Jan 26, 2023

1. Introduction

In order to continue its goal to provide a safe environment for players on its system, ESPORT NEWCO SAS (”Blitz”) crafted this Anti-Money Laundering and Counter-Terrorism Policy (”AML/CTF Policy”).

This AML/CTF Policy is designed to comply with the applicable laws and regulations of Blitz Eligible Jurisdictions and to support the implementation of a risk-based approach to anti-money laundering (”AML”) and counter-terrorism financing (”CTF”) activities within our organization.

Blitz operates with Know Your Customer (”KYC”) providers and Payment Service Providers (collectively, the “Providers”) that are regulated entities and also comply with the applicable laws and regulations of Blitz Eligible Jurisdictions.

2. Scope

This policy applies to all personnel, including employees, contractors, consultants, and other third parties, who are involved in AML/CTF activities. In particular, are targeted Blitz employees involved with payments, fraud, customer support, and compliance.

3. Risk-Based Approach

Our organization is committed to implementing a risk-based approach to AML/CTF activities. Blitz will identify, assess, and manage the AML/CTF risks associated with our activities, products, services, customers, customers’ transactions, and geographic locations.

4. Risk Assessment

Blitz will conduct periodic risk assessments to identify, assess, and manage the AML/CTF risks associated with our activities and transactions. The risk assessment will consider the following factors:

• The products and services offered by our organization;
• The customers Blitz serves;
• The frequency, size, and complexity of customer transactions;
• The geographic locations of our customers;
• The jurisdictions in which Blitz operates;
• The risk of money laundering or terrorism financing associated with specific customers or groups of customers;
• The flow of funds into and out of Blitz organization;
• Our organizational structure;