Anti-Money Laundering (AML) Prevention

Policy Manual for the Prevention of Money Laundering and Terrorism Financing Crimes

Purpose of the Policy

This document is permanent, aligned with 4P Finance's Risk and Compliance (R&C) standards and the provisions of Law No. 9,613/1998, which defines the crime of money laundering or asset concealment, establishing measures for financial system entities; amended by Law No. 12,683/2012, and including the following regulations: Central Bank Circulars No. 3,978/20, 4,001/20, 3,461/09; Securities Commission Instructions No. 301/99, 617/19; COAF regulations; CGU Integrity Manuals; FATF Recommendations; IOSCO Guidelines for Cryptoasset Trading Platforms.

Scope of the Policy

4P Finance's AML responsibilities apply to all employees, partners, directors, and affiliates, directly or indirectly connected.

Policy Requirements

I. Introduction and Objectives

Money laundering involves operations aimed at inserting illicitly obtained funds into the economy, through three stages: Placement, Layering, and Integration.

Placement

Funds enter the financial system through deposits, purchases, or complex splitting techniques.

Layering

Funds are moved to disguise their origin, using anonymous accounts and countries with banking secrecy.

Integration

Assets are formally incorporated into the economy via investments in businesses or services.

The Brazilian Money Laundering Law (No. 9,613/98, amended by No. 12,683/12) criminalizes concealing the origin of funds, punishable by 3 to 10 years in prison and fines.

Guidelines, Responsibilities, and Target Audience

Policy Application

4P Finance adopts KYC procedures. Transfers are only accepted from accounts matching the registered CPF or CNPJ. Only PIX transactions are allowed.

Suspicious Case Reporting

Suspicious activities must be registered and reported to 4P Finance's legal advisors.

Risk-Based System

Users' operations are categorized into green, yellow, and red flags according to risk level.

Procedures

Users must provide documents according to their risk level for platform access.

Transaction Records

All transactions are recorded and may be shared with authorities if required.

Periodic Assessment

This policy undergoes periodic reviews to maintain effectiveness.

Prevention Programs and Training

All employees receive periodic training on AML policies.

Validity and Modification

This policy is effective upon approval and may be updated at any time by the Compliance Committee.