Money Laundering Prevention Policy

BLOCKBR SERVIÇOS DIGITAIS LTDA. (“BLOCKBR”) operates in compliance with current laws and regulations to prevent its activities from being involved in Money Laundering, Terrorism Financing, or other crimes related to the concealment of financial resources, as described in Law No. 9,613 of March 3, 1998, as amended, and respective regulatory norms.

Throughout this document, money laundering operations will be typified, controls used by BLOCKBR will be identified, and rules for the application of 'Know Your Customer' forms will be defined. Knowledge of any indication of money laundering, terrorism financing, or any other illicit practices related to any operations and/or clients of BLOCK BR must be immediately reported to the Internal Controls and Compliance department (“Compliance”), which is responsible for investigating the reported information and, if applicable, informing the regulatory authorities.

This policy aims to establish the guidelines and formalize the rules, procedures, and controls implemented by BLOCKBR to prevent and mitigate practices related to money laundering, to which all its members must pay attention, especially professionals assigned to areas that engage with clients and counterparts (“Policy”).

The behaviors and practices described in this Policy must be strictly observed within the activities carried out 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 to finance terrorist actions.

The custody and intermediation of digital assets with its own or third-party resources, in national or foreign currency, can be used in the practice of illegal financial transactions, making it necessary to apply this Policy to mitigate this practice.

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

BACEN: Banco Central do Brasil is a federal autarchy integrated into the National Financial System without affiliation to a Ministry.

COAF (Conselho de Controle de Atividades Financeiras): Council created under the Ministry of Finance with the purpose of regulating, applying administrative penalties, receiving, examining, and identifying suspicious occurrences of illicit activities provided for in Law No. 9,613/1998, without prejudice to the competence of other organs and entities. Currently, it is linked to BACEN.

CVM: Comissão de Valores Mobiliários is an autarchy linked to the Ministry of Economy of Brazil, responsible for regulating the operation of the securities market and the actions of its protagonists.

LDFT: Money Laundering and Terrorism Financing.

GAFI/FATF: Financial Action Task Force on Money Laundering and Terrorism Financing.

The activities carried out by BLOCKBR are not directly and specifically regulated. However, for the purpose of preventing and combating money laundering, the provisions of regulatory rules in the financial market can be used, including:

Law No. 9,613/98 - Provides for the crimes of money laundering or concealment of assets, rights, and values; prevention of the use of the financial system for such offenses; and establishes the COAF - Financial Activities Control Council;

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

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

BACEN Circular Letter No. 4001/20 – Provides a list of operations and situations that may constitute indications of the crimes provided for in Law No. 9,613/98, which should be reported 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 significant advances in preventing and combating money laundering, such as the elimination of the exhaustive list of predicate crimes, now allowing any criminal offense to be considered a predicate crime for money laundering.

Customer registration is an essential element in the prevention and combating of money laundering and terrorism financing, making it imperative to comply with all the precepts contained in the Registration Department's Rules and Procedures Policy (“Registration Policy).

Therefore, BLOCKBR must keep the registration information of its customers, in a way that, within reasonable criteria and technical possibilities, it is possible to identify the beneficiary of the operations carried out on its platform, subjecting all its customers to the completion of the registration form before using any product or service offered by BLOCKBR. Furthermore, for BLOCKBR to validate and keep its customers' registration information up-to-date, other relevant documents may be requested, at the sole discretion of BLOCKBR.

BLOCKBR's registration form is clear and objective, and all documentation must be carefully analyzed for the purpose of confirming the registration. For the purpose of updating, each customer's registration must be updated no later than every 24 (twenty-four) months, without prejudice to the possibility that customers may communicate other updates at any time.

Furthermore, BLOCKBR will inform its customers about the importance of keeping their registration data always up-to-date and correct. When this update is not carried out within the established deadline and after communication to the customer, the use of certain products and services by such customer may be suspended until the situation is regularized with the Registration Department.

Considering the main guidelines and rules in the financial and asset trading market, as well as the analysis of the main cases of money laundering, it is possible to relate the individuals most sensitive to involvement in 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 accordance with current regulations, BLOCKBR and its employees must pay special attention to politically exposed persons.

PEP includes individuals who, in the last 5 (five) years, have met the following conditions: (I) holders of elective positions in the Executive and Legislative branches of the Union; (II) holders of positions in the Union's Executive branch, Ministers of State or equivalent, Special Nature or equivalent; (III) President, Vice President, Director, or equivalent, of entities of the indirect public administration; (IV) Senior Management and Advisory Group - DAS, level 6, or equivalent; (V) members of the National Council of Justice, Supreme Federal Court, Superior Courts, Regional Federal, Labor, and Electoral Courts, Superior Labor Justice, and Federal Justice Council; (VI) members of the National Council of the Public Prosecutor's Office, the Attorney General of the Republic, the Deputy Attorney General of the Republic, the Attorney General of Labor, the Attorney General of Military Justice, Deputy Attorneys General of the Republic, and Attorneys General of the States and the Federal District; (VII) members of the Court of Auditors of the Union and the Attorney General, and Deputy Attorneys General of the Public Prosecutor's Office with the Court of Auditors of the Union; (VIII) national presidents and treasurers, or equivalent, of political parties; (IX) governors and state and federal district secretaries, state and federal district deputies, presidents, or equivalent, of state and federal district entities of indirect public administration, and presidents of Courts of Justice, Military Courts, of Accounts, or equivalent of States and the Federal District; (X) mayors, councilors, municipal secretaries, presidents, or equivalent, of municipal entities of indirect public administration and presidents of Audit Courts, or equivalent, of Municipalities. Politically exposed persons abroad also include: (I) heads of state or government; (II) senior-level politicians; (III) holders of high-level government positions; (IV) senior generals and members of senior levels of the judiciary, legislative, or military branches; (V) senior executives of state-owned enterprises; or (VI) leaders of political parties; (VII) leaders of senior levels of entities of public or private international law.

