Money Laundering Prevention Policy

Topics

Topics

1. Introduction

BLOCKBR SERVIÇOS DIGITAL LTDA. (“BLOCKBR”) acts in accordance with current laws and regulations in order to prevent its activities from being involved in Money Laundering, Terrorist Financing or other crimes of concealment of financial resources, described in Law 9,613, of 3 March 1998, as amended, and related regulatory rules.

Throughout this document, money laundering operations will be typified, the controls used by BLOCKBR will be identified and the rules for the application of the “Know your client” forms will be defined. The knowledge of any evidence of money laundering, financing of terrorism and/or any other illegal practices that are related to any operations and/or clients of BLOCK BR must be immediately communicated to the Internal Controls and Compliance department (“Compliance”), being responsible for verifying the information reported and, if applicable, communicating it to Organs regulatory bodies.

2. Objectives

This policy aims to establish guidelines and formalize the rules, procedures and controls implemented by BLOCKBR in order to prevent and mitigate practices related to money laundering, which all its members must pay attention to, especially professionals allocated to areas that carry out relationship with customers and counterparties (“Policy”).

The conduct and practices described in this Policy must be strictly observed within the activities developed by BLOCKBR, in line with local legal and regulatory requirements, and aim to prevent its Employees from being used as a vehicle for illicit activities related to financial crimes, such as attempts to launder money for criminal activities or for the financing of terrorist actions.

The custody and intermediation activities of digital assets with own resources or those of third parties, in national or foreign currency, can be used in the practice of illegal financial transactions, which makes the financial system particularly vulnerable to money laundering, making it necessary to application of this Policy to mitigate this practice.

This document applies unrestrictedly to all BLOCKBR employees, service providers and partners.

3. Concepts and acronyms

  • BACEN: Central Bank of Brazil is a federal autarchy that is part of the National Financial System without being linked to the Ministry.
  • COAF (Council for the Control of Financial Activities): Council created within the scope of the Ministry of Finance with the purpose of disciplining, applying administrative penalties, receiving, examining and identifying suspected occurrences of illegal activities provided for in Law No. 9.613/1998, without prejudice within the competence of other bodies and entities Currently it is linked to BACEN.
  • CVM: Securities and Exchange Commission, is an autarchy linked to the Ministry of Economy of Brazil, to discipline the functioning of the securities market and the performance of its protagonists.
  • LDFT: Money Laundering and Terrorist Financing.
  • FATF/FATF: Financial Action Group against Money Laundering and Terrorist Financing, an intergovernmental organization that aims to develop and promote national and international policies to combat money laundering and terrorist financing.

4. Regulatory standards

The activities developed by BLOCKBR are not directly and specifically regulated. However, for the purposes of preventing and combating money laundering, provisions contained in financial market disciplinary rules can be used, among which it is worth mentioning:

Law No. 9613/98 - Deals with crimes of “laundering” or concealment of assets, rights and values; the prevention of the use of the financial system for the respective illicit acts and creates the COAF - Council for the Control of Financial Activities;

CVM Instruction No. 617/19 - Provides for the identification, registration, registration, operations, communication, limits and administrative responsibility related to money laundering and terrorist financing crimes in the securities market;

BACEN Circular No. 3,978/20 - Provides for the procedures to be adopted in the prevention and combat of activities related to the crimes provided for in Law No. 9,613/98;

BACEN Circular Letter No. 4001/20 – Provides for the list of operations and situations that may constitute evidence of the occurrence of crimes provided for in Law No. 9,613/98, subject to communication to the Financial Activities Control Council – COAF;

Rules issued by COAF – Financial Activities Control Council.

In 2012, Law No. 9,613 was amended by Law No. 12,683, which brought important advances in the prevention and fight against money laundering, such as the extinction of the exhaustive list of antecedent crimes, now admitting as a antecedent crime of money laundering any criminal offense.

