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Compliance policy

INTRODUCTION

This Money Laundering Prevention and Combat Policy (“Policy”) aims to promote the adequacy of 488ex’s operational activities with the rules pertaining to the crime of money laundering.
We adopt the best practices in customer registration and pay special attention to concepts and activities that help prevent and combat money laundering. The laws and regulations related to this crime, as well as the rules of this Compliance Policy must be complied with.
The Compliance Policy will identify the concept of money laundering, the steps that configure the crime and the characteristics of people and products susceptible to involvement with this crime. In addition, money laundering operations will be typified, the controls used will be identified and the rules for the application of the “Know your customer” forms will be defined.
The knowledge of any indication of money laundering will, if applicable, be communicated to the competent bodies.

1. CONCEPTS

1.1 DEFINITION
The term “money laundering” consists of the conduct of commercial or financial operations with the purpose of incorporating resources, goods and services obtained illicitly.
1.2 STAGES OF THE CRIME OF MONEY LAUNDERING
The money laundering process involves three steps: placement, concealment and integration.
Placement is the stage in which the criminal introduces illegally obtained money into the economic system through deposits, purchase of negotiable instruments or purchase of goods. It deals with the removal of the money from the place that was illegally acquired and its inclusion, for example, in the financial market.
Concealment is the moment when the perpetrator carries out transactions that are suspicious and that characterize the crime of laundering. At this stage, several complex transactions are configured to disassociate the illegal source of the money.
In the integration the illegal resource definitely integrates the economic and financial system. From this moment on, the money is given a legal appearance.

2. REGULATORY STANDARDS

Among the main disciplinary rules of the financial market with respect to prevention and
fights money laundering, it’s worth mentioning:
– Law No. 9613/98 – Provides on the crimes of “laundering” or concealment of property, rights and values; the
prevention of the use of the financial system for the respective illicit ones and creates the COAF – Council of
Control of Financial Activities;
– CVM Instruction No. 1.888/99 – Provides on identification, registration, operations, the
communication, the limits and administrative liability in respect of the crimes of laundering or
concealment of assets, rights and values;
– BACEN Circular Letter No. 2826/98 – Discloses list of operations and situations that may configure
evidence of the crime of money laundering, and establishes procedures for its
communication to the Central Bank of Brazil;
– BACEN Circular No. 3461/09- Provides on the procedures to be adopted in prevention and
combating activities related to the crimes provided for in Law No. 9,613/98; and
– BACEN Circular Letter No. 3430/10- Clarifies aspects related to the prevention and combating of
activities related to the crimes provided for in Law No. 9,613 of March 3, 1998, dealt with in the
Circular No. 3461 of July 24, 2009.
– Rules issued by COAF – Financial Activities Control Board.
In 2012, Law No. 9,613 was amended by Law No. 12,683, which brought important advances in the prevention of fraud and other irregularities.
and fight money laundering, such as:
– The extinction of the list of previous crimes, now being admitted as a previous crime of the
money laundering any criminal infraction;
– the inclusion of early disposal and other insurance measures to ensure that
the goods do not depreciate or deteriorate;
– the inclusion of new obligated subjects such as notaries, professionals who carry out activities of
financial advice or consulting, representatives of athletes and artists, fairs, among others;
– Increase of the maximum fine to R$ 20 million.

3. AUTOMATED DATA CONTROL SYSTEM

We work with the most modern data auditing tools. We brought to Brazil
first fully audited platform by Kapersky, a benchmark in the industry. Our data can be
shared by any entity authorizes via API.
Our accounting system issues invoices for all transactions performed and also issues the respective
tax collection guide for our clients, facilitating compliance with CVM IN 1888,
by sending this information to the IRS every month.

