Comments/Suggestions/Observations on the Anti-Money Laundering Compliance

Procedures

1. The company needs to obtain the following information to comply with the
customer due diligence or know-your-customer rule

a. Complete Name of the client

b. Present address of the client
c. Residence telephone number
d. Permanent Address
e. Birthdate and Birth place
f. Nature of work or occupation of the client (specific designator or title of
the client, e.g. attorney, cashier, physician)
g. Name of Employer or Name of business and the complete address and
telephone number of the employer or business
h. Nature of self-employment or business and complete address and
telephone numbers
i. Valid Identification
j. Source of funds
k. If the customer or client acts in a representative capacity, obtain
documents showing proof of his capacity and verify the identity of the
person being represented in the transaction.

2. The company also needs to obtain and store a hard copy of the valid
identification used by the client in registering with the system and verify the true
and full identity of their customers. For foreign national, a valid passport must
be presented and must be stored in the office for safekeeping and recording
purposes.

3. The company also needs to make a database detailing and storing all customers
transactions.

a. When the customer logged in.

b. How long did he logged in with the system.
c. The transactions during the time he was logged in.
d. How much was his bet during his transactions.

4. The company must conduct face-to-face contact at the account opening to verify
the identity of the account holder. There must be an interview to verify the
identity and the information being submitted by the customer before he is
allowed as a member of the casino.

5. There must also be face-to-face conduct in case of withdrawal or transfer of

funds.

6. The company must safekeep all documentations pertaining to customer

identification and all their transactions.

a. The documentation must include information on the customer name,

address, nature and date of transactions, type and amount of currency
involved, the account of the customer, and information whether a person
is a customer or a beneficial owner of the transaction.
7. The recordkeeping of all documentation should be computerized and have a
back-up system.