5. Customer registration

Customer registration is an essential element in preventing and combating money laundering and terrorist financing crimes, which makes it essential to comply with all the precepts contained in the Rules and Procedures Policy of the Registration department ("Registration").

Therefore, BLOCKBR must keep the registration information of its customers, so that, within reasonable criteria and technical possibilities, it is possible to identify the beneficiary of the operations carried out on its platform, submitting all its customers to fill out the registration form in advance. to the use of any product or service offered by BLOCKBR. Also, so that BLOCKBR can validate and keep the registration information of its clients up to date, other relevant documents may be requested, at BLOCKBR's sole discretion.

The BLOCKBR registration form is clear and objective, all documentation must be carefully analyzed in order to confirm the registration. For updating purposes, each customer's record must be updated at intervals not exceeding[24 (vinte e quatro)] months, without prejudice to the possibility for customers to communicate further updates at any time.

Also, BLOCKBR will spread to its customers the importance of keeping the registration data always updated and correct. When this update is not carried out within the established period and after communication to the customer, the use of certain products and services by such customer may be interrupted until the situation is regularized before the Registry.

Considering the main guidelines and rules existing in the financial and asset trading market, as well as the analysis of the main cases of money laundering, it is possible to list the most sensitive people involved in the crime of money laundering. In these cases, all BLOCKBR employees must pay special attention to customers who may fall into any of the categories below.

5.1 Politically Exposed Persons (PEP) : In compliance with the regulations in force, BLOCKBR and its employees must pay special attention to politically exposed persons.

PEPs are considered to be people who in the last 5 (five) years have met the following conditions: (I) the holders of elective mandates of the Executive and Legislative Powers of the Union; (II) the holders of positions, in the Executive Power of the Union, Minister of State or equivalent, Special Nature or equivalent; (III) president, vice-president and director, or equivalent, of entities of the indirect public administration; (IV) Senior Management and Advisory Group – DAS, level 6, or equivalent; (V) the members of the National Justice Council, the Federal Supreme Court, the Superior Courts and the Federal, Labor and Electoral Regional Courts, the Superior Labor Justice Council and the Federal Justice Council; (VI) the members of the National Council of the Public Ministry, the Attorney General of the Republic, the Deputy Attorney General of the Republic, the Attorney General of Labor, the Attorney General of Military Justice, the Deputy Attorneys General of the Republic and the Attorneys General of Justice of the States and the Federal District; (VII) the members of the Federal Court of Accounts and the Attorney General, and the Deputy Attorneys General of the Public Ministry at the Federal Court of Accounts; (VIII) the national presidents and treasurers, or equivalent, of political parties; (IX) the governors and secretaries of the State and the Federal District, the State and District Deputies, the presidents, or equivalent, of entities of the state and district indirect public administration and the presidents of Courts of Justice, Military, of Accounts or equivalent of State and the Federal District; (X) Mayors, Councilors, Municipal Secretaries, presidents, or equivalent, of entities of the municipal indirect public administration and presidents of Courts of Auditors, or equivalent, of the Municipalities. Politically exposed persons are also considered to be those who, abroad, are: (I) heads of state or government; (II) senior politicians; (III) occupants of government positions at higher levels; (IV) general officers and members of higher echelons of the judiciary, the legislature or the military; (V) senior executives of public companies; or (VI) leaders of political parties; (VII) senior managers of public or private international law entities.

5.2 “Suspicious” persons : These are those persons who, due to personal and professional characteristics, are more susceptible to involvement in money laundering, terrorist financing, among other illicit acts, even if unintentionally.

According to the sector of activity and the profession exercised, people who work in the tourism, gaming, air transport, insurance companies, currency exchange bureaus, among others, are considered “suspicious”.

People residing in border areas are also considered “suspicious”, in addition to clients over 70 (seventy) and under 18 (eighteen) years old and those who appoint attorneys for the purpose of representation before BLOCKBR.

