Política de PLD/FTP

AML POLICY

ANTI-MONEY LAUNDERING, COUNTER TERRORIST FINANCING AND PROLIFERATION OF WEAPONS OF MASS DESTRUCTION POLICY

1. Introduction

Suprema Bet LTDA (operator of the “ULTRA bet” brand) is licensed by the Secretariat of Prizes and Betting of the Ministry of Finance (“SPA/MF”) to operate fixed-odds betting at a national level, pursuant to the authorization published in SPA/MF Ordinance No. 256/2025. ULTRA bet is committed to preventing money laundering and combating the financing of terrorism, by minimizing and managing regulatory, legal, and reputational risks.

The Company stays up to date with the best national and international practices to prevent money laundering, terrorist financing, and the proliferation of weapons of mass destruction. In doing so, it protects its operations, reputation, and employees from involvement in such crimes.

1.3. This policy complies with applicable legal and regulatory obligations, including but not limited to Law No. 9.613/1998, Decree-Law No. 5.640/2005, Law No. 13.260/2016, COAF Resolutions No. 36 and No. 40, Law No. 13.756/2018, Law No. 14.790/2023, and SPA/MF Normative Ordinances No. 1.330/2023 and No. 1.143/2024.

 

2. Definitions

2.1. Money Laundering (ML): The process of concealing the true origin of illegally obtained funds, typically divided into three stages:

  • Placement: Introducing illicit funds into the financial system.
     
  • Layering: Employing methods to disguise the origin of funds.
     
  • Integration: Using the funds as if they were legally obtained.
     

2.2. Terrorist Financing (TF): Providing funds for terrorist activities, regardless of whether the origin of those funds is legal or illegal.

2.3. Financing the Proliferation of Weapons of Mass Destruction (P): Facilitating the transfer or trade of nuclear, chemical, or biological weapons.

 

3. Roles and Responsibilities

3.1. Board of Directors:

  • Promotes an AML/CTF culture within the Company.
     
  • Establishes, approves, and reviews this AML Policy.
     
  • Approves Know Your Customer (KYC), Know Your Partner (KYP), Know Your Supplier (KYS), and Know Your Employee (KYE) procedures.
     
  • Oversees the implementation of AML/CTF measures.
     
  • Appoints the Suspicious Activity Reporting Officer (SARO) and ensures their autonomy and support.
     
  • Ensures accessibility and compliance with the AML Policy for employees and third parties.
     

3.2. Suspicious Activity Reporting Officer (SARO):

  • Reports suspicious transactions to the COAF.
     
  • Develops and oversees the implementation of AML policies and controls.
     
  • Maintains risk-based classifications for customers and transactions.
     
  • Conducts internal audits and reports deficiencies to management.
     
  • Prepares an annual suspicious transaction report.
     

3.3. Employees:

  • Must comply with KYC, KYP, KYS, and KYE procedures.
     
  • Promptly report suspicious transactions.
     
  • Cooperate with AML procedures and foster a compliance-oriented culture.
     

 

4. Risk-Based Approach

4.1. ULTRA bet adopts a risk-based approach, using Business Risk Assessment (BRA) to identify vulnerabilities and threats related to ML/TF/P.

4.2. Risk profiles considered include:

  • Customers and users of the platform.
     
  • Business model and geographical areas of operation.
     
  • Characteristics of transactions and payment methods used.
     
  • Employees, suppliers, and partners.
     
  • New products, services, or technologies that may be exploited for ML/TF/P purposes.
     

4.3. Internal procedures include:

  • Risk classification and mitigation in business activities.
     
  • Monitoring atypical transactions.
     
  • Annual assessment of business risks.
     

 

5. Compliance and Integrity Program

5.1. Integrity and Governance Program:

  • Mechanisms to promote governance, integrity, and Environmental, Social and Corporate Governance (ESG).
     
  • Compliance with Law No. 12.846/2013 and Decree No. 11.129/2022.
     
  • Anti-corruption and fraud prevention measures.
     

5.2. Organizational AML/CTF Culture:

  • Regular communication and training on AML/CTF/P.
     
  • Encouragement to report suspicious behavior.
     
  • Ongoing monitoring and risk analysis.
     

 

6. Training and Monitoring

6.1. ULTRA bet requires all employees to undergo:

  • Initial Training: Provided within twenty business days after hiring, covering legislative requirements and AML/CTF/P fundamentals.
     
  • Ongoing Training: Continuous education to stay current with evolving risks and new regulations.
     

6.2. Training records must include:

  • Details of the training provider.
     
  • Dates and type of training conducted.
     
  • Identification of participants.
     
  • Materials used.
     

 

7. Policy Review and Update

7.1. This Policy will be periodically reviewed to ensure compliance with applicable regulations and industry best practices.

7.2. Significant changes will be communicated to employees and partners to ensure proper adoption of the updated guidelines.

 

Version: V.03.2025

 

Política de PLD/FTP - ULTRA bet