Anti-Money Laundering and Counter-Terrorist Financing Policy

1. Purpose

Finaltable Media Ltd (“the Company”) is committed to preventing its services, systems, and commercial relationships from being used — knowingly or unknowingly — to facilitate money laundering, terrorist financing, or the financing of proliferation. This Anti-Money Laundering and Counter-Terrorist Financing (“AML/CTF”) Policy sets out the controls, responsibilities, and expectations that apply across the business.

2. Scope and regulatory context

The Company operates as an online media and affiliate marketing business promoting UK Gambling Commission-licensed operators. We do not hold customer funds, do not accept customer stakes, and are not ourselves a ‘regulated sector’ firm under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the ‘MLRs 2017’).

Nevertheless, because our commercial partners are regulated gambling operators, we voluntarily adopt AML/CTF principles aligned with: the Proceeds of Crime Act 2002 (POCA); the Terrorism Act 2000; the MLRs 2017; the UK sanctions regime administered by the Office of Financial Sanctions Implementation (OFSI); and the Gambling Commission’s guidance on the prevention of money laundering and combating terrorist financing.

This policy applies to all directors, employees, contractors, consultants, agents, and any third parties acting on the Company’s behalf.

3. Policy statement

The Company has zero tolerance for money laundering and terrorist financing. We will:

• Conduct risk-based due diligence on all commercial partners, including affiliate counterparties, payment providers, and material suppliers.
• Only enter into affiliate relationships with operators that are licensed, authorised, and in good standing with their relevant regulator (primarily the UK Gambling Commission).
• Screen counterparties against applicable sanctions lists before onboarding and periodically thereafter.
• Report suspicious activity to the appropriate authorities in accordance with UK law.
• Maintain accurate records of due diligence, decisions, and related correspondence.
• Provide relevant training to staff and ensure this policy is reviewed at least annually.

4. Definitions

• Money laundering — the process by which the proceeds of criminal conduct are made to appear legitimate, including concealing, converting, transferring, or removing criminal property.
• Terrorist financing — the provision or collection of funds, by any means, with the intention or knowledge that they will be used to carry out acts of terrorism.
• Proceeds of crime — any property or benefit derived from criminal conduct, wherever that conduct took place.
• Suspicious activity — any transaction, conduct, or circumstance that gives rise to knowledge, suspicion, or reasonable grounds for suspicion of money laundering or terrorist financing.

5. Risk-based approach

The Company applies a risk-based approach to AML/CTF. We assess the inherent risk of the products, commercial partners, payment flows, and jurisdictions involved in our business and apply proportionate controls. Because we do not handle customer stakes or payouts, our principal residual risk is counterparty risk — specifically, that we may be commercially associated with an entity that itself facilitates financial crime.

6. Counterparty due diligence

Before entering into any commercial affiliate agreement, the Company verifies that the operator:

• Holds a current and valid operating licence from the UK Gambling Commission (or, for non-UK markets, an equivalent credible regulator).
• Is not subject to any published enforcement action that would render the partnership inappropriate.
• Has publicly available AML/CTF, responsible gambling, and data protection policies consistent with its regulatory obligations.
• Is not a designated person or entity on the UK Sanctions List or any other list we are required to screen against.

Records of these checks — including licence reference, date of verification, and any supporting documents — are maintained for a minimum of five years from the date the relationship ends.

7. Sanctions screening

The Company does not process customer transactions. We do, however, screen prospective counterparties (operators, payment providers, and material suppliers) against the UK Sanctions List maintained by OFSI at the point of onboarding and re-screen on a risk-sensitive basis thereafter. Any positive or inconclusive match is escalated to the Director before any commercial engagement proceeds.

8. Suspicious activity and reporting

Any person covered by this policy who has knowledge, suspicion, or reasonable grounds for suspicion that a person is engaged in money laundering or terrorist financing must escalate the matter internally to the designated officer: Brett Andrews (brett.andrews@finaltablemedia.co.uk). The designated officer will assess the report and, where appropriate, submit a Suspicious Activity Report (SAR) to the UK Financial Intelligence Unit at the National Crime Agency.

‘Tipping off’ — informing any person who is the subject of a suspicion or report that a disclosure has been or may be made — is a criminal offence and is strictly prohibited.

9. Record keeping

The Company retains records of: counterparty due diligence, sanctions screening outcomes, internal suspicious activity reports, external SARs (where made), training completion, and relevant correspondence. These records are held securely for a minimum of five years from the end of the relevant business relationship or the date of the report, in line with MLRs 2017 guidance.

10. Training and awareness

All personnel receive AML/CTF awareness briefing on induction covering: what money laundering and terrorist financing are; the main UK offences; red-flag indicators; how to escalate concerns internally; and the prohibition on tipping off. Refresher training is provided at least annually and upon any material regulatory change.

11. Responsibilities

The Board has overall accountability for the Company’s AML/CTF controls.

The Director (Brett Andrews) is the designated officer responsible for day-to-day implementation, counterparty due diligence decisions, handling internal reports, and liaising with law enforcement.

All personnel are responsible for being alert to red flags, escalating concerns promptly, and complying with this policy.

12. Breach and disciplinary action

Failure to comply with this policy may result in disciplinary action, up to and including summary dismissal, and may constitute a criminal offence. Third parties found in breach may have their contract terminated with immediate effect and be reported to the appropriate authorities.

13. Review

This policy is reviewed at least annually and whenever there is a material change in the Company’s business, applicable law, or regulatory guidance. The next scheduled review date is 19 April 2027.