Individuals or legal entities that have already been involved in the practice of crimes related to money laundering and have any type of reputational problems as a result of the disclosure in the media of facts related to crimes of money laundering and the like that had previously occurred should be considered "suspected ” and observed by Compliance.

6. PLD/CFT program guidelines

6.1. Money laundry

Money Laundering is the processing of profits from illicit sources as proceeds of crime in order to disguise their origin, allowing the criminal to enjoy these benefits without making their source public.

The FATF/FATF definition of such crimes is: To disguise illicit profits without compromising those involved, money laundering is carried out through a dynamic process that requires: (i) distancing the funds from their origin, avoiding their direct association with crime; (ii) the disguise of its various movements to make it difficult to track these resources; and (iii) making the money available again to criminals after it has been sufficiently moved through the laundering cycle to be considered “clean”.

There are three stages to the crime of Money Laundering:

  • Placement: it is the step of distancing the resources from their origin, that is, it is the placement of the money in the economic system. To hide its origin, the criminal seeks to move the money in countries with more permissive rules or in those that have a financial system with less strict controls;
  • Concealment: this is the stage of the process that makes it difficult to track illicit resources in accounting. The objective is to break the chain of evidence before the possibility of carrying out investigations into the origin of the money; and
  • Integration: in this last step, the assets are formally incorporated into the economic system. Criminal organizations seek to invest in enterprises that facilitate their activities. BLOCKBR will always act under the terms and limits established by the applicable legislation and regulations in force. In addition, BLOCKBR will act with transparency and based on ethical standards of conduct, always observing the conduct and good practices established through this Policy.

6.2. Terrorism Financing

Terrorist Financing is related to a future action, not aiming to hide illicit resources, but to gather funds of any nature (legal or illegal) to carry out terrorist acts.

7. Know your customer (KYC) procedures

7.1. DEFINITION

The KYC procedure has the objective of verifying and knowing the origin, constitution of the assets and financial resources of its clients, seeking to identify and monitor situations that may qualify as suspicious or configure any indications of LDFT practices. Adequate knowledge of customer characteristics minimizes the risk of entry and movement of illicit capital through BLOCKBR. In order to minimize such risks, the following procedures are adopted:

  • Physical person

o Identification of tax regularity with the Federal Revenue Service of Brazil;

o Identification of the credit situation with the credit bureaus (which may or may not be subject to this analysis);

o Suitability profile identification;

o PEP identification;

o Identification of discrediting news.

  • Legal person

o Identification of tax regularity with the Federal Revenue Service of Brazil;

o Identification of the credit situation with the credit bureaus (which may or may not be subject to this analysis);

o Identification of the company's organizational structure.

7.2. PROCESS FOR PERFORMING PERSONAL VISITS

Personal visits will be carried out when some of the following factors are observed:

  • Research regarding negative media indicated points of questioning
  • Incompatibility between declared income/investment
  • Corporate structure of a PJ investor presents overlapping partners in other companies

7.3. CLIENT RISK LEVEL SCALE

In order to allow the analysis to accurately reflect the level of risk, in terms of PLDFT, the KYC procedure establishes a “Customer Risk Scale”:

  • Low risk: customers without any indication or characteristics that may constitute indications of LDFT practices or that place them in a position of susceptibility to the practice of such crimes. It should be noted that the same criteria and requirements for updating registration must be maintained for customers in this category.
  • Medium risk: customers who present indications or have informed situations that place them in a situation of possible vulnerability to involvement in LDFT crimes, among which those who present any of the characteristics listed in item 5.2 above can be mentioned in isolation or in conjunction with any other that may be considered relevant by Compliance.
  • High risk: customers who present personal, professional or any other characteristics that place them in a position highly susceptible to involvement in the practice of LDFT illicit acts, including, but not limited to, people described in item 5.1 of this Policy and/or who present multiple characteristics among those described in item 5.2 above.

