Anti-Money Laundering, Identity Verification and Sanctions Policy

Dizso applies proportionate identity-verification, sanctions-screening, transaction and payout controls according to the risks associated with its services.

Dizso is not a bank, investment firm, payment institution or crypto-asset service provider. It does not hold client money, accept deposits, execute customer orders on real markets or custody customer assets.

The fees paid by users provide access to Dizso's technology, educational content and simulated evaluations. Rewards paid to users are funded by Dizso and relate to performance within a simulated environment.

Dizso will not establish or maintain a relationship with:

• A person who cannot satisfactorily complete the required identity verification.
• A person or entity designated under sanctions or restrictive measures applicable to Dizso.
• An entity owned or controlled, directly or indirectly, by a sanctioned person where applicable sanctions prohibit the relationship.
• A person acting on behalf of an undisclosed third party.
• A person providing false, altered, misleading or materially inconsistent identity, residence, ownership or payment information.
• A person whose relationship with Dizso would otherwise breach applicable sanctions, restrictive measures or criminal law.

Potential matches or inconsistencies are subject to human review before a final decision is made.

Identity verification is required before a user's first payout and may be required earlier where Dizso identifies circumstances requiring additional verification.

Users may be required to provide:

• A valid government-issued photo identity document.
• Proof of residential address.
• A selfie or other evidence reasonably necessary to verify that the applicant is the legitimate holder of the identity document.
• Additional information or documentation where required to resolve discrepancies or assess elevated risk.

Verification is reviewed by authorised Dizso personnel.

Where identity, residence or ownership information is inconsistent, Dizso may request updated documentation, additional evidence or a video verification before completing the review.

Verification may be repeated where an identity document expires, the user's name or residence changes, material information changes, Dizso has reasonable grounds to doubt information previously provided, or additional verification is appropriate following a risk review.

Materially false or fraudulent identity information may result in the rejection or termination of the relationship following human review.

Dizso conducts sanctions screening as part of its onboarding and ongoing compliance controls.

Potential sanctions matches are subject to human review. Dizso will not establish, maintain or process a relationship or transaction where doing so would breach sanctions or restrictive measures applicable to Dizso.

Potential matches involving politically exposed persons (“PEPs”) are also reviewed.

Where a customer is confirmed to be a PEP or otherwise presents an elevated risk, Dizso may apply enhanced due diligence, including:

• Obtaining additional information regarding the purpose and nature of the relationship.
• Requesting evidence regarding source of funds or source of wealth where appropriate.
• Requiring approval from authorised management.
• Applying enhanced monitoring.

PEP status does not automatically result in rejection.

Payments received by Dizso and payouts made to users are subject to risk-based compliance controls.

Payouts are made to wallet addresses provided by the verified user.

Before a payout, Dizso may screen the destination wallet using blockchain-analysis tools to identify sanctions exposure, illicit activity or other material financial-crime risks.

A payout may be temporarily held where a screening result requires additional investigation.

Dizso will not execute a payout where:

• Applicable sanctions or restrictive measures prohibit the transaction.
• The destination address presents a confirmed prohibited risk.
• Dizso cannot satisfactorily resolve material compliance concerns associated with the transaction.

Where appropriate and legally permissible, a user may be asked to provide an alternative wallet address or additional supporting information.

Automated screening results do not, by themselves, determine a final adverse decision. Material alerts are reviewed by authorised personnel.

Dizso applies risk-based monitoring throughout the customer relationship.

Where potentially suspicious or unusual circumstances are identified, Dizso may:

• Request additional identification or supporting documentation.
• Request information regarding the source of funds or source of wealth.
• Review payment or payout information.
• Conduct additional sanctions or blockchain screening.
• Temporarily hold an affected payout while the review is completed.
• Apply enhanced due diligence.
• Escalate the matter internally to the person responsible for compliance.

Decisions resulting from material compliance concerns are subject to human review.

Dizso may restrict disclosure of information relating to an investigation where disclosure would be prohibited by applicable law.

Any employee or authorised person who identifies activity that may be associated with money laundering, terrorist financing, fraud, sanctions evasion or another serious financial crime must report the matter promptly to the person responsible for compliance.

The user concerned must not be informed of an internal suspicious-activity report where doing so could prejudice an investigation or breach applicable law.

The compliance function assesses the available information and determines the appropriate response in accordance with applicable legal obligations.

Where Dizso is required by applicable law or by a legally binding request to provide information to a competent authority, Dizso will cooperate in accordance with the applicable legal framework.

The consideration or escalation of suspicious activity does not, by itself, determine the contractual status of the user's account.

Dizso retains relevant compliance records for 5 years after the customer relationship ends, unless a longer retention period is required by applicable law.

Relevant records may include:

• Identity-verification documentation.
• Verification and review records.
• Sanctions and PEP screening results.
• Enhanced due-diligence documentation.
• Wallet-screening results.
• Internal compliance reviews and decisions.
• Communications and supporting documentation relevant to a compliance investigation.

Access to these records is restricted to authorised personnel.

Dizso will preserve and provide information to competent authorities where required by applicable law or by a legally binding request.

Dizso will not disclose the existence or content of a confidential regulatory or law-enforcement request where such disclosure is prohibited by law.