BSA / AML / OFAC / KYC POLICY

Updated as of September 16, 2026

Internal AML Compliance Officer: [Insert Name], AML Compliance Officer

Note to counsel/operator: the AML Compliance Officer named above should be an individual whose role is independent of, and does not overlap with, commercial or day-to-day executive operating responsibilities (for example, this role should not be held by the CEO), so that the Company can demonstrate independent compliance judgment to banks, payment processors, and regulators. This bracket must be completed with a real name and title before this policy is issued.

1. Introduction

Objective

This BSA/AML/OFAC/KYC policy (the “AML Policy” or “Policy”) applies to KodeDice LLC, a Delaware limited liability company (the “Company”), in connection with its operation of FunSpinz, a social and sweepstakes gaming platform available at https://www.funspinz.com and through associated apps (the “Platform”). While the classification of sweepstakes-model social gaming operators under the Bank Secrecy Act continues to evolve and has not been definitively resolved by regulators or courts, the Company has voluntarily adopted this Policy as a matter of best practice, aligned with the principles of the Bank Secrecy Act (31 U.S.C. §§ 5311–5314, 5316–5332) and the USA PATRIOT Act (Pub. L. 107-56), in order to mitigate money-laundering and terrorist-financing risk and to support the due-diligence expectations of the Company’s banking, payment-processing, and identity-verification partners. Nothing in this Policy is, or should be construed as, an admission that the Company is a “financial institution” as defined under the Bank Secrecy Act; counsel should confirm the appropriate regulatory characterization of the Company’s programme before this Policy is relied upon in that context.

Key objectives:

Risk identification: systematically identifying potential money-laundering and terrorist-financing risks associated with customer activity;

Compliance assurance: maintaining rigorous compliance with applicable legal and regulatory requirements;

Customer due diligence: implementing customer due diligence (“CDD”) measures to verify customer identities;

Continuous monitoring: maintaining ongoing transaction-monitoring protocols to detect and report suspicious activity;

Staff training and awareness: providing regular employee training on this Policy; and

Cooperation with authorities: maintaining a cooperative posture with regulators and law enforcement.

This Policy reflects the Company’s commitment to a secure and transparent operating environment and to responsible conduct in the social gaming and sweepstakes sectors.

Scope

This Policy applies to all Company employees, contractors, and agents, and governs the Company’s interactions with customers, including onboarding, transaction processing, and record-keeping. It covers all deposits, withdrawals, and other monetary movements on the Platform. While the Policy is designed primarily around U.S. regulatory requirements, the Company also has regard to internationally recognized AML standards, including guidance published by the Financial Action Task Force (“FATF”).

Compliance and review

The Company will conduct a review and, where appropriate, an independent audit of this Policy and its implementation at least annually. Each such review or audit will assess: the Company’s policies, procedures, and controls for detecting money laundering, terrorist financing, and other financial crime; the Company’s transaction-monitoring systems; sanctions-screening processes; customer due-diligence practices; and suspicious-activity reporting practices. The review will identify any weaknesses or deficiencies in these areas and will be documented, together with any resulting corrective actions.

Implementation

This Policy is implemented through a combination of internal controls, employee training, and technology-based monitoring and detection tools, described further below.

2. Legal framework

Bank Secrecy Act (BSA)

The BSA framework — including recordkeeping and reporting requirements, Currency Transaction Reports (“CTRs”) for transactions over $10,000, and Suspicious Activity Reports (“SARs”) for activity that appears suspicious regardless of amount — informs the design of this Policy.

USA PATRIOT Act

The Company has designed its onboarding and monitoring processes with reference to the PATRIOT Act’s principles of Customer Identification Programs (“CIP”) and Enhanced Due Diligence (“EDD”) for higher-risk activity, and its information-sharing framework under Section 314(a), which facilitates information sharing among financial institutions regarding suspected money laundering or terrorist financing.