Betr9 is committed to preventing its services from being used for financial crime, money laundering, and terrorist financing. Strict compliance with all applicable regulations is essential for protecting the company, its management, and its employees from the risks associated with legal violations, regulations, and oversight requirements. Furthermore, adhering to these regulations helps safeguard Betr9's reputation against potential damage caused by being implicated in such illegal activities.

To achieve these objectives, the following policies are enforced:

• Employee Responsibilities
  Each employee must perform their duties in accordance with their assigned responsibilities.
  
  
• Anti-Money Laundering Commitment
  Commercial considerations must not take precedence over Betr9's commitment to preventing money laundering.
  
  
• Appointment of Money Laundering Reporting Officer (MLRO)
  Betr9 will appoint a Money Laundering Reporting Officer (MLRO) and a substitute to cover the MLRO’s duties in their absence. The substitute will be the Chief Executive Officer (CEO). The MLRO and their substitute will receive full assistance and cooperation from all employees in the execution of their duties.

Compliance with AML/CFT Regulations

Betr9 will strictly adhere to all applicable Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) rules and regulations. This includes:

• Culture of Compliance: Establishing and maintaining a culture of compliance throughout the company to prevent financial crimes.
  
  
• Customer Identity Verification: Ensuring that customer identities are verified satisfactorily within required limits.
  
  
• Know Your Customer (KYC): Appropriately implementing KYC procedures, both during customer acceptance and throughout the business relationship. This includes verifying the customer’s identity and continuously monitoring their use of Betr9 services.
  
  
• Employee Training: Ensuring that employees are well-informed about the laws, their obligations, and the procedures for complying with these requirements.
  
  
• Suspicion Reporting: Encouraging employees to promptly report any suspicions of financial crime or violations internally.

Risk-Based Approach

The company’s policies, procedures, and controls are based on a risk-based approach, which means resources will be focused on the areas of greatest risk.
By enforcing these policies, Betr9 strives to maintain a high standard of compliance and to protect itself, its employees, and its reputation from involvement in illegal activities.