8. Indications of Policy Violation

As reiterated throughout this Policy, it is the duty of all BLOCKBR employees to respect compliance with the rules and guidelines set forth herein, taking steps to report any evidence of non-compliance with the practices now exposed to Compliance, in order to prevent digital wallets from ("Wallets ”) of BLOCKBR, among other products, are used by third parties and customers as a form of application in illegal or illegal activities.

Pursuant to the applicable regulations, the following are indications to be observed by employees, configured as operations:

  • that present a sudden change and without objective justification in relation to the operational modalities usually used by the client;
  • with values that are incompatible between the reported professional occupation and the declared patrimonial situation;
  • with a degree of complexity and risk incompatible with the technical qualification of the client or its representative;
  • with significant fluctuation in relation to the volume and/or frequency of trades of any of the parties involved;
  • with characteristics that demonstrate acting, consistently, on behalf of third parties;
  • that are carried out between the same parties or for the benefit of the same parties, in which there are consecutive gains or losses with regard to any of the parties involved; and
  • devoid of economic foundation, carried out with the purpose of generating loss or gain.

The following practices can also be configured as evidence of money laundering:

  • resistance to providing the information necessary for registering and opening an account;
  • declaration of several bank accounts and/or constant modification; and
  • opening an account and appointing a proxy without any apparent connection.

BLOCKBR employees who become aware of any of the above practices must report to Compliance informing about the occurrence of such practices, respecting the duty of secrecy and assessment of the facts by Compliance.

After an investigation carried out by Compliance regarding the reported facts, the occurrence may be filed, if the materiality of any of the complaints made is not proven.

However, in the face of any of the signs listed above or a complaint received by an employee that may require a more careful evaluation, some measures may be taken by Compliance in order to examine the situation, such as a request for registration update, request for clarifications and even suspension of access to the BLOCKBR platform.

In the case of confirmation of the complaints with proof of the materiality of the denounced practices, a formal communication will be prepared to COAF, which must be previously evaluated and approved by the[Compliance] .

9. General provisions

BLOCKBR Compliance is responsible for changing this Policy whenever necessary.

This Policy is effective on the date of its approval and revokes any documents to the contrary.

1. Introduction

BLOCKBR SERVIÇOS DIGITAL LTDA. (“BLOCKBR”) acts in accordance with the laws and regulations in force in order to prevent its activities from being involved in Money Laundering, Terrorist Financing or other crimes of concealment of financial resources, described in Law 9,613, of 3 March 1998, as amended, and related regulatory rules.

Throughout this document, money laundering operations will be typified, the controls used by BLOCKBR will be identified and the rules for the application of the “Know your client” forms will be defined. The knowledge of any evidence of money laundering, financing of terrorism and/or any other illegal practices that are related to any operations and/or clients of BLOCK BR must be immediately communicated to the Internal Controls and Compliance department (“Compliance”), being responsible for verifying the information reported and, if applicable, communicating it to Organs regulatory bodies.

2. Objectives

This policy aims to establish guidelines and formalize the rules, procedures and controls implemented by BLOCKBR in order to prevent and mitigate practices related to money laundering, which all its members must pay attention to, especially professionals allocated to areas that carry out relationship with customers and counterparties (“Policy”).

The conduct and practices described in this Policy must be strictly observed within the activities developed by BLOCKBR, in line with local legal and regulatory requirements, and aim to prevent its Employees from being used as a vehicle for illicit activities related to financial crimes, such as attempts to launder money for criminal activities or for the financing of terrorist actions.

The custody and intermediation activities of digital assets with own resources or those of third parties, in national or foreign currency, can be used in the practice of illegal financial transactions, which makes the financial system particularly vulnerable to money laundering, making it necessary to application of this Policy to mitigate this practice.

This document applies unrestrictedly to all BLOCKBR employees, service providers and partners.

