Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy

Last Updated: April 5, 2026

1. Purpose and Scope

Daily Gaming LLC ("Daily Gaming") is committed to operating its platform in compliance with applicable U.S. laws and regulations relating to financial crimes, including the Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq., and applicable anti-money laundering (AML) regulations. This policy establishes the standards Daily Gaming follows to:

• Verify the identity of users who deposit or withdraw funds on the platform
• Detect and prevent money laundering, fraud, and other financial crimes
• Comply with applicable U.S. tax reporting obligations
• Report suspicious financial activity as required by law

This policy applies to all Daily Gaming users who engage in financial transactions on the Platform, including deposits, withdrawals, and contest prize payouts.

2. Customer Identification Program (CIP)

Daily Gaming maintains a Customer Identification Program consistent with applicable regulatory requirements. The following information is collected from users at account registration and/or prior to processing withdrawals:

Standard Account Registration

• Full legal name
• Email address
• Date of birth (to verify 18+ eligibility)
• State of residence (for geographic restriction enforcement)

Enhanced Verification — Triggered by Withdrawal or Threshold Activity

Enhanced identity verification is required before processing a withdrawal request and may be required when a user's cumulative activity triggers applicable thresholds. Enhanced verification may require:

• Government-issued photo identification (driver's license, state ID, or passport)
• Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)
• Proof of residential address (utility bill, bank statement, or similar document dated within 90 days)
• A selfie or live photo for identity matching

Daily Gaming uses a licensed third-party identity verification provider to process and verify submitted identity documents. Identity documents are handled in accordance with Daily Gaming's Privacy Policy.

Verification Timing

Identity verification may be completed at registration or deferred until a user requests a withdrawal or reaches an activity threshold. Users who do not successfully complete verification will have withdrawal privileges suspended until verification is completed. Contest participation is not affected by pending verification status unless fraud is suspected.

3. Prohibited Users and Sanctions Screening

Daily Gaming prohibits the use of its Platform by individuals or entities that are:

• Listed on the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list
• Located in or nationals of countries subject to comprehensive U.S. sanctions
• Otherwise prohibited from transacting under applicable U.S. law

Daily Gaming screens users against applicable sanctions lists at account registration and may re-screen when user information is updated. Accounts matching a sanctions list entry will be immediately suspended and reported as required by applicable law.

4. Anti-Money Laundering Controls

Daily Gaming implements the following controls to detect and prevent money laundering and other financial crimes:

Transaction Monitoring

• Deposit and withdrawal activity is monitored for unusual patterns, including structuring (breaking transactions into smaller amounts to avoid reporting thresholds), rapid cycling of funds, and activity inconsistent with stated gaming purpose
• Accounts that deposit and withdraw funds without meaningful contest participation will be flagged for review
• Accounts with unusually high or irregular transaction volumes relative to their contest activity will be reviewed

Deposit and Withdrawal Limits

• Daily Gaming may impose deposit limits, withdrawal limits, and account-level controls as part of its financial risk management practices
• Deposited funds are subject to a 24-hour hold period before withdrawal to allow for fraud and chargeback risk management

Chargeback and Fraud Controls

• Accounts associated with fraudulent chargebacks, stolen payment methods, or fraudulent deposits will be permanently banned and the associated funds frozen pending investigation
• Device identifiers and IP addresses associated with confirmed fraud are retained to prevent re-registration

5. IRS Tax Reporting

Daily Gaming complies with applicable U.S. IRS reporting obligations for contest prize payouts:

• Users who receive cumulative net winnings of $600 or more in a calendar year will be issued IRS Form 1099-MISC or 1099-NEC as required by law
• Users reaching this threshold must provide a valid SSN or ITIN via a completed IRS Form W-9 before further withdrawals are processed
• Failure to provide required tax information will result in mandatory federal backup withholding (currently 24%) applied to applicable winnings
• Daily Gaming retains tax reporting records for a minimum of seven (7) years as required by IRS record-keeping guidelines

6. Suspicious Activity

Daily Gaming monitors for and investigates activity that may indicate money laundering, fraud, or other financial crimes. Indicators of suspicious activity may include but are not limited to:

• Requests to send winnings to a third party not associated with the account
• Use of multiple payment methods in unusual patterns
• Accounts that fund a wallet and withdraw without meaningful gameplay
• Structured transactions designed to avoid reporting thresholds
• Account activity inconsistent with the user's stated identity or location
• Collusion between accounts to transfer funds through contest results

When suspicious activity is identified, Daily Gaming may suspend the account, freeze the associated wallet balance, request additional documentation, and/or file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) as required by applicable law. Daily Gaming is legally prohibited from notifying an account holder that a SAR has been filed.

7. Record Retention

Daily Gaming retains records related to user identity verification, financial transactions, and suspicious activity investigations for a minimum of five (5) years following the closure of the account or the end of the business relationship, or as otherwise required by applicable law. Records related to IRS tax reporting are retained for a minimum of seven (7) years.

8. Employee Training and Compliance Oversight

Daily Gaming's personnel involved in financial operations and compliance are trained on applicable BSA/AML requirements, red flag indicators, and internal reporting procedures. Daily Gaming designates a Compliance Officer responsible for overseeing this policy, maintaining required records, and ensuring the policy remains current with applicable law.

9. Cryptocurrency Transactions and Service Providers

Deposits and withdrawals on Daily Gaming are conducted in USDC, a U.S. dollar stablecoin, on the Polygon network. Daily Gaming does not accept credit cards, debit cards, or bank transfers directly on the platform and does not store payment card information. On-chain transaction data (wallet addresses, transaction hashes, amounts, and timestamps) is recorded and retained to satisfy financial recordkeeping and reporting obligations.

Daily Gaming uses licensed third-party providers for identity verification, blockchain infrastructure (including node and webhook providers), and other compliance functions. These providers maintain their own information security and compliance programs and are contractually required to comply with applicable law.

10. Policy Updates

This policy will be reviewed and updated periodically to reflect changes in applicable law, regulatory guidance, and business practices. Material updates will be communicated to users through the Platform or by email.

11. Contact

Questions regarding this policy may be directed to:

Daily Gaming LLC — Compliance
Atlanta, Georgia, United States
Email: support@daily-gaming.com