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Sportingtech – Legal and Compliance Report

Author Rev Revision Date

Sanjin Bajramovic 1 Mar 1, 2018

Legal and Compliance Report – January and February 2018

This report covers the following:

● Compliance Department
○ What is done?
○ In progress?
○ To be done?
● Legal Department
○ What is done?
○ In progress?
○ To be done?
● Next steps

Compliance Department - January & February 2018

1. Internal Due Diligence:

- Acquisition of updated, translated and certified personal identifiable and utility bills for the
following:
o Ahmet Altuner – Done for next three months
o Burak Basel – Done for next three months
o Lorenzo Caci - need translation of UB
o Tiago Almeida - Done
o Rui Vilela – need scan of passport instead of picture of passport
o eMoore directors
▪ George Bergmann - waiting for Arran to send me certified documents
▪ Hendrik Manse - waiting for Arran to send me certified documents
o David Meli – Done

2. Due Diligence for Game Providers:

o Evolution Gaming – completed and sent - done

o YGGDRASIL – completed and sent - done
o Netent – completed and sent – need eMoore directors certified documents

3. Due Diligence for Payment Service providers

o Neteller – documentation ready, signed and sent - done

o Skrill - documentation ready, signed and sent - done
o Paysafe– documentation ready, signed and sent - done

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o APCOPay – agreement under review

o Astropay – waiting for approval on commercials and the forward to David Meli on
signature
o CreditCard– waiting for approval on commercials and the forward to David Meli on
signature
o iDebit– waiting for approval on commercials and the forward to David Meli on signature
o Interac2pay– waiting for approval on commercials and the forward to David Meli on
signature
o Paysec– waiting for approval on commercials and the forward to David Meli on signature
o Safetypay– waiting for approval on commercials and the forward to David Meli on
signature
o Zimpler – waiting for approval on commercials and the forward to David Meli on signature
o Trustly – waiting for MGA License
o Zotapay - waiting for DF Advocates to send the documentation

4. Satabank due diligence

o Need translation of Lorenzo’s UB

o Need scan of Rui Passport instead of picture
o Waiting for answer from Satabank compliance team

5. NMi Certification against Portuguese Legislation

o Initial stage
o Expecting to receive invoice to pay deposit
o Kick-off call after Deposit – introduction of teams and defining first steps

Meanwhile I suggested meeting with Burak and Elvis to see available resources in order to dedicate team
who will be in charge for the certification process, as this approach makes process much more efficient.

TO BE DONE:

Listing betzest under Curacao License:

1. Domain ownership document (whois.com) to confirm the owner

- If the owner is not the Curacao company, then we will require a permissions letter from
the owner to allow the Curacao company to manage and operate the website under its
license.
2. Declaration letter from the UBO (to eMoore) to confirm that minors will be blocked and problem
gambling will be mentioned on the website
3. A list of software/games to be displayed on this website.
4. A list of target markets
5. A network diagram to understand the flow of data (e.g. attached) and to identify where the
Curacao servers a located in this process flow.

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Legal Department - January & February 2018

- Service Agreement with all corresponding Attachments including SLA which was communicated
and adjusted in accordance with Pronetgaming - done
- Procedure for KYC documentation - done
- Procedure for submission of Service Agreement requests - done
- Anti-Money Laundering Policy - done
- Anti-Bribery and Anti-Corruption Policy - done
- Responsible Gambling Policy - done
- Business Plan – waiting for Rui’s Financial Forecast – in progress
- Disaster Recovery Plan – waiting for Tiago’s review and then we continue working, this is being
done with Murat and Ali from Pronetgaming – in progress

1. IP Research – how to submit copyright protection of software in order to achieve the following
aims:
o Keep Sportingtech and Pronetgaming separated
o Do not exclude Pronetgaming from IP Rights
o Make possible for Sportintech to include IP Rights in Balance Sheet

2. Agreements for Game providers

o Netent agreement – agreement under review

o YGGDRASIL Agreement – no agreement received
o Evolution Gaming Agreement – reviewed and sent back to Evolution Gaming
o Microgaming – reviewed and sent back to Microgaming

3. Agreements for Payment Services

o APCOPay Agreement
o Skrill Agreement
o Neteller Agreement
o Astropay Agreement
o Interac2pay Agreement
o Safetypay Agreement

The other did not send the agreements yet.

4. Agreements with clients

o Futebolfacil - done
o Maxbet Ghana - done

TO BE DONE:

1. GDPR Analysis and potential implications on platform in terms of Personal Data Protection,
privacy protection including the impact on the Affiliate service.

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2. Service Agreement for B2C clients which are using our License

3. Service Agreement between Sportingtech LTD and Sporting Tech N.V. to allow each other to use
gaming licenses.

Next steps:

Search for Compliance and Legal Personnel:

Total number of personnel for both departments: 5

a) Compliance department personnel: 2

b) Legal department personnel: 3

1. Structure of Compliance department

COMPLIANCE
DEPARTMENT

External Internal
Compliance Compliance
Officer Officer

- Researches the area of relevance

- Creates internal policies in
and provides instructions to the
accordance with instructions given by
Internal compliance team identifying
External Compliance Officer
key principles and objectives
- Monitoring internal policies
necessary to be achieved by internal
policies

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2. Structure of Legal department

LEGAL
Corporate DEPARTMENT Product Legal
Legal Advisor Advisor

- Corporate Law - Service Agreements

- All other Agreements - Intellectual property
except Service law
Agreements - Product certification
- Finance and Tax law

Privacy and
AML Legal
Advisor

- Data Privacy
- Anti/Money Laundering and Counter
Terrorist financing law
- Competition law

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3. Expectations of future personnel

Compliance officer description Legal advisor description

The Compliance officer is responsible for ensuring The legal advisor is primarily responsible for
respect for national and international regulations, providing high quality advice to the organization or
professional and extra-professional norms as well the client on major legal issues and problems.
as rules of ethics and good behavior as defined by Additionally, position of Legal Advisor assumes
the company. A good Compliance officer must be responsibility for formulating the best possible legal
able to analyze these regulations and norms from solution after analyzing the legal problem in depth.
the company’s perspective depending on its Person occupying the position of legal advisor
activity, culture and the global financial should be skilled enough to come out with a
environment. Compliance Officer also advises desired outcome from the client's point of view.
whether all the proceedings of the organization are Moreover, Legal Advisor should be able to take
in compliance with the requirements of the correct decisions and provide the necessary
legislation. professional support. He/she supervises, analyzes
and researches the implication of laws, legislation,
etc., that may affect the organization and advises
the organization so that there is minimum legal
exposure and liability. Thus, the legal advisor
needs to handle a multitude of responsibilities.