3. Concepts and acronyms

  • BACEN: Banco Central do Brasil is a federal autarchy that is part of the National Financial System without being linked to the Ministry.
  • COAF (Council for the Control of Financial Activities): Council created within the scope of the Ministry of Finance with the purpose of disciplining, applying administrative penalties, receiving, examining and identifying suspected occurrences of illegal activities provided for in Law No. 9.613/1998, without prejudice within the competence of other bodies and entities Currently it is linked to BACEN.
  • CVM: Securities and Exchange Commission, is an autarchy linked to the Ministry of Economy of Brazil, to discipline the functioning of the securities market and the performance of its protagonists.
  • LDFT: Money Laundering and Terrorist Financing.
  • FATF/FATF: Financial Action Group against Money Laundering and Terrorist Financing, an intergovernmental organization that aims to develop and promote national and international policies to combat money laundering and terrorist financing.

4. Regulatory standards

The activities developed by BLOCKBR are not directly and specifically regulated. However, for the purposes of preventing and combating money laundering, provisions contained in financial market disciplinary rules can be used, among which it is worth mentioning:

Law No. 9613/98 - Deals with crimes of “laundering” or concealment of assets, rights and values; the prevention of the use of the financial system for the respective illicit acts and creates the COAF - Council for the Control of Financial Activities;

CVM Instruction No. 617/19 - Provides for the identification, registration, registration, operations, communication, limits and administrative responsibility related to money laundering and terrorist financing crimes in the securities market;

BACEN Circular No. 3,978/20 - Provides for the procedures to be adopted in the prevention and combat of activities related to the crimes provided for in Law No. 9,613/98;

BACEN Circular Letter No. 4001/20 – Provides for the list of operations and situations that may constitute evidence of the occurrence of crimes provided for in Law No. 9,613/98, subject to communication to the Financial Activities Control Council – COAF;

Rules issued by COAF – Financial Activities Control Council.

In 2012, Law No. 9,613 was amended by Law No. 12,683, which brought important advances in the prevention and fight against money laundering, such as the extinction of the exhaustive list of antecedent crimes, now admitting as a antecedent crime of money laundering any criminal offense.

5. Customer registration

Customer registration is an essential element in preventing and combating money laundering and terrorist financing crimes, which makes it essential to comply with all the precepts contained in the Rules and Procedures Policy of the Registration department ("Registration").

Therefore, BLOCKBR must keep the registration information of its customers, so that, within reasonable criteria and technical possibilities, it is possible to identify the beneficiary of the operations carried out on its platform, submitting all its customers to fill out the registration form in advance. to the use of any product or service offered by BLOCKBR. Also, so that BLOCKBR can validate and keep the registration information of its clients up to date, other relevant documents may be requested, at BLOCKBR's sole discretion.

The BLOCKBR registration form is clear and objective, all documentation must be carefully analyzed in order to confirm the registration. For updating purposes, each customer's record must be updated at intervals not exceeding[24 (vinte e quatro)] months, without prejudice to the possibility for customers to communicate further updates at any time.

Also, BLOCKBR will spread to its customers the importance of keeping the registration data always updated and correct. When this update is not carried out within the established period and after communication to the customer, the use of certain products and services by such customer may be interrupted until the situation is regularized before the Registry.

Considering the main guidelines and rules existing in the financial and asset trading market, as well as the analysis of the main cases of money laundering, it is possible to list the most sensitive people involved in the crime of money laundering. In these cases, all BLOCKBR employees must pay special attention to customers who may fall into any of the categories below.

5.1 Politically Exposed Persons (PEP) : In compliance with the regulations in force, BLOCKBR and its employees must pay special attention to politically exposed persons.

