Flow of Funds

1. Overview

OnPointCasino.us and OnPointCasino.com, operated by OnPoint Administration LLC, is a U.S.-based sweepstakes gaming and sportsbook platform operating under a sweepstakes model in compliance with applicable federal and state laws. This document describes the complete flow of funds through the platform, from initial customer payment through final disbursement.

The Company does not operate as a licensed gambling operator. All monetary transactions are structured as the purchase of Gold Coins (virtual currency with no cash value) and the free issuance of Sweeps Coins (promotional currency redeemable for prizes).

2. Business Model Summary

2.1 Currency Types

• Gold Coins (GC): Purchased by customers for entertainment play. Gold Coins have no monetary value and cannot be redeemed for cash or prizes.
• Sweeps Coins (SC): Issued free of charge as a bonus with Gold Coin purchases, or through free promotional channels. Sweeps Coins can be redeemed for cash prizes upon completion of applicable playthrough and verification requirements.

2.2 Revenue Model

The Company generates revenue solely from the sale of Gold Coin packages. The sale of Sweeps Coins is prohibited; they are issued exclusively as free promotional currency.

3. Inbound Funds Flow

3.1 Customer Deposit / Purchase Process

1. Customer initiates a Gold Coin package purchase on the platform website or mobile app.
2. Customer selects a payment method (credit/debit card, ACH, or other accepted method).
3. Transaction is submitted to the Company's payment processor via encrypted, PCI-DSS compliant API.
4. The Processor performs real-time fraud checks and processes the transaction against the customer's bank or card issuer.
5. Upon successful authorization, funds are settled by the Processor into the Company's designated merchant settlement account.
6. Gold Coins (and any associated Sweeps Coins bonus) are credited to the customer's account in real time.
7. Transaction details are logged in the platform's transaction management system.

3.2 Accepted Payment Methods

• Visa and Mastercard credit/debit cards
• ACH bank transfer
• PayPal (where available)
• Other alternative payment methods as approved by the compliance team

All payment methods are subject to AML/KYC review. Cash, cryptocurrency, gift cards, and anonymous payment methods are not accepted.

3.3 Merchant Account Structure

Customer purchase proceeds are deposited into the Company's primary merchant settlement account at the Company's banking institution. A single primary operating account is maintained for platform revenue. Sub-accounts are used for prize reserve and operational expense segregation.

4. Outbound Funds Flow — Prize Redemptions

4.1 Sweeps Coins Redemption Process

1. Customer meets minimum redemption threshold (typically 100 SC = $100 USD equivalent).
2. Customer completes identity verification (KYC) via Sumsub if not already completed.
3. Customer submits a redemption request through the platform dashboard.
4. Customer passes OFAC/sanctions screening and fraud review.
5. Customer provides valid payout method: ACH bank transfer or approved e-wallet.
6. Compliance team reviews and approves redemption request (typically within 1-5 business days).
7. Funds are disbursed from the Company's prize payout account to the customer's verified account.
8. Transaction is logged and reported per AML/BSA requirements.

4.2 Payout Methods

• ACH bank transfer to a verified U.S. bank account (primary method)
• PayPal transfer to verified account
• Check by mail (for exceptions, subject to enhanced review)

Cryptocurrency, prepaid cards, gift cards, and cash payouts are not permitted. All redemptions are paid exclusively to the verified account holder. Third-party payouts are prohibited.

4.3 Payout Thresholds and Review

Redemptions above $500 are subject to enhanced manual review. Redemptions above $2,500 require senior compliance approval. All redemptions above $5,000 are reviewed for SAR filing obligations.

5. Account Structure

5.1 Operating Accounts

• Primary Merchant Settlement Account: Receives all customer Gold Coin purchase proceeds.
• Prize Payout Reserve Account: Funded from the operating account to maintain adequate prize payout reserves. Dedicated solely to customer prize disbursements.
• Operating Expense Account: Used for platform operating costs. Funded by periodic transfer from the primary account.

5.2 Fund Segregation

The Company maintains strict segregation between customer prize funds and operating revenue. Minimum reserve requirements ensure prize payout obligations can be met at all times. The Company does not commingle customer prize reserves with general operating funds.

6. Third-Party Processors and Partners

• Payment Processor: Handles card and ACH transaction processing, fraud detection, and settlement.
• Sumsub: KYC/identity verification for customer onboarding and redemption approvals.
• Banking Institution: Holds all Company operating and reserve accounts.
• Fraud/Risk Platform: Real-time transaction risk scoring integrated at checkout.

All third-party partners are contractually bound to comply with applicable AML, data security, and privacy requirements.

7. Record Keeping

The Company maintains complete transaction records for all inbound and outbound fund flows for a minimum of five (5) years, including customer identity records, all purchase and redemption transaction details, processor settlement records, internal approval records, and SAR filings where applicable.

Document Approval

This document has been reviewed and approved by authorized representatives of OnPoint Administration LLC.

Authorized Signatory. OnPoint Administration LLC | OnPointCasino.us | OnPointCasino.com. Date: April 12, 2026.