Rust Clash AML Policy

Money laundering is a type of financial crime defined as the process of covering up or “laundering” illegally obtained money to wipe away traces of criminal activity and make it appear as if it were legitimately obtained. Recognizing that online gaming platforms, such as Clash.gg/Rustclash.com can be exploited by bad actors to launder criminal proceeds, the Company has taken steps to develop an anti-money laundering policy (the “Policy”) that provides for a risk-based approach to the prevention and identification of money laundering. To this end, the Policy, in pertinent part, provides for the following:

• The appointment of an anti-money laundering officer (“AMLO”), whose role is to oversee the implementation of the Policy, collaborate with the Company’s senior management to ensure that appropriate resources are dedicated to continued compliance with the Policy, and act as a point of contact for employee disclosures and reports related to the Policy. The AMLO is also responsible for monitoring developments in anti-money laundering regulations and policy to ensure that the Company’s Policy remains in line with relevant compliance standards.

• Regular audits of the Company’s Policy to ensure that the Policy is being effectively implemented. The results of the audit will be reported to the AMLO, who will determine whether changes need to be made to the substance or implementation of the Policy to increase its effectiveness or to bring it up-to-date with current compliance standards.

• Customer risk assessments based upon the Company’s collection of Know Your Customer (“KYC”) information and verification of each customer’s identity. This may include partnering with third-party identity verification services who use sophisticated tools to identity whether a customer qualifies as a Politically Exposed Person or whether a customer has been listed on the Office of Foreign Assets Control’s Specially Designated Nationals List or the U.S. Department of Treasury’s Sanctions List.

• Regular and ongoing transaction monitoring to identify patterns of suspicious behavior.

• The development of a training policy designed to educate all personnel whose duties require knowledge of or involve some aspect of anti-money laundering compliance, including those who interact with customers and monitor customer accounts and transactions. The training is required upon onboarding and at regular intervals to ensure each employee possesses relevant and up-to-date knowledge of the latest developments in anti-money laundering regulations and their obligations stemming therefrom.

The Company is dedicated to identifying and mitigating the risk of money laundering that may result from bad actors’ use of its platform. Accordingly, the Company aims to attain company-wide awareness of its AML obligations along with an effective level of regulatory compliance commensurate with the nature and size of the business. Through company-wide commitment to the implementation of the Policy, the Company can effectively prevent the exploitation of its platform by bad actors, and continue to provide a safe, fun, and entertaining experience for its customers.