Sanctions & Anti-Money-Laundering Notice

Aetheria Media Holdings S.r.l. ("we", "us", "our") is committed to complying with applicable sanctions, anti-money-laundering ("AML"), counter-terrorist-financing ("CTF"), and related financial-crime laws in connection with the "England vs Norway" conditional promotional giveaway (the "Promotion").

1. Purpose and Scope

1.1. This notice explains the sanctions and AML controls that apply to the Promotion, including entry, verification, and prize payment. It applies to all entrants and potential winners.

1.2. These controls are necessary because the Promotion offers prizes in digital assets (USDT) and may involve cross-border participants, wallets, and transactions.

2. Sanctions Screening

2.1. Entrants and potential winners may be screened against applicable sanctions, watch lists, and restricted-party lists maintained by the United Nations, the European Union, the United States Office of Foreign Assets Control (OFAC), the United Kingdom, and other relevant authorities.

2.2. The Promotion is void in comprehensively sanctioned countries and territories, and entries or potential winners connected to sanctioned persons, entities, governments, or jurisdictions are excluded or disqualified.

2.3. Screening may include:

- automated checks against published sanctions lists and politically exposed person lists;

- country-based IP restrictions and geolocation analysis;

- manual review of verification documents, wallet addresses, and other information; and

- checks against proprietary and third-party risk indicators.

2.4. A "sanctioned person" includes any individual, entity, government, or body that is listed on, or owned or controlled by a person listed on, any applicable sanctions list, or that is otherwise subject to restrictive measures under applicable law.

3. Anti-Money-Laundering and Counter-Terrorist-Financing Controls

3.1. Because prizes are paid in digital assets, we apply risk-based AML and CTF controls. These controls may include:

- identity verification of Provisional Winners;

- confirmation of the source of eligibility and the lawful origin of any entitlement;

- politically exposed person (PEP) screening;

- enhanced due diligence for higher-risk cases (for example, high-value prizes, high-risk jurisdictions, or complex ownership structures);

- transaction monitoring and wallet-address screening; and

- record-keeping for audit and regulatory purposes.

3.2. We may request additional information or documentation to satisfy ourselves that the source of the prize entitlement and the destination wallet do not present an unacceptable AML, CTF, sanctions, or fraud risk.

3.3. We may delay or refuse payment if we are unable to complete required AML or sanctions checks to our reasonable satisfaction.

4. Prohibited Conduct

4.1. The Promotion must not be used for money laundering, terrorist financing, sanctions evasion, fraud, bribery, corruption, or any other unlawful purpose.

4.2. You must not enter, attempt to claim a prize, or receive a prize on behalf of a sanctioned person, a person located in a prohibited jurisdiction, or any person whose participation would violate applicable law.

4.3. We may refuse entry, withhold a prize, disqualify a winner, or take any other reasonably necessary action where we reasonably suspect such conduct.

5. Reporting to Authorities

5.1. We may report suspicious activity, transactions, or circumstances to competent authorities where required by law, without notice to the affected person.

5.2. We may also disclose information to regulators, law enforcement, or tax authorities to the extent required by law or lawful process.

6. Cooperation and Records

6.1. Provisional Winners and entrants are expected to cooperate with reasonable verification, sanctions, and AML requests. Failure to cooperate may result in disqualification.

6.2. We maintain records of screening, verification, and any reports made to authorities for as long as required by law.

7. No Guarantee of Payment

7.1. Compliance with sanctions and AML laws is mandatory. We may refuse to pay a prize if doing so would violate applicable sanctions, AML, or other financial-crime laws, even if the Provisional Winner would otherwise be eligible.

7.2. No compensation, damages, or alternative prize is payable where payment is refused or delayed for sanctions, AML, or legal-compliance reasons, except where required by law.