Triumph Labs, Inc.

Effective Date: June 1, 2021.

Updated: October 27, 2022

1. Firm Policy

It is Triumph Lab Inc.’s (”Triumph” or the “Company”) policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by working with our payment processors and banking partner(s) (the “Service Providers”) to comply with all applicable requirements under the Bank Secrecy Act (“BSA”), the USA PATRIOT Act (the “Patriot Act”), and their implementing regulations.

Money laundering means any activity that is meant to conceal or disguise the origins of criminally derived proceeds to appear to constitute legitimate assets. A criminal will typically achieve money laundering in three stages. At the "placement" stage, the criminal converts cash generated by illicit means into monetary instruments or deposits it into accounts maintained by otherwise legitimate businesses at financial institutions. At the "layering" stage, the criminal transfers or moves the funds into other accounts or other financial institutions to put greater distance between the money and its criminal origins. At the "integration" stage, the criminal reintroduces the funds into the economy, using them to purchase legitimate assets or fund other criminal activities or legitimate businesses.

Firms that process transactions for their customers are uniquely situated in an evolving technological, financial, and regulatory landscape. Such a firm must always anticipate that its customers or their counterparties could be attempting to launder funds obtained elsewhere or generate illicit funds on the financial technology platform itself. Triumph uses the transfer of funds to pay our real money tournament winners (as defined in the Terms and Conditions). Users cannot lose tournaments on purpose as a means of transferring funds to another user and the players in the tournaments are matched within certain parameters, such as skill, on a random basis - making attempts to launder or purposefully transfer money through the system extremely difficult.

Unlike money laundering, terrorist financing does not necessarily involve the proceeds of criminal conduct. The funding sources of terrorist financiers are often legitimate. Terrorist financing typically involves an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of terrorist financing can include charitable donations, foreign government sponsors, business ownership, and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can look similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

This Bank Secrecy Act and Anti-Money Laundering Policy (“BSA/AML Policy”) and our procedures and internal controls for implementing the policy are designed to ensure compliance with all applicable laws and regulations. We will review and update this BSA/AML Policy on a regular basis and put in place appropriate procedures and internal controls to account for both regulatory changes and changes in our business.

2. Compliance Officer Designation and Duties (TODO)

Triumph Labs has designated Jamin Horn, its General Counsel, as its Compliance Officer, who is fully responsible for maintaining a program with procedures and internal controls appropriate to give effect to this BSA/AML Policy. Jamin Horn has a working knowledge of the BSA, the Patriot Act, and their implementing regulations and is qualified by experience, knowledge, and training that includes seven years as attorney for, or in-house as General Counsel or Corporate Counsel for clients designated high risk.

The Compliance Officer will be responsible for overseeing communication and training for employees and monitoring the firm’s compliance with all obligations, including those directly applicable to this firm under the BSA and indirectly applicable through Service Providers. The Compliance Officer will also ensure the firm keeps and maintains all necessary transaction records and timely file : notices of potentially suspicious transactions with our Service Providers; and reports of currency received in a trade or business and, if applicable, Foreign Bank and Financial Accounts Reports (“FBARs”) with the Financial Crimes Enforcement Network (FinCEN) when appropriate. The Compliance Officer is vested with full responsibility and authority to implement and enforce this BSA/AML Policy.

The Compliance Officer’s contact information is as follows:

Jamin Horn, General Counsel

90 Sheridan Street, San Francisco CA

Triumph will promptly notify our Service Providers if there is any change to the Compliance Officer position or their contact information, or the BSA/AML Policy itself.

3. Giving AML Information to Financial Partners

We will respond to any demand made by our Service Providers pursuant to a FinCEN BSA § 314(a) request concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity, or organization named in the demand. We will respond to any such demand within 3 business days unless otherwise specified our Service Providers. Demand should be made to the Compliance Officer at the contact information provided. Unless otherwise stated in the demand, we are required to search those documents outlined in FinCEN’s FAQs. [FinCEN’s FAQs relating to the section 314(a) process may be obtained on the Secure Information Sharing System (“SISS”), by calling the FinCEN resource center at 800-767-2825 or 703-905-3591, or by emailing] If we find a match, the Compliance Officer will report the match and all relevant documents to whichever Service Provider made the demand.