4. POLITICALLY EXPOSED PERSONS

In accordance with CVM Instruction 463/08, COAF Resolution 16/07, Circular 3461/09 and Letter
Circular 3430/10 of the Bacen, we must pay special attention to politically exposed people.
Politically exposed people are considered those people who perform or have performed,
in the last 5 (five) years, positions, jobs or relevant public functions, in Brazil or in other countries,
foreign territories and dependencies, as well as their representatives, family members and other persons of their
close relationship.
In addition, they are examples of situations that characterize close relationships and lead to the
permanent client environment as a politically exposed person:
– Constitution of a politically exposed person as a prosecutor or prelate;
– Control, direct or indirect, corporate client by politically exposed person;
– Every client is required to declare himself/herself as a politically exposed person at the time of the
registration.
All politically exposed customers are defined by the system as high risk of
involvement with illicit activities associated with money laundering. The Compliance Policy analyzes data from
occurrence and, if applicable, requests the necessary clarifications from the responsible adviser or from the
client about his operations. If the evidence is consistent, I will be responsible for reporting to
regulatory bodies, respecting the operational flow as we will treat in this document.

5. SUSPICIOUS” PEOPLE

According to parameters applied in the financial market, people working in the tourism sectors,
games, air transport, insurance companies, exchange bureaus, distributors, factoring, among others, are
more susceptible to intentional involvement (or not) in money laundering crimes.
It should be noted that persons resident in border areas should also be identified as
of high susceptibility for participation in activities linked to money laundering.
Finally, “suspect” clients can be characterized as individuals or companies already
involved in a crime of laundering or received any kind of negative publicity. For the purpose of
control, Politica Compliance develops an internal list containing the data of people disclosed by
media or by regulatory agencies that have a direct or indirect relationship with the crime of laundering of
money.

6. KNOW YOUR CUSTOMER

The application of the “Know your customer” policy is another way used in prevention and
fighting the crime of money laundering. The identification of customer profiles and accurate information on
professional performance, branch of activity and the financial situation of the clients protect and keep away
possibility of administrative penalties or financial losses.

7. EVIDENCE OF MONEY LAUNDERING

In accordance with the above-mentioned regulations, it is of the utmost importance
the knowledge of the operations that constitute evidence of money laundering. Evidence of
money laundering, the operations:
– Whose values seem objectively incompatible with professional occupation and situation
declared financial asset;
– carried out between the same parties or for the benefit of the same parties, in which they have followed
gains or losses with respect to any of those involved;
– Evidence of significant oscillation in relation to the volume and/or frequency of business of any of the
parties involved;
– Whose characteristics and/or unfoldings show acting, in a contumacious way, on behalf of
third parties;
– that show a sudden and objectively unjustified change in the modalities
operations usually used by the person(s) involved;
– Realized with the purpose of generating loss or gain for which there is, objectively, no foundation
inexpensive; and
– Whose degree of complexity and risk appears incompatible with the client’s technical qualification or
of your representative.
The following practices can also be configured as evidence of money laundering:
– Create resistance in facilitating the necessary information for the account;
– To declare several bank accounts and/or modify them with habituality; and
– Open an account and authorize a proxy who has no apparent link.
All cases of suspected money laundering will be reported to the competent bodies, the Policy
Compliance will be responsible for respecting the confidentiality of the reporting and providing proper investigation of the
suits.

8. IDENTIFICATION AND TREATMENT OF EVIDENCE OF MONEY LAUNDERING

The Compliance Policy is responsible for the operations monitoring routines for
identification of evidence of money laundering. The routines aim to identify operations with recurrence of
counterparty, unjustified transfers, transactions with incompatibility of assets, not limited.
The money laundering prevention system will generate occurrences related to the operations of the
customers. A customer whose operations are atypical will be signaled by the system that will also inform others
information from this client such as:
– If he’s a politically exposed person;
– If he has made an atypical change of address or ownership of a bank account or proxy;
– If you reside/have an account/prosecutor in border locations.
Once the occurrence is generated, the Compliance Policy will analyze the customer further to
confirm or not the suspicion of evidence of money laundering. The analysis will consist of checking for
documents, movements and data confronted by the respective system.
There are several possible measures, among them: the requirement of cadastral update, a request for
clarifications to the client’s advisor, commercial or the client himself or the filing of the
occurrence. Each one will be processed according to the case in question.
If after the other analyses the suspicion is confirmed, such analyses and occurrences will be recorded in
system, in the client’s history and formal communication will be made to COAF.



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