Policy for Preventing and Combating Money Laundering, the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction – AML/CFT

Introduction

Money laundering and terrorist financing are constantly referred to in the same context. However, these crimes are distinct, and the main difference lies in the origin of the funds.

Terrorist financing uses funds for an illegal purpose, but the resources are not necessarily illicit. On the other hand, money laundering is disguising the proceeds of illicit activities to appear legitimate. 

Despite this conceptual difference, from a technical perspective, the methods of money laundering and terrorism financing are similar. 

Although it might seem logical that funds from legitimate sources wouldn’t need to be laundered, terrorist groups do need to disguise the connection between themselves and their legitimate funding sources. To do this, these terrorists use methods similar to those of criminal organisations in the process of money laundering. They engage in activities such as structuring, purchasing financial products, making bank transfers (redemptions and deposits), using credit or debit cards, taking out loans, and receiving donations.

The crime takes place in a very dynamic way and basically through three (3) phases:

• Placement – With the illicit resources, the criminal first attempts to distance them from their true origin. At this stage, the possibility of associating the illegal financial assets with the crime is still high.

• Layering – This second stage is characterised by the criminal’s attempt to make it difficult to trace the illicit funds by concealing their origin and carrying out multiple transactions in various institutions in Brazil and other countries. And

• Integration – In this final stage, the offender begins integrating illegal assets into the economic system. At the end of this phase, the resources start to appear legitimate.

WEpayments (“WE”) knows its duties and responsibilities and believes it must fully cooperate with all government bodies. 

Our focus on preventing these criminal practices must address two crucial points.

• Preventing criminals from continuing their illegal activities, and
• Maintain WE’s image and reputation with its clients, potential clients, staff members, regulatory bodies, and society.

Based on this, the Combating Money Laundering and the Financing of Terrorism & Proliferation (“AML/CFT”) (the “Policy”) was developed to raise everyone’s awareness of the relevant aspects of this critical issue and, most importantly, to establish the rules and guidelines for conducting our activities.

A series of controls, processes and measures should be followed to avoid our direct or indirect involvement in the illicit activities of “money laundering” or terrorist financing. 

If you have doubts about the subject or become aware of facts that lead to an assumption that a client, another staff member, third party or transaction is involved in illicit practices, you should immediately report it to the Compliance department. The Compliance department will take the appropriate measures and, if applicable, report it to the competent authorities.

We want to emphasise that, according to current laws and regulations and for this policy, anyone who engages in the activities listed below, whether through bad faith, negligence, or willful blindness, will be considered involved in illegal activities.:

• Assisting or attempting to assist the criminal in any way to achieve their illegal objectives
• Entering into transactions with clients who provide inadequate, incomplete, fraudulent or misleading information
• Failing to report their suspicions to the Compliance department immediately
• Revealing to the “suspect” that they are the subject of an analysis report or criminal investigation

Remember, we all play a fundamental role in preventing and combating money laundering and terrorist financing. 

Scope

This Policy applies to all WePayments staff, business partners, and third-party service providers.

Purpose

Within the objectives of this Policy, the following stand out:

• To raise awareness and help disseminate the corporate culture of AML/CFT
• Clarify the main concepts on the subject
• Serve as a technical basis for consultation and internal training
• Define criteria for identifying, recording and reporting unusual or suspicious transactions regarding the parties involved, the economic basis, how they were conducted and the instruments used, and
• Define limits, rules, procedures, roles, and responsibilities, including, among others, those relating to four essential AML/CFT processes: KYC (Know Your Customer), KYP (Know Your Partner), KYS (Know Your Supplier), and KYE (Know Your Employee)

Furthermore, we must emphasise the need to observe various controls, processes, and measures to avoid direct or indirect involvement in money laundering or terrorist financing.

Current and future actions must always be taken based on at least the four (4) basic principles of WE’s activities in the AML/CFT area, namely:

• Comply with the law: always conduct our business and activities following high ethical standards, ensure that laws and regulations are followed, and do not supply products or provide services when there are good reasons to suspect that the transactions are associated with money laundering or terrorist financing activities.

