Last update: December 2025

3-102-932956 LTD (the "Company") is a company incorporated under Costa Rica Law and operates the online gaming website www.solpump.io.

As part of its global operations, Company has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

Company is not a financial institution within the meaning of applicable law of Costa Rica and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers.

Company's intention is to follow global best practices in guarding against Company products being used to facilitate such activities. Those best practices include:

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler's checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.

Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by an account or external user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions. For example, they are used:

Company maintains a dedicated support team that is responsible for coordinating the implementation of the AML Policy and policy program. The support team's duties also include developing AML initiatives, working with other stakeholders to revise the AML Policy, assessing new regulatory requirements, and investigating potentially suspicious or unusual activities. Company also provides AML training to all its employees on a regular basis.

Company will apply appropriate account due diligence and ongoing monitoring measures required by law. Company will endeavor to prevent accounts from engaging in illicit or otherwise unauthorized activity. Company uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.

Company has adopted a risk based CDD approach to enable Company to understand the nature and purpose of the relationship of the Company, its products and services, with potential end users in order to develop a general customer risk profile that may be applied to the Company's products and services. In order to do so, the Company collects certain documentary information at the account-opening stage, commensurate with the nature of the specific business relationship for each account with the products and services of the Company that are made available to individual clients, the type of account and services that Company offers. The Company applies different CDD measures for different accounts, products and services, considering each account's risk profile and jurisdiction.

For instance, the CDD requires certain customer accounts to undergo the Company's customer identification process ("CIP"). The CIP includes procedures for:

The above steps are applied, as appropriate, on a risk-based basis using the following measures:

Company performs ongoing monitoring on its accounts in order to detect any patterns or indicators that might suggest elevated money laundering and terrorism financing practices risk or misuse of the Company's products or services. To support this, the Company applies a set of red flag indicators adapted to its relationships with customers and monitors for unusual changes in account activity, sanctions/PEP/adverse media concerns, or material legal changes affecting eligibility.

Whenever one of these red flags is triggered, any related account will be suspended, the business relationship may be paused, and Company will initiate enhanced due diligence to the account. Enhanced due diligence under this policy may include without limitation, obtaining the following information from the customer:

The Company may use a third-party service provider to verify any of the above information to establish a reasonable basis to know the true identity and legitimacy of the account where the account activity warrants such action as aforesaid.

Company will not enter into or will terminate relationships with accounts that:

Company reserves the right to suspend or terminate services to and relationship with accounts for any other reasons consistent with its internal risk policies and compliance procedures.

Company is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose Company established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring.

Company will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review account history and patterns of activity to detect and report any unusual activity as required and to develop and implement any additional controls or limits in its platform.

Company implemented procedures addressing the following two key components of unusual or suspicious activity management:

Company will use the following processes to achieve both goals:

Additionally to the above-mentioned controlling procedures, Company has also implemented the following procedures to complement its know your customer and ongoing monitoring procedures:

Company is obliged to report any unusual or suspicious transactions, in accordance with the Costa Rica Law. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity as required by Law.