REGULATORYCOMPLIANCE

Regulatory Compliance Statement

Effective: 02 January 2026Updated: April 2026

Metawell Sports Limited is fully committed to operating in compliance with all applicable UAE federal laws, RAK Innovation City regulations, India's PROGA 2025 (as applicable to esports), international AML/CFT standards, and relevant global privacy and consumer protection frameworks. Compliance is built into our operational architecture — not retrofitted. This framework is subject to ongoing review and validation by external legal counsel; formal legal opinions are available upon request for authorised due diligence purposes.

1. Company Registration & Verified Licensing

Company NameMetawell Sports Limited
Registration Number01010965
Business Licence Number07010938
Legal TypeCompany Limited by Shares — Sole Shareholder, Sole Director
Incorporation Date02 January 2026
Licence Validity02 January 2026 – 01 January 2027 (annual renewable)
D-U-N-S Number57-114-1643 (Issued 06 February 2026 — CRIF Gulf DWC LLC / Dun & Bradstreet)
Free Zone AuthorityRAK Innovation City (RAK INC), Government of Ras Al Khaimah, United Arab Emirates
Entity ClassificationNon-custodial utility gaming platform — not a financial service, exchange, or investment operator (based on current legal analysis, subject to regulatory interpretation)
Verification Portalverify.rakdao.com/document · Cert: 857117-Oyuxyk · Licence: 743021-Ypokky · MOA: 337252-Jzkpla

2. Licensed Business Activities

Licensed ActivityCPL Games RelevanceStatus
Gaming PublisherPublishing and operating CPL eCricket esports application on Android, iOS, and webActive
E Sports EcosystemCompetitive tournaments, GECPL League, global leaderboards, and full esports competition structureActive
Gaming StudioIn-house game design, development, and production operationsActive
Gaming Production Service ProvidersPlatform infrastructure, game engine operations, and technical service provisionActive
Web Portals – Web 3.0opBNB blockchain integration, NFT marketplace, smart contract managementActive
Artificial IntelligenceAI-powered gameplay analytics, match analysis, anti-cheat systemsActive
Metaverse Service ProviderVirtual stadium environments and immersive eCricket experiencesActive
Data Management & Cyber SecurityPlatform security, user data management, threat monitoring, cybersecurity complianceActive

3. UAE Regulatory Framework

FrameworkStatusKey Details
RAK Law No. 2 of 2023CompliantCompany incorporated, licensed, and operating under RAK Innovation City regulations
UAE Federal Law No. 32 of 2021CompliantSingle-shareholder company; Board Resolution executed; MOA signed and registered
UAE PDPL — Decree-Law No. 45/2021CompliantPrivacy Policy implemented; DPO appointed; legal bases defined; user rights framework operational
UAE AML — Decree-Law No. 20/2018CompliantAML/CFT Policy v1.0 active; MLRO appointed; goAML STR reporting operational; Chainalysis/TRM Labs or equivalent blockchain analytics in use
UAE Cabinet Decision No. 10/2019CompliantCDD/KYC implemented; EDD for PEPs; sanctions screening (CBUAE/UN/OFAC/EU) active
VARA Guidelines (Virtual Assets)Based on current legal analysis, non-VASP classificationPlatform is non-custodial utility gaming service — based on current legal analysis, not subject to VASP licensing. All VARA developments actively monitored; classification is subject to regulatory interpretation.
UAE Consumer Protection — Law No. 15/2020CompliantClear terms, transparent pricing, no unfair trade practices, complaint handling in place

4. AML/CFT Compliance Programme

Programme ElementDetailsStatus
MLRO / Compliance OfficerMurlidhar Abhimanyu Tripathi — Director/CEO · +971 567672367 · md@metawellsports.comAppointed
AML/CFT PolicyVersion 1.0 signed and active from 02 January 2026 — aligned with UAE AML Law and FATF 40 Recommendations (updated October 2025)Active
Blockchain AnalyticsChainalysis (Reactor/KYT), TRM Labs, Elliptic, or equivalent industry-standard provider — wallet screening, transaction risk scoring, ongoing monitoringActive
Customer Due Diligence (CDD/KYC)Risk-tiered identity verification at appropriate thresholds per RAK INC guidance and UAE AML LawActive
Enhanced Due Diligence (EDD)Applied to Politically Exposed Persons (PEPs), high-value users, and high-risk geographic profilesActive
Sanctions ScreeningAll users and partners screened against UAE (CBUAE), UN, OFAC, and EU consolidated sanctions lists — real-time or near-real-timeActive
Suspicious Transaction ReportingFiled via goAML to UAE Financial Intelligence Unit (FIU). Tipping-off strictly prohibited.Active
Record KeepingAll CDD documentation and transaction records retained minimum 5 yearsActive
Annual AML/CFT TrainingMandatory annual training for all relevant personnel and the MLROActive
No Customer Deposits PolicyCompany does not accept, hold, or custody customer fiat or digital asset fundsConfirmed

5. India — PROGA 2025 Compliance

CPL Games is designed, built, and operated as skill-based esports. India's Promotion and Regulation of Online Gaming Act, 2025 (PROGA) explicitly separates skill-based esports from prohibited 'online money games'.

  • All match outcomes are 100% skill-determined — zero random mechanics, zero wagering, zero betting
  • CPL Tokens are utility tokens — not stakes or bets in any game
  • CPL Games does NOT constitute an "online money game" under PROGA
  • Supporting judicial precedents: K.R. Lakshmanan v. State of Tamil Nadu (1996 SC); Dream11 SC validation (2021)
Current PROGA Status — April 2026PROGA received Presidential assent on 22 August 2025. Enforcement provisions are NOT YET formally notified by the central government. Constitutional challenges are pending before the Supreme Court of India — three-judge bench (Head Digital Works Pvt Ltd and others v. Union of India), hearings ongoing through 2026. State-level restrictions are independently enforced. Metawell Sports Limited actively monitors all developments and will update Indian user access and platform operations as required by law.

6. Global Privacy & Standards

FrameworkJurisdictionCompliance Level
GDPREU/EEA usersAligned — DPO appointed; legal bases defined; user rights; SCCs for cross-border transfers
CCPA/CPRACalifornia residentsAligned — user rights honoured; no sale of personal data; non-discrimination guaranteed
DPDP Act 2023IndiaAligned — data fiduciary obligations; user consent framework; rights mechanism operational
FATF 40 Recommendations (Oct 2025)All digital asset activitiesCompliant — full AML/CFT programme aligned with FATF standards including June 2025 Travel Rule revisions
EU MiCA (July 2026 enforcement)EU usersMonitored — NFTs are unique, non-fungible in-game digital goods generally excluded from MiCA scope; non-CASP position based on current legal analysis

7. Responsible Gaming

  • Age Verification: 18+ strictly enforced at registration — zero tolerance for underage access
  • Skill-Only Platform: Zero gambling mechanics, zero chance-based outcomes, zero wagering — 100% skill-determined competition
  • On-Chain Transparency: All material transactions on opBNB — publicly and independently auditable
  • User Controls: Account suspension and full data deletion available on user request at any time
  • Regulatory Monitoring: Continuous global regulatory monitoring — operations updated as required by law

8. Regulatory Contact

MLRO / Compliance Officer

Murlidhar Abhimanyu Tripathi

Compliance Email

md@metawellsports.com

Phone

+971 567672367

Verification Portal

verify.rakdao.com/document

Registered Address

Office A, RAK Innovation City Business Centre, Ras Al Khaimah, UAE, P.O. Box 30099

Support

md@metawellsports.com