• Know your Customer (KYC); Know your Employee (KYE); Know your Partner (KYP); Know your Supplier (KYS): make every reasonable effort to obtain information that allows us to draw up a profile, evaluate and detect unusual or suspicious situations through rigorous registration, identification and relationship criteria with business partners, suppliers, staff members and, above all, our clients.

• Cooperate with regulatory and supervisory bodies: fully cooperate by adopting adequate control mechanisms, reporting suspicious or unusual operations, and establishing competent and independent operational areas with primary AML/CFT roles; and
• Policies, procedures, internal controls, and training: Adopt policies, procedures, and controls consistent with the principles outlined in this Policy. All staff members must be adequately informed and trained, particularly in recognising unusual situations, understanding clients, maintaining documentation, and reporting suspicious or illicit transactions.

Applicable legislation

All individuals subject to this Policy must adhere to the following laws and regulations (collectively Applicable Law):

• Law No. 9.613/1998: provides for money laundering crimes and the prevention of using the financial system for the illicit acts outlined in this law.
• Law No. 12.865/2013: provides for the Payment Arrangements and Payment Institutions integrating the Brazilian Payment System (SPB).
• Law No. 13.260/2016: regulates Terrorist Financing.
• Law No. 13.810/2019: provides for enforcing sanctions imposed by United Nations Security Council resolutions.

• COAF RESOLUTION No. 29/2017: provides for the procedures to be observed by persons regulated by COAF.
• BCB RESOLUTION No. 44/2020: establishes procedures for implementing the measures determined by Law No. 13.810/2019.
• RESOLUÇÃO BCB Nº 1/2020: creates the PIX payment arrangement and approves its Regulation.

• RESOLUÇÃO BCB N° 80/2021: establishes the requirements and procedures for the creation, operation, and request for authorisation of Payment Institutions and provides for the payment services by other institutions authorised to operate by Bacen.
• JOINT RESOLUTION Nº01/2020: provides for implementing the Open Banking System.
• BACEN CIRCULAR Nº 3.978/2020: provides for the policy, procedures, and internal controls adopted by institutions authorised to function by Bacen and aims to prevent using the financial system for money laundering and the financing of terrorism.
• BACEN CIRCULAR LETTER Nº 4.001/2020: discloses the list of operations and situations that may indicate signs of money laundering and the financing of terrorism, subject to communication to COAF.

The laws and regulations are referred to as examples. They include only the guidelines in force when this Policy was prepared, and neither cover all the legislation applicable to WePayOut activities.

Main concepts

• Money Laundering: A criminal activity wherein the proceeds of illegal activities such as financial resources, goods, or assets are concealed to make them appear legitimate.
• Terrorist Financing: It provides funds or other financial resources to organisations, groups, or individuals involved in terrorist activities.
• End beneficiary: A natural person who ultimately, directly, or indirectly, owns, controls or significantly influences a legal entity.
• Politically exposed person (PEP): A person who is or has been entrusted with a prominent national or foreign political or public position, family members, and close associates. The condition of the politically exposed person must be applied for the following five (5) years from the date the person no longer fulfils the categories set out in the Standard.
• Business partner: A legal entity that has commercial agreements with WePayments.
• Third-party service providers: Natural or legal persons under contract to provide goods or services to WePayment.
• COAF: The Council for Financial Activities Controls (COAF) is the Brazilian Financial Intelligence Unit. It is the system’s primary authority for preventing and combating money laundering, the financing of terrorism, and the proliferation of weapons of mass destruction (AML/CFT), especially in receiving, analysing and disseminating financial intelligence information.

WEpayments context

As a payment institution, in its capacity as an electronic money provider (IP EME) and transaction initiator (IP ITP), WePayments implemented control mechanisms according to BCB Circular No. 3,978/20, as amended, BCB Circular Letter No. 4,001/20, and Laws Nos. 9,613/1998, 13,260/2016, and 13,810/2019.

