AML/CFT Policy – Anti-Money Laundering and Counter and Combatting the Financing of Terrorism Policy

It is the policy of BRAZILIEX and all of its affiliates to prohibit and prevent money laundering and any activity that facilitates the laundering of money or the financing of terrorist or criminal activities. BRAZILIEX requires its officers, employees and affiliates to follow these standards to prevent the use of its products and services for illicit purposes.

Each member of BRAZILIEX, whose functions are associated with the provision of products and services of BRAZILIEX and that directly or indirectly deals with its clientele, must know the requirements of the laws and regulations applicable to the company, as well as their work responsibilities. Each member must also effectively commit to performing their respective responsibilities in compliance with the applicable laws and regulations.

Compliance with relevant laws and regulations and the prevention of money laundering is ensured by its management and directors, who have established and maintain a continuous program for this purpose. Such a program coordinates specific regulatory requirements across the group within a consolidated framework in order to effectively manage the risk of exposure to money laundering, criminal and terrorist financing across all business units, functions, and legal entities.

All identification documents and service records must be maintained for the minimum period of time required by local law. The treatment of these documents must be in accordance with the Privacy Policy of BRAZILIEX.

No transactions carried out in cash will be tolerated. The only instrument accepted for transfers of monetary values are bank transfers in national electronic currency, that is, Brazilian Real held in a banking device or electronic system that allow the end user to make an operationalized payment transaction through electronic bank transfers (“TED”) and credit order documents (“DOC”). Withdrawals made by foreigners can only be made in Brazilian Real by individuals who hold and present a Brazilian “Cadastro de Pessoa Física” (“CPF”) and through a Brazilian bank account.

Each of BRAZILIEX’s affiliates is obliged to comply with the company’s policy for the prevention of money laundering and financing of crimes and terrorism. All new employees will receive training in this regard as part of the mandatory training program for new hires. All employees whose competencies so require are also demanded to complete training in the prevention of money laundering and the financing of criminal and terrorist activities. Participation in additional targeted training programs is required for all employees with day-to-day responsibilities involved with the prevention of money laundering and the financing of criminal and terrorist activities.

All clients, partners, employees and anyone who wish to do business with BRAZILIEX declare that they are familiar with and agree to this policy in its full extent. Accordingly, BRAZILIEX reserves the right to carry out the immediate unsubscription of any client with the purpose of preventing and mitigating the risks of money laundering and the financing of crimes and terrorism.