As part of our commitment to ethical business and integrity, MervCF Limited adopts a zero‑tolerance policy on money laundering. Money laundering is a serious crime that can damage the integrity of our business and harm society.

Measures to prevent money laundering

• Identification and verification of participants: robust ID and documentation checks to validate participation in our lottery.
• Transaction monitoring: careful monitoring and analysis of all transactions to identify suspicious activity (e.g., unusual large transactions, frequent transfers to/from various wallets, or patterns outside normal behaviour).
• Education and awareness: staff training and resources to recognize and report suspicious activity.
• Cooperation with law enforcement: work with relevant authorities to investigate and report suspicious activity and comply with legal requirements.
• Periodic review: regular review and revision of policies and procedures to ensure effectiveness.
• Ticket limits: each player can buy a maximum of 100 tickets in each lottery.

MervCF Limited is not a financial institution under Costa Rican law and is not directly subject to statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. Nevertheless, consistent with Costa Rican AML/CFT regulations (2016) and FATF norms, MervCF Limited expressly prohibits the use of its products for any illicit activity, including money laundering, terrorist financing, or sanctions violations.

MervCF Limited follows global best practices, including:

• Adoption of written AML/CFT policy, procedures, and controls.
• Designation of a compliance officer to oversee implementation.
• Education and training for relevant personnel.
• Independent reviews, monitoring, and maintenance of the program.

Money Laundering: process of making illegally gained proceeds appear legal, generally in three steps: placement, layering, and integration.

Placement: placing unlawful proceeds into financial institutions through deposits or other avenues.

Layering: separating proceeds from their origin via complex transactions (e.g., money orders, wire transfers, securities, assets).

Integration: using apparently legitimate transactions to disguise illicit proceeds and reintroduce funds into normal use.

Suspicious Activity: activity where indications suggest fraudulent or illegal purposes.

The Chief Compliance Officer (CCO) coordinates AML program implementation, develops initiatives, revises policy, assesses new regulatory requirements, and investigates potentially suspicious activity. AML training is provided regularly to employees.

MervCF Limited applies appropriate user due diligence and ongoing monitoring required by law.

A. Customer Due Diligence (CDD)

Risk‑based CDD to understand user relationships and develop risk profiles. The CIP includes procedures for:

• Collecting baseline onboarding info (e.g., wallet and email addresses);
• Monitoring risk profile of the wallet used to fund accounts;
• Maintaining records used to identify the user; and
• Determining whether the user appears on terrorist/sanctions lists.

Operational measures include:

• Identity & Age Verification: third‑party provider validates KYC details and screens sanctions/jurisdictions.
• Customer Information: collection of KYC details (wallet, name, address, country, DOB/postal code) prior to issuing funding address.
• Geo‑blocking (Prohibited & Sanctioned jurisdictions): IP‑based controls and certifications; examples include Iran, Cuba, North Korea, Syria, and Crimea.
• Contractual Prohibitions: users are notified that services aren’t offered in restricted jurisdictions.

B. Enhanced Due Diligence (EDD) & Ongoing Monitoring

Red‑flag triggers lead to suspension and EDD, which may require:

• Full legal name, citizenship country, permanent address;
• Identification number and document;
• Source of funds and source of wealth.

C. Acceptance Policy

• Block users who fail to provide requested ID, provide fake documents, deceive location, are from restricted/sanctioned jurisdictions, are gambling addicted/have mental health issues, or whose funds originate in restricted jurisdictions.
• MervCF Limited may block/suspend players for other reasons at its own discretion.

Transactions Monitoring

• Ongoing monitoring using in‑house and third‑party rule‑based systems; identification and alert management processes.
• Due‑diligence at withdrawal; may refuse withdrawals or request additional information where red flags exist.
• Screening against sanctions databases; periodic re‑screening; use of blockchain forensics (e.g., Chainalysis).
• Monitoring for unusual size/volume/patterns; anti‑mixing measures; high‑risk address restrictions; withdrawal‑threshold KYC.

D. Other Ongoing Monitoring Controls

• Ban‑evasion detection via device‑link analysis; prohibition of P2P transfers on the platform.
• Time‑zone monitoring to detect geo‑location spoofing.
• Product & service review to prevent exploitation; disallow anonymity‑enhancing tech (mixers/tumblers/certain coins).
• Vendor management and periodic assessments; compliance innovation and trials of blockchain‑native tools.

Training on AML, counter‑terrorist financing, and sanctions compliance is provided periodically under CCO oversight, with support from legal counsel, as appropriate.

MervCF Limited will report unusual or suspicious transactions as required under applicable law. Customers identified on sanctions lists or linked to money laundering, terrorism financing, or other criminal activity will be reported to the regulator as suspicious activity.