Anti-Money Laundering & Counter-Terrorist Financing Policy

Elovolve is operated by ExcaliburHQ B.V., a company incorporated in the Netherlands.

Elovolve does not represent itself as a bank, payment institution, electronic money institution, crypto-asset service provider ("CASP"), or other regulated financial institution unless separately authorised or registered to provide such services.

Where Elovolve uses regulated or specialised third-party providers to process payments, verify identities, process crypto payments or facilitate other payment methods, those providers may perform their own legally required customer due diligence, transaction monitoring, sanctions screening and other compliance procedures.

The use of third-party providers does not prevent Elovolve from implementing its own risk-based controls where appropriate.

Where applicable law imposes direct AML, sanctions or financial-crime obligations on Elovolve, Elovolve will comply with those obligations.

Elovolve applies a risk-based approach to financial crime prevention.

We assess risk based on factors including:

• the identity and behaviour of users;
• whether the user is a Player or Coach;
• geographic location;
• payment method;
• transaction size;
• transaction frequency;
• transaction patterns;
• use of cryptocurrency;
• use of gaming skins or other digital assets;
• unusual account activity;
• suspected fraud;
• sanctions exposure;
• attempts to circumvent Elovolve's payment systems;
• information received from payment providers or other trusted third parties.

Not every transaction or user presents the same level of risk.

Where appropriate, Elovolve may apply enhanced controls to higher-risk users, transactions or activities.

Elovolve may require users to provide information necessary to establish and maintain a trustworthy marketplace.

For Coaches, this may include:

• legal name;
• date of birth;
• country of residence;
• address;
• contact information;
• gaming profiles;
• payment information;
• identity verification information;
• information required by payment providers.

Where payment onboarding or identity verification is performed by Stripe or another third-party provider, the relevant provider may collect and verify the information directly.

Elovolve may rely on verification performed by an appropriate third-party provider where permitted by law and appropriate for the relevant risk.

Where necessary to manage financial crime risks, Elovolve may require additional verification before allowing a user to:

• provide coaching services;
• receive funds;
• withdraw funds;
• use certain payment methods;
• complete certain transactions;
• continue using the Platform following a risk alert.

Additional information may include proof of identity, proof of address, information concerning the source or purpose of funds, or other information reasonably necessary to assess risk.

If required information cannot be satisfactorily verified, Elovolve may restrict or terminate the relevant account.

Elovolve uses third-party payment providers to process payments and payouts.

These may include:

• Stripe;
• Stripe Connect;
• cryptocurrency payment providers;
• skin-payment providers;
• other financial or payment service providers.

Payment providers may independently perform:

• identity verification;
• KYC;
• sanctions screening;
• transaction monitoring;
• fraud detection;
• payment risk assessment;
• source-of-funds checks;
• regulatory reporting.

Elovolve may receive information from these providers concerning payment status, verification status, risk indicators, fraud alerts or other information necessary to operate the Platform.

Where cryptocurrency payments are supported, Elovolve intends to use specialised third-party payment providers rather than operate its own cryptocurrency exchange or custody infrastructure.

Depending on the provider and payment method, supported assets may include cryptocurrencies such as Bitcoin, Ethereum and Solana.

Elovolve may receive information such as:

• payment amount;
• cryptocurrency type;
• transaction identifier;
• blockchain transaction information;
• EUR equivalent value;
• payment status;
• wallet information where provided by the payment provider;
• risk or compliance information provided by the payment provider.

Elovolve may refuse or restrict cryptocurrency payments where the payment provider identifies compliance, sanctions, fraud or financial-crime concerns.

Where a third-party crypto provider is subject to applicable AML/CFT requirements, that provider remains responsible for carrying out the regulatory controls applicable to its own regulated services.

Where Elovolve supports payments using CS2, Dota 2 or other gaming skins, Elovolve intends to use specialised third-party skin-payment providers.

Elovolve does not intend to operate its own skin exchange or directly provide a general-purpose skin trading service.

Third-party providers may be responsible for:

• Steam authentication;
• item valuation;
• trade processing;
• custody;
• fraud detection;
• inventory verification;
• liquidation;
• settlement.

Elovolve may receive information necessary to determine whether a skin payment has successfully completed and the EUR value attributed to the payment.

Elovolve may reject transactions where there are indications of:

• stolen items;
• fraudulent activity;
• manipulated valuations;
• suspicious trading;
• payment fraud;
• sanctions concerns;
• abuse of the payment system.

Elovolve may monitor transactions and account activity for unusual or suspicious patterns.

Examples of potentially suspicious activity include:

• transactions inconsistent with the user's normal activity;
• unusually frequent transactions;
• repeated high-value transactions;
• attempts to split transactions to avoid controls;
• multiple accounts appearing to be controlled by the same person for suspicious purposes;
• unusual payment and refund patterns;
• repeated chargebacks;
• suspicious cryptocurrency activity;
• suspicious gaming-skin activity;
• attempts to convert the Platform into a money-transfer service;
• transactions involving high-risk jurisdictions;
• attempts to circumvent payment restrictions;
• transactions involving sanctioned persons or jurisdictions;
• activity that appears to have no reasonable commercial purpose.

The presence of one indicator does not automatically mean that a user is involved in financial crime.

Elovolve may consider multiple factors before taking action.

Elovolve may screen users, transactions and other relevant parties against applicable sanctions lists and restrictions.

Where required or appropriate, this may include screening against relevant:

• European Union sanctions;
• United Nations sanctions;
• Dutch sanctions;
• United States sanctions;
• United Kingdom sanctions;
• other applicable sanctions regimes.

Elovolve may restrict or terminate accounts or transactions where necessary to comply with applicable sanctions laws or the requirements of our payment providers.