As an IP EME, WePayments manages and safeguards clients’ financial resources held by commercial partners to facilitate the receipt and payment of funds.

As an IP ITP, WePayments processes instructed payment transactions from customer accounts without managing or holding funds.

The mais prevention methods

Know your client – KYC

The primary purpose of the KYC process is to gather information, draw up our clients’ profiles, monitor their transactions, and identify and mitigate abnormal or unusual situations or those that show signs of being directly or indirectly related to money laundering or terrorist financing offences.

Knowing clients, final beneficiaries, proxies, and legal representatives is a requirement of regulatory and supervisory bodies for AML/CFT procedures. Considering the related legal and image risks, it is crucial that the entire process of knowing the client is finalised before carrying out any operation. Regardless of the client identification mechanisms adopted, the knowledge process must also be maintained throughout the relationship with WE through tests, information updates, visits, telephone contacts, etc.

Due to the complexity and importance of the KYC process, WE has a Know Your Client/Merchant (KYC) Procedures Manual. Therefore, we recommend that you consult this document for detailed guidelines and rules regarding this process.

Know Your Employee – KYE

The KYE process essentially involves setting hiring criteria and monitoring staff members’ behaviour and conduct.

As for the measures to be adopted, we would emphasise:

• Ensuring that all staff members are aware of and adhere to the rules, guidelines and training
• Implementing a policy containing strict criteria and procedures for selecting and evaluating staff members
• Follow-up and monitoring of staff members’ behaviour and conduct
• Training and improvement of staff members on ethics and prevention of illicit money laundering, terrorist financing, corruption and fraud in general
• Careful assessment of staff member transfers between company areas and terminations.

Due to the complexity and importance of the KYE process, WE has internal policies and guidelines on the subject. These include criteria for monitoring the economic and financial situation of our staff. These policies are only accessible to authorised staff members.

Know your business partner – KYP

Establish criteria for hiring, accepting or maintaining business partners, according to the relationship’s profile and purpose, to prevent money laundering risks.

Main measures required to apply the Know Your Partner procedure:

• Defining the relevant business partner profile
• Monitoring contracts, relationships and contract terminations
• Analysing and monitoring the relevant business partner profile
• Research into economic, financial and reputational history
• Updating of records
• EDD (Enhanced Due Diligence) processes and
• Drawing up and maintaining watch and impediment lists

 Know Your Supplier – KYS

It establishes rules, procedures and controls for identifying and accepting suppliers and service providers, preventing hiring unsuitable companies or those suspected of involvement in illicit activities. 

• Screening suppliers before contracting
• Monitoring contracting, rendering of services, relationships and contract terminations with the supplier
• Adopting and monitoring specific approval levels
• Monitoring completed payments
• EDD (Enhanced Due Diligence) processes

Roles and responsabilities

WE’s Compliance department operates with an independent and specific AML/CFT structure. This structure is designed to recognise, prevent, detect, analyse, and, when necessary, report suspicious transactions and individuals to the appropriate authorities. The procedures are in line with Brazilian law and adhere to the best market practices.

However, as already mentioned, the Compliance department will never succeed alone. The adopted measures will only be successful if everyone is committed and works together. 

As for internal responsibilities relating to AML/CFT, we would like to highlight the following:

Executive Board

• Approval of the AML/CFT Policy
• Be aware of the internal risk assessment and effectiveness assessment
• Be aware of the action plan regarding the Effectiveness Report when applicable
• Disseminate the internal culture and AML/CFT guidelines in all operating area
• Reporting any unusual or suspicious activity or transaction to the Compliance department 

Director in charge of AML/CFT

• Implement the AML/CFT structure
• Document and approve the internal risk assessment
• Approve the procedures for understanding the client, staff, business partners and third-party service providers
• Approve the monitoring, selecting and screening procedures for suspicious operations and situations
• Approve the Effectiveness Assessment
• Ensure that the payment institution’s staff is adequately trained and aware of the AML/CFT obligations
• Deciding on filing or reporting any suspicious transactions to Coaf 
• Ensure that WePayments is fully compliant with regulatory standards

AML/CFT Subcommittee

The subcommittee has no set periodicity; it meets on demand, and deliberations occur electronically (e-mail).

