Anti-Money Laundering Policy

BUGA Games (operated by PEFFNELO INDUSTRIES LIMITED) is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy outlines our obligations and procedures in accordance with the applicable laws and regulations of the Federal Republic of Nigeria, including the Lagos State Lotteries and Gaming Authority (LSLGA) licensing requirements.

Money laundering is the process of making illegally obtained funds appear legitimate. BUGA Games has a zero-tolerance policy toward any form of money laundering, terrorist financing, or other financial crimes on our platform.

This AML Policy applies to:

• All users and customers of the BUGA Games platform
• All employees, contractors, and agents of PEFFNELO INDUSTRIES LIMITED
• All financial transactions processed through the platform
• All third-party payment providers and partners

This policy is reviewed and updated regularly to reflect changes in applicable laws, regulations, and industry best practices.

BUGA Games implements a robust Know Your Customer program to verify the identity of all users. KYC procedures include:

Accounts that fail to complete KYC verification within the required timeframe may be suspended or terminated.

BUGA Games continuously monitors all transactions on the platform to detect suspicious activity. Our monitoring systems flag:

• Unusually large deposits or withdrawals inconsistent with a user's profile
• Frequent deposits followed by immediate withdrawals without gaming activity
• Multiple accounts operated by the same individual or from the same device
• Transactions structured to avoid reporting thresholds (structuring/smurfing)
• Deposits from or withdrawals to high-risk jurisdictions
• Use of multiple payment methods by a single user in a short period
• Rapid movement of funds with no apparent gaming purpose

Where suspicious activity is identified, BUGA Games is obligated to report to the relevant authorities. Our reporting obligations include:

The following activities are strictly prohibited on the BUGA Games platform:

• Using the platform to launder proceeds of crime or illegal activity
• Depositing funds from stolen, unauthorized, or fraudulent payment methods
• Conducting transactions on behalf of a third party without disclosure
• Structuring transactions to avoid AML thresholds or reporting requirements
• Operating multiple accounts to obscure transaction trails
• Using the platform to finance terrorism or any illegal organization
• Providing false or misleading information during KYC verification

Violation of any prohibited activity will result in immediate account suspension, forfeiture of funds, and mandatory reporting to law enforcement authorities.

BUGA Games applies a risk-based approach to AML compliance. Customers are classified into risk categories based on:

• Geographic location and country of residence
• Transaction volume and frequency
• Payment methods used
• Politically Exposed Person (PEP) status
• Adverse media or sanctions screening results
• Source of funds and wealth

Higher-risk customers are subject to Enhanced Due Diligence (EDD) and more frequent monitoring reviews.

BUGA Games screens all customers and transactions against international and domestic sanctions lists, including:

• United Nations Security Council (UNSC) Sanctions List
• Office of Foreign Assets Control (OFAC) SDN List
• European Union Consolidated Sanctions List
• Nigerian Sanctions List issued by the CBN and relevant authorities

Any match against a sanctions list will result in immediate account freeze and reporting to the relevant regulatory authority.

BUGA Games maintains comprehensive records of all KYC documentation, transactions, and AML-related activities in accordance with regulatory requirements.

All records are retained for a minimum of 5 years from the date of the transaction or the end of the customer relationship, whichever is later. Records are stored securely and made available to regulatory authorities upon request.

All employees of PEFFNELO INDUSTRIES LIMITED who interact with customers or handle financial transactions receive mandatory AML training covering:

• Recognition of suspicious activity and red flags
• KYC procedures and customer due diligence requirements
• Internal reporting obligations and procedures
• Regulatory requirements under Nigerian law and LSLGA licence conditions
• Consequences of non-compliance for individuals and the company

AML training is conducted at onboarding and refreshed annually or whenever there are significant regulatory changes.

BUGA Games has appointed a designated AML Compliance Officer responsible for:

- Overseeing implementation of this AML Policy - Reviewing and investigating suspicious activity reports - Filing regulatory reports with the NFIU and LSLGA - Ensuring staff training is up to date - Keeping this policy current with regulatory changes

For AML-related concerns, contact: compliance@buga.games

This AML Policy is reviewed at least annually and updated as required to reflect changes in applicable laws, regulations, and industry best practices. BUGA Games reserves the right to amend this policy at any time.

Users will be notified of material changes through the platform or via email.

For questions or concerns regarding our AML Policy or to report suspicious activity:

Compliance Team: compliance@buga.games Support: support@buga.games Website: www.buga.games

PEFFNELO INDUSTRIES LIMITED (BUGA GAMES) Licensed by the Lagos State Lotteries and Gaming Authority Licence No: LSLGA/OP/OG/BG131025