PEPs are considered to be people who in the last 5 (five) years have met the following conditions: (I) the holders of elective mandates of the Executive and Legislative Powers of the Union; (II) the holders of positions, in the Executive Power of the Union, Minister of State or equivalent, Special Nature or equivalent; (III) president, vice-president and director, or equivalent, of entities of the indirect public administration; (IV) Senior Management and Advisory Group – DAS, level 6, or equivalent; (V) the members of the National Justice Council, the Federal Supreme Court, the Superior Courts and the Federal, Labor and Electoral Regional Courts, the Superior Labor Justice Council and the Federal Justice Council; (VI) the members of the National Council of the Public Ministry, the Attorney General of the Republic, the Deputy Attorney General of the Republic, the Attorney General of Labor, the Attorney General of Military Justice, the Deputy Attorneys General of the Republic and the Attorneys General of Justice of the States and the Federal District; (VII) the members of the Federal Court of Accounts and the Attorney General, and the Deputy Attorneys General of the Public Prosecutor's Office at the Federal Court of Accounts; (VIII) the national presidents and treasurers, or equivalent, of political parties; (IX) the governors and secretaries of the State and the Federal District, the State and District Deputies, the presidents, or equivalent, of entities of the state and district indirect public administration and the presidents of Courts of Justice, Military, of Accounts or equivalent of State and the Federal District; (X) Mayors, Councilors, Municipal Secretaries, presidents, or equivalent, of entities of the municipal indirect public administration and presidents of Courts of Auditors, or equivalent, of the Municipalities. Politically exposed persons are also considered to be those who, abroad, are: (I) heads of state or government; (II) senior politicians; (III) occupants of government positions at higher levels; (IV) general officers and members of higher echelons of the judiciary, the legislature or the military; (V) senior executives of public companies; or (VI) leaders of political parties; (VII) senior managers of public or private international law entities.

5.2 “Suspicious” persons : These are those persons who, due to personal and professional characteristics, are more susceptible to involvement in money laundering, terrorist financing, among other illicit acts, even if unintentionally.

According to the sector of activity and the profession exercised, people who work in the tourism, gaming, air transport, insurance companies, currency exchange bureaus, among others, are considered “suspicious”.

People residing in border areas are also considered “suspicious”, in addition to clients over 70 (seventy) and under 18 (eighteen) years old and those who appoint attorneys for the purpose of representation before BLOCKBR.

Individuals or legal entities that have already been involved in the practice of crimes related to money laundering and have any type of reputational problems as a result of the disclosure in the media of facts related to crimes of money laundering and the like that had previously occurred should be considered "suspected ” and observed by Compliance.

6. PLD/CFT program guidelines

6.1. Money laundry

Money Laundering is the processing of profits from illicit sources as proceeds of crime in order to disguise their origin, allowing the criminal to enjoy these benefits without making their source public.

The FATF/FATF definition of such crimes is: To disguise illicit profits without compromising those involved, money laundering is carried out through a dynamic process that requires: (i) distancing the funds from their origin, avoiding their direct association with crime; (ii) the disguise of its various movements to make it difficult to track these resources; and (iii) making the money available again to criminals after it has been sufficiently moved through the laundering cycle to be considered “clean”.

There are three stages of the crime of Money Laundering:

  • Placement: it is the step of distancing the resources from their origin, that is, it is the placement of the money in the economic system. To hide its origin, the criminal seeks to move the money in countries with more permissive rules or in those that have a financial system with less strict controls;
  • Concealment: this is the stage of the process that makes it difficult to track illicit resources in accounting. The objective is to break the chain of evidence before the possibility of carrying out investigations into the origin of the money; and
  • Integration: in this last step, the assets are formally incorporated into the economic system. Criminal organizations seek to invest in enterprises that facilitate their activities. BLOCKBR will always act under the terms and limits established by the applicable legislation and regulations in force. In addition, BLOCKBR will act with transparency and based on ethical standards of conduct, always observing the conduct and good practices established through this Policy.

6.2. Terrorism Financing

Terrorist Financing is related to a future action, not aiming to hide illicit resources, but to gather funds of any nature (legal or illegal) to carry out terrorist acts.