5.2. “Suspect” Persons: These are individuals who, due to personal and professional characteristics, have a higher susceptibility to involvement in money laundering, terrorism financing, among other offenses, even if unintentional.

Depending on the sector of activity and the profession exercised, individuals working in the tourism, gaming, air transport, insurance companies, exchange houses, among others, are considered “suspect.” Also considered “suspect” are individuals residing in border areas, as well as customers over 70 (seventy) and under 18 (eighteen) years of age, and those who appoint attorneys for representation before BLOCKBR.

Individuals or legal entities that have been involved in crimes related to money laundering and have any kind of reputational problems due to media disclosure of facts related to money laundering and related offenses that have previously occurred should be considered “suspect” and monitored by Compliance.

6.1. Money Laundering

Money laundering is the processing of proceeds from illegal sources as the products of crime, in order to disguise their origin, allowing criminals to enjoy these benefits without disclosing their source.

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

There are three stages of money laundering:

Placement: This is the stage of distancing the resources from their origin, i.e., placing the money in the economic system. To conceal its origin, the criminal seeks to move the money in countries with more permissive rules or those with a financial system with less stringent controls; Layering: This is the stage of the process that involves making it difficult to trace the accounting of illicit funds. The goal is to break the chain of evidence in case of investigations into the source of the money; and Integration: In this final stage, assets are formally incorporated into the economic system. Criminal organizations seek to invest in ventures that facilitate their activities. BLOCKBR will always operate within the terms and limits established by applicable legislation and regulations in force. Furthermore, BLOCKBR will operate transparently and adhere to ethical conduct standards, always observing the conduct and best practices established through this Policy.

6.2. Terrorism Financing Terrorism financing is related to a future action, not aiming to conceal illicit funds, but rather to gather funds of any nature (legal or illegal) to carry out terrorist acts.

7.1. DEFINITION

The KYC procedure aims to verify and understand the origin, constitution of assets, and financial resources of its customers, seeking to identify and monitor situations that may be considered suspicious or indicate any indications of money laundering or terrorism financing. Adequate knowledge of customer characteristics minimizes the risk of illicit capital entering and moving through BLOCKBR. In order to minimize such risks, the following procedures are adopted:

Individuals

Identification of tax regularity with the Brazilian Federal Revenue Service; Identification of credit status with credit bureaus (may or may not be subject to this analysis); Suitability profile identification; PEP identification; Identification of unfavorable news.

Legal Entities

Identification of tax regularity with the Brazilian Federal Revenue Service; Identification of credit status with credit bureaus (may or may not be subject to this analysis); Identification of the company's organizational structure.

7.2. PROCESS FOR PERFORMING PERSONAL VISITS

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

Research regarding negative media indicated points of concern; Incompatibility between declared income/investment; Investor PJ's corporate structure has overlapping partners in other companies.

7.3. CUSTOMER RISK LEVEL SCALE

In order to allow the analysis to accurately reflect the level of risk, in terms of AML/CTF, the KYC procedure establishes a 'Customer Risk Scale':

Low risk: customers without any indications or characteristics that may constitute indications of money laundering or place them in a position of susceptibility to 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 reported situations that place them in a situation of possible vulnerability to involvement in money laundering crimes, including those who present any of the characteristics listed in section 5.2 above individually or in conjunction with any other considered relevant by Compliance. High risk: customers who have personal, professional, or any other characteristics that place them in a highly susceptible position to involvement in money laundering offenses, including, but not limited to, individuals described in section 5.1 of this Policy and/or who present multiple characteristics among those described in section 5.2 above.

As reiterated throughout this Policy, it is the duty of all BLOCKBR employees to ensure compliance with the rules and guidelines presented here, taking steps to report any indications of non-compliance with the practices described herein to Compliance, in order to prevent BLOCKBR's digital wallets (“Wallets”), among other products, from being used by third parties and customers as a means of engaging in illegal or illicit activities.

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

that show a sudden and unjustified change in relation to the operational modalities usually used by the customer; with values inconsistent between the declared professional occupation and the declared financial situation; with a level of complexity and risk inconsistent with the technical qualification of the customer or its representative; with significant fluctuation in relation to the volume and/or frequency of transactions by any of the parties involved; with characteristics demonstrating continuous acting on behalf of third parties; that are carried out between the same parties or for the benefit of the same parties, where there are repeated gains or losses regarding any of those involved; and lacking economic foundation, carried out for the purpose of generating loss or gain.

The following practices may also be configured as indications of money laundering:

resistance to providing the necessary information for registration and account opening; declaration of multiple bank accounts and/or constant modification; and account opening and appointment of attorney without any apparent connection.

BLOCKBR employees who become aware of any of the above practices must report them to Compliance, respecting the duty of confidentiality and evaluation of the facts by Compliance.

After an investigation by Compliance into the reported facts, the occurrence may be archived if the materiality of any of the allegations made is not proven.

However, in the case of any of the indications listed above or upon receiving a report from an employee that requires a more thorough evaluation, Compliance may take certain actions to examine the situation, such as requesting an update to the registration, requesting clarification, and even suspending access to the BLOCKBR platform.

In the event of confirmation of the allegations with the proof of the materiality of the reported practices, a formal communication will be prepared for COAF, which must be previously evaluated and approved by Compliance.

It is the responsibility of BLOCKBR's Compliance to amend this Policy whenever necessary. This Policy comes into effect on the date of its approval and supersedes any documents to the contrary.