This panel comprises the CEO, the AML/CFT Director and the CTO.

Its purpose is to deliberate on approving clients classified as high-risk.

AML/CFT Department

• To draft, implement and maintain policies, procedures and internal controls related to AML/CFT, ensuring alignment with the Central Bank of Brazil regulations
• Promote the AML/CFT culture among staff, business partners and outsourced service providers
• Promotes actions to raise awareness regarding AML/CFT
• Ensure that the institution adequately verifies clients’ identity and due diligence, including gathering information on the origin of funds and the purpose of transactions
• Regularly assess risks related to money laundering and the financing of  terrorism
• Monitor transactions to identify suspicious or unusual activity and conduct in-depth analysis when necessary
• As regulations require, identify and report suspicious operations or activities to COAF and other competent authorities
• Perform due diligence on suppliers and business partners to ensure compliance with AML/CFT regulations
• Prepare the Annual Declaration of Non-Communication – DAAC, if applicable, under current regulations
• Continuous monitoring of databases and media
• In collaboration with the Legal Department, drafting technically based opinions on specific issues related to legislation on the subject
• Further analyse whether the information on the suspects is current and gather any information from commercial areas. They should provide information and documents to verify if there are any indications of money laundering and the financing of terrorism that need to be reported.
• Updating and monitoring lists of suspicious names, companies, countries, and activities, or those with a higher image risk, money laundering, and terrorist financing.
• Developing regulatory reports.

Legal Department

• Prepare opinions on cases classified as high-risk
• Work with the Compliance department when dealing with regulatory bodies
• Actively participate with the Compliance department in the understanding and applicability of AML/CFT and Proliferation legal requirement
• Jointly with the Compliance department, prepare technically based opinions on specific issues related to the legislation in question
• Preparing responses to any demands from regulatory bodies, with the support of the Compliance department

Internal Controls Department

• Identify and assess WePayments’ operational and compliance risks and design, implement and monitor internal controls to mitigate identified risks
• Regularly testing the AML/CFT department’s procedure

Human Resources Department (People Management)

• Assist the Compliance department in communicating and coordinating training related to AML/CFT
• Coordinate adherence to policies and participation lists at training sessions
• Collaborating in the Know Your Employee process

Operations Department

• Provide support, when necessary, to understand operations assessed by the AML/CFT department

Commercial Department

• Apply the Know Your Client procedures, fully identifying clients by obtaining all mandatory registration documentation (and subsequent updates), as well as through close commercial relations, contacts and periodic visits, where applicable
• Respond to and justify the AML/CFT department’s monitoring demands regarding its clients
• Communicate any suspicious behaviour, unusual proposals, or procedures causing concern to the Compliance department
• Alert the Compliance department about any doubts or suspicions regarding the information provided in the client records

Risk and Fraud Management 

• Apply strict preventive and tracking controls to manage fraud risks in WE’s businesses
• Compliance with regulatory requirements for client registration and documentation.
• Keeping updated client records, as well as powers of attorney

Information Technology (IT)

• Assist in the development/ procurement of AML/CFT software and tools, as specified by the Compliance department.

 AML/CFT procedures

Internal risk assessment

The internal risk assessment identifies and measures the risks associated with using products and services for crimes set out in this Policy. It must be documented, approved by the AML/CFT  department and sent to senior management.

The internal risk assessment analyses: (i) WePayments and its business model and geographical area of operation; (ii) customers; (iii) operations, transactions, products and services offered, covering all distribution channels and the use of new technologies; and (iv) the activities performed by staff, business partners and third-party service providers.

The risk analysis determines risk categories to enable more robust management and mitigation controls for high-risk situations and more straightforward controls for low-risk ones. 

