Anti Money Laundering Policy.
Introduction:

Policy Objective: We offer maximum security for all our users on dota2expert .com, for which our clients' accounts are checked regularly, that the person's data is actually registered correctly, and the deposit methods used are not stolen or used by anyone else, which should establish a common framework with dota2expert to combat money laundering (AML).

dota2expert also takes reasonable measures to control and limit AML risk, including the allocation of appropriate funds.
dota2expert adheres to high anti-money laundering (AML) standards and requires management and employees to comply with these standards to prevent the use of their services for money laundering.

The dota2expert AML program is designed with the following requirements in mind:
EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
EU: “Regulation 2015/847 on information accompanying transfers of funds ”
EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods.
Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash (unofficial coordination: 06/2021).

MONEY LAUNDERING
Money laundering means: Converting or transferring property, knowing that such property obtained as a result of criminal activity or an act of participation in such activity, with the aim of concealing or concealing the illegal origin of property or providing assistance to any person participating in the commission of such activity in order to evade the legal consequences of this person's actions.
Concealment or concealment of the true nature, source, location, location, movement, rights in relation to or possession of property, knowing that such property was obtained as a result of criminal activity or as a result of participation in such activity.
Acquisition, possession or use of property, if known at the time of receipt, that such property was obtained as a result of criminal activity or as a result of participation in such activity.
Participation, complicity in committing, attempts to commit and aiding, abetting, facilitating and consulting in the commission of any of the actions.
Money laundering is considered as such even if you act The property, as a result of which the laundered property was obtained, was carried out in the territory of another Member State or in the territory of a third country.

ORGANIZATION AML
In accordance with anti-money laundering legislation, dota2expert has appointed a “top level” to prevent money laundering: The D-level management: Director of Sales.
AMLCO (Anti-Money Laundering Compliance Officer) is responsible for ensuring that dota2expert's AML policies and procedures are followed.
AMLCO reports directly to the Chief Compliance Officer, with the direct responsibility of the Chief Executive Officer.

POLICY IMPLEMENTATION REQUIREMENTS
Every significant change to the dota2expert AML policy is subject to approval by dota2expert, Office level D. Enterprise-wide risk assessment.
As part of its risk-based approach, dota2expert has conducted an AML Corporate Risk Assessment Enterprise-Wide Risk Assessment (EWRA) ​​to identify and understand the risks specific to dota2expert and its business lines.
Risk Policy dota2expert AML is determined after identifying and documenting the risks inherent in its lines of business, such as the products and services offered by the website. Customers who are offered such products and services, transactions performed by these customers, delivery channels, banks used, geographic location of bank operations, customers and transactions, as well as other qualitative and emerging risks.
AML risk categories are defined based on dota2expert's understanding of regulatory requirements, regulatory expectations and industry guidance.
EWRA is reassessed annually.

MINIMUM STANDARDS
dota2expert has set the standard for Know Your Customer (KYC). These standards require due diligence in relation to each client at risk before providing the opportunity to receive the goods offered on dota2expert by identifying and verifying his identity, as well as his representatives and beneficial owners based on documents, data or information obtained from a reliable and an independent source complying with national and European AML laws and regulations.
Interpreting the KYC principle starts with identifying a customer using the required identification documents.
All geographic and user data we receive allows us to apply the Customer Acceptance Policy. In addition to these objective criteria, there are subjective elements that can raise suspicion about the customer and which should be paid special attention to.
Finally, since KYC does not include static data, but dynamic data through the relationship with the customer, it also requires a follow-up and permanent customer monitoring.

CUSTOMER IDENTIFICATION AND VERIFICATION (KYC)
Official customer identification when entering into a business relationship is a vital element for both money laundering regulations and KYC policies.
This identification is based on the following fundamental principles:
A copy of your passport, ID or driver's license, each displayed along with a handwritten note that mentions dota2expert. Please note that all four corners of the ID must be visible in one image and all data must be legible.

ADDRESS VERIFICATION:
A recent utility bill sent to your registered address issued within the last 3 months.
To expedite the approval process, make sure the document is submitted with a clear authorization that all four corners of the document are visible and all text is readable.
Electricity bill, water bill, bank statement or any government letter addressed to you is a good example.

CONTINUOUS COMPREHENSIVE CUSTOMER CHECKING
For Certain high-risk specialized customer categories are periodically undertaken risk analyzes to ensure that customer data or information is up to date.
The current KYC verification process for other customer categories is essentially based on the “principle of awareness” after reviewing the special file by the AML team. This principle of awareness is to continue to ask the account manager to carefully conduct periodic KYC analysis of the client.

CONTINUOUS TRANSACTION MONITORING
AML-Compliance ensures that 'ongoing transaction monitoring' is carried out to identify transactions that are unusual or suspicious compared to the customer's profile. This transaction monitoring is carried out at two levels:

1)First line of control:
dota2expert works exclusively with trusted payment service providers who have effective AML policies that prevent most suspicious deposits on dota2expert from appearing without proper KYC procedures for a potential client.
2) Second line of control:
dota2expert informs its network that any contact with a client, player or authorized representative must lead to due diligence in relation to transactions in the corresponding account. In particular, these include:
Requests to perform financial transactions on an account.
Requests for funds or services in an account.
Specific transactions submitted to the customer service manager, possibly through their compliance manager should also be subject to due diligence.
Determination of the unusual nature of one or more transactions is mainly dependent on subjective assessment of the customer's knowledge (KYC), their financial behavior and the transaction counterparty.
Transactions observed in customer accounts, for which it is difficult to get a correct understanding of the legal actions and origin of funds, therefore, should be quickly considered atypical (since they have no direct justification). Any employee of
dota2expert must inform the AML department of any unusual transactions that they observe and cannot be attributed to a legitimate activity or source of income known to the client.
The second line of control is complemented by risk-based automation, and the second line of control includes enhanced monitoring of customer transactions considered high risk.
3) Third line of control:
To accompany these due diligence measures, one should gradually introduce more structural measures such as limiting remittances applicable to each customer category.
Organizing Internal Controls Suspicious Transaction Reporting
In its internal procedures, dota2expert describes in detail for its employees when to report and how to proceed.
Reports on atypical transactions are analyzed by the AML team in accordance with the exact methodology fully described in the internal procedures.
Depending on the result of this check and on the basis of the information collected, the AML group:
Will decide whether to send a report to the FIU in accordance with the legal obligations stipulated by the Law of September 18, 2017, Will decide whether to terminate the business relationship with the customer.

PROCEDURES
AML rules, including minimum KYC standards, have been translated into operational guidelines or procedures, available on the dota2expert website and on the intranet.

ACCOUNTING, ACCOUNTING, BUSINESS PRODUCTION
Records of data obtained for identification purposes must be retained for at least ten years after the termination of the business relationship.
Records of all transactional data must be kept for at least ten years after the transaction or the termination of the business relationship.

TRAINING
dota2expert has developed various ways to training and awareness raising to keep their employees informed of their anti-money laundering responsibilities. The training and awareness program is reflected in its use:
Mandatory AML training program in accordance with the latest changes in legislation.
AML academic training courses for all new employees.
The content of this training program should be determined according to the type of business in which the interns work, and the positions held by them. These sessions are conducted by an AML specialist working in the dota2expert AML team.

AUDIT
Internal audit regularly sets missions and reports on AML activities.