Elovolve may also restrict access from jurisdictions subject to applicable sanctions or other legal restrictions.

Where Elovolve identifies a higher financial crime risk, we may conduct enhanced due diligence.

This may include requesting:

• additional identification;
• proof of address;
• information regarding the purpose of transactions;
• information regarding the source of funds;
• information regarding the source of wealth;
• information regarding business or professional activities;
• additional verification through payment or identity providers.

Higher-risk circumstances may include unusually large or complex transactions, unusual transaction patterns, high-risk jurisdictions, suspected fraud or other circumstances indicating elevated risk.

Elovolve may take additional measures where a user is identified as a Politically Exposed Person ("PEP"), or as a family member or close associate of a PEP, where such measures are required or appropriate under applicable law.

Additional information or verification may be requested.

Being identified as a PEP does not automatically mean that a user is prohibited from using Elovolve.

Where Elovolve identifies activity that may involve:

• money laundering;
• terrorist financing;
• sanctions violations;
• fraud;
• stolen assets;
• payment fraud;
• identity fraud;
• financial crime;
• other unlawful financial activity,

we may take appropriate action.

This may include:

• blocking or delaying a transaction;
• restricting account functionality;
• suspending an account;
• terminating an account;
• preventing withdrawals;
• requesting additional verification;
• requesting additional information;
• contacting relevant payment providers;
• preserving relevant records;
• reporting information to competent authorities where legally required or permitted.

Elovolve may refuse to onboard or may suspend or terminate a user where:

• identity cannot be satisfactorily verified;
• required compliance information is not provided;
• a payment provider rejects the user;
• suspicious activity is detected;
• sanctions concerns arise;
• fraud is suspected;
• the user attempts to circumvent financial controls;
• the user provides materially false information;
• continued access presents an unacceptable financial crime risk.

Where legally permitted, Elovolve may withhold or delay funds while an investigation is ongoing.

Any withholding or adjustment of funds will be subject to applicable law and the Elovolve Terms of Service.

Users may not use Elovolve to arrange transactions and then deliberately move payments outside the Platform in order to:

• avoid Elovolve fees;
• circumvent payment controls;
• avoid identity verification;
• evade refunds or disputes;
• conceal the actual value of a transaction;
• facilitate unlawful activity.

Attempts to circumvent the Platform's payment system may result in suspension or permanent termination.

Elovolve may maintain records necessary to:

• operate the Platform;
• investigate fraud;
• investigate financial crime;
• resolve disputes;
• comply with legal obligations;
• respond to lawful requests;
• demonstrate compliance with applicable requirements.

Records may include:

• account information;
• transaction information;
• payment information;
• verification information;
• risk assessments;
• fraud reports;
• dispute information;
• relevant communications;
• investigation records.

Personal data will be retained in accordance with the Elovolve Privacy Policy and applicable law.

Where Elovolve investigates potentially suspicious activity, we may limit the information provided to the affected user concerning the investigation.

Where legally required, Elovolve will not disclose confidential information concerning regulatory reports, investigations or requests from competent authorities.

Nothing in this policy limits any disclosure that Elovolve is legally required to make.

Elovolve may cooperate with competent authorities, law enforcement agencies, regulators, payment providers and other authorised parties where required or legally permitted.

This may include providing information necessary to:

• investigate financial crime;
• prevent fraud;
• enforce sanctions;
• comply with legal obligations;
• respond to lawful requests;
• protect users or the Platform.

Where a legally required report must be made to a competent authority, Elovolve will make the report in accordance with applicable law.

Users are responsible for providing accurate and complete information when requested.

Users must not:

• provide false identity information;
• use another person's payment account without authorisation;
• use Elovolve to launder funds;
• use Elovolve to finance terrorism;
• use stolen payment methods;
• use stolen gaming items;
• conceal the origin of funds;
• circumvent financial controls;
• structure transactions for the purpose of avoiding applicable controls;
• assist another person in circumventing Elovolve's AML or payment controls.

Violations may result in immediate account restrictions or termination.

Elovolve may maintain internal controls designed to identify and mitigate financial crime risks.

These may include:

• account verification;
• payment-provider verification;
• sanctions screening;
• transaction monitoring;
• fraud detection;
• automated risk signals;
• manual review;
• enhanced due diligence;
• account restrictions;
• payment restrictions;
• withdrawal restrictions;
• investigation procedures.

Elovolve may periodically review and update these controls as the Platform, payment methods and regulatory environment develop.

Elovolve may rely on specialised third-party providers for certain financial crime controls.

For example, a payment provider may perform KYC, sanctions screening and transaction monitoring as part of its regulated payment services.

Such reliance does not mean that Elovolve will ignore financial crime risks identified through its own Platform.

Where Elovolve receives relevant information indicating elevated risk, we may take additional action.

AML and financial crime prevention activities involve the processing of personal data.

Elovolve processes such information in accordance with applicable data protection laws, including the GDPR.

Further information regarding the collection, use, retention and disclosure of personal data is available in the Elovolve Privacy Policy.

Where financial crime prevention or legal obligations require the retention or processing of information, certain information may be retained even after an account is closed, subject to applicable law.

This AML Policy is maintained by ExcaliburHQ B.V.

Elovolve may periodically review this policy based on:

• changes in applicable law;
• changes in payment methods;
• new products or services;
• changes in geographic availability;
• emerging fraud patterns;
• financial crime risks;
• information received from payment providers;
• changes in the Platform's risk profile.

Material changes may be reflected in an updated version of this policy.

Questions concerning this AML Policy may be directed to:

ExcaliburHQ B.V.

Operator of Elovolve

[Registered address]

The Netherlands

Email: management@elovolve.com