The internal risk assessment must be reviewed every two years or when significant changes occur in the risk profiles that support it. The operating procedures described in the specific manuals highlight these situations.

Risk-based Approach (RBA)

WePayments adopts a risk-based approach defined by verifying the identified risk classification. This ensures that the measures adopted to prevent or mitigate money laundering and combat the financing of terrorism are proportionate to the risks identified in accepting, monitoring, and maintaining the relationship.

Metric to define client risks

Client RBA comprises the following criteria:

• Type of transaction
• Risk segment (restrictive, impeding)
• KYC Form Answers

Systemic Analysis

The definition of customer risks is also assessed with external searches using:

• Criminal proceedings
• Social environmental and climate cases
• Labour lawsuits
• Discrediting media
• Restrictive lists

If the client is included in the abovementioned items, their risk rating automatically rises to high.

Responsibility and frequency

The client categorisation using the ABR results in the following approval levels.:

• Low risk: Approval by the AML/CFT Director
• Medium risk: Approval by the AML/CFT Director
• High risk: Assessment by the AML/CFT, Legal and Customer Experience (CX) departments + Approval via subcommittee

Each risk level has a specific updating frequency. The customer risk reassessment process consists of reassessing a new KYC form and generating a new dossier with the analysis related to the abovementioned parameters. The stipulated frequency is: 

• Low risk: 24 months
• Medium risk: 18 months
• High risk: 12 months – except for clients in the gambling industry

Product and service analysis

WePayments has a procedure for approving new products and services, including using new technologies to offer them or existing products and services.

The AML/CFT department participates in the deliberations to mitigate the regulatory risks of new products and services potentially being used to commit money laundering or terrorist financing offences.

Effectiveness Assessment

Evaluating effectiveness is fundamental to ensuring that Combating Money Laundering and the Financing of Terrorism measures are effective.

WePayments annually assesses the effectiveness of the policy, procedures and internal controls under Circular BCB No. 3,978/20. 

The result of this assessment is documented in a specific report that includes a) the methodology adopted in the effectiveness assessment, b) the tests applied, c) the qualification of the evaluators, and d) the deficiencies identified. This document is sent to the board of directors for information by 31 March of the following calendar year.

If any deficiencies are identified in this report, the AML/CFT department will create action plans to address the issues. These plans will be documented in a follow-up report and sent to WePayments’ board of directors no later than 30 June of the following calendar year.

Training

Awareness-raising, refresher and training sessions on the issues outlined here will be held for staff members, partners and outsourced service providers.

These training sessions will be organised by the People Management department and conducted by the Compliance department.

Wepayments staff members can be trained annually online or in person or receive educational booklets.

Finally, in some cases, knowledge tests will be implemented to assess everyone’s understanding of the topics and internal policies under the annual acculturation schedule.

Financial, legal, reputational, and social and environmental impacts

WEpayments evaluates its risks according to the risk approach of the Central Bank of Brazil (Bacen). Risks are categorised as low, medium, or high based on their likelihood of occurrence and the potential financial, legal, reputational, social, and environmental impacts on the institution. To accomplish this, the following criteria are taken into consideration:

Probability of Occurrence

• Historical Analysis: an examination of past events to identify patterns
• Internal Controls: evaluation of the effectiveness of policies and procedures
• Segment Monitoring: monitoring changes in the payment landscape
• External Environment Analysis: consideration of external factors  

Impact Magnitude

• Financial Impact: assessment of the impact on finances considering losses and cost
• Legal Analysis: an examination of the legal and regulatory implications
• Reputation: evaluation of the impact on WEpayments’ reputation
• Social and Environmental Responsibility: Consideration of social and environmental impacts

By incorporating these criteria into its risk management approach, WEpayments can identify, assess and mitigate the risks related to its segment. 

The above matrix’s risks define the actions for each identified case. In summary:

• Reduced: Refers to events with minimal impacts for WEpayments, characterised by practically zero risk. In this case, conducting in-depth investigations or undertaking significant treatment efforts