7. Know your customer (KYC) procedures

7.1. DEFINITION

The KYC procedure has the objective of verifying and knowing the origin, constitution of the assets and financial resources of its clients, seeking to identify and monitor situations that may qualify as suspicious or configure any indications of LDFT practices. Adequate knowledge of customer characteristics minimizes the risk of entry and movement of illicit capital through BLOCKBR. In order to minimize such risks, the following procedures are adopted:

  • Physical person

o Identification of tax regularity with the Federal Revenue Service of Brazil;

o Identification of the credit situation with the credit bureaus (which may or may not be subject to this analysis);

o Suitability profile identification;

o PEP identification;

o Identification of discrediting news.

  • Legal person

o Identification of tax regularity with the Federal Revenue Service of Brazil;

o Identification of the credit situation with the credit bureaus (which may or may not be subject to this analysis);

o Identification of the company's organizational structure.

7.2. PROCESS FOR PERFORMING PERSONAL VISITS

Personal visits will be carried out when some of the following factors are observed:

  • Research regarding negative media indicated points of questioning
  • Incompatibility between declared income/investment
  • Corporate structure of a PJ investor presents overlapping partners in other companies

7.3. CLIENT RISK LEVEL SCALE

In order to allow the analysis to accurately reflect the level of risk, in terms of PLDFT, the KYC procedure establishes a “Customer Risk Scale”:

  • Low risk: customers without any indication or characteristics that may constitute indications of LDFT practices or that place them in a position of susceptibility to the practice of such crimes. It should be noted that the same criteria and requirements for updating registration must be maintained for customers in this category.
  • Medium risk: customers who present indications or have informed situations that place them in a situation of possible vulnerability to involvement in LDFT crimes, among which those who present any of the characteristics listed in item 5.2 above can be mentioned in isolation or in conjunction with any other that may be considered relevant by Compliance.
  • High risk: customers who present personal, professional or any other characteristics that place them in a position highly susceptible to involvement in the practice of LDFT illicit acts, including, but not limited to, people described in item 5.1 of this Policy and/or who present multiple characteristics among those described in item 5.2 above.

8. Indications of Policy Violation

As reiterated throughout this Policy, it is the duty of all BLOCKBR employees to respect compliance with the rules and guidelines set forth herein, taking steps to report any evidence of non-compliance with the practices now exposed to Compliance, in order to prevent digital wallets from ("Wallets ”) of BLOCKBR, among other products, are used by third parties and customers as a form of application in illegal or illegal activities.

Pursuant to the applicable regulations, the following are indications to be observed by employees, configured as operations:

  • that present a sudden change and without objective justification in relation to the operational modalities usually used by the client;
  • with values that are incompatible between the reported professional occupation and the declared patrimonial situation;
  • with a degree of complexity and risk incompatible with the technical qualification of the client or its representative;
  • with significant fluctuation in relation to the volume and/or frequency of trades of any of the parties involved;
  • with characteristics that demonstrate acting, consistently, on behalf of third parties;
  • that are carried out between the same parties or for the benefit of the same parties, in which there are consecutive gains or losses with respect to any of the parties involved; and
  • without economic foundation, carried out with the purpose of generating loss or gain.

The following practices can also be configured as evidence of money laundering:

  • resistance to providing the information necessary for registering and opening an account;
  • declaration of several bank accounts and/or constant modification; and
  • opening an account and appointing a proxy without any apparent connection.

BLOCKBR employees who become aware of any of the above practices must report to Compliance informing about the occurrence of such practices, respecting the duty of secrecy and assessment of the facts by Compliance.

After an investigation carried out by Compliance regarding the reported facts, the occurrence may be filed, if the materiality of any of the complaints made is not proven.

However, in the face of any of the signs listed above or a complaint received by an employee that may require a more thorough evaluation, some measures may be taken by Compliance in order to examine the situation, such as a request for registration update, request for clarifications and even suspension of access to the BLOCKBR platform.

In the case of confirmation of the complaints with proof of the materiality of the denounced practices, a formal communication will be prepared to COAF, which must be previously evaluated and approved by the[Compliance] .

9. General provisions

BLOCKBR Compliance is responsible for changing this Policy whenever necessary.

This Policy is effective on the date of its approval and revokes any documents to the contrary.

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