices in guarding against Froze products being used to facilitate such activities. Those best practices include:

• Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;
• Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;
• Provision of related education and training to relevant personnel; and
• Independent reviews, monitoring and maintenance of the policy, procedures and controls.

2. Definitions

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.

Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions.For example, they are used:

• To encourage a change in behaviour for a target country or regime;
• To apply pressure on a target country to comply with set objectives;
• As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or
• To prevent and suppress the financing of terrorists or terrorist acts.

3. Governance and Oversight

Froze has appointed a Chief Compliance Officer (“ CCO ”) that is responsible for coordinating the implementation of the AML Policy and policy program. The Chief Compliance Officer’s duties also include developing AML initiatives, work with other frozeholders to revising the AML policy, assessing new regulatory requirements and investigate potentially suspicious or unusual activity. Froze also provides AML training to all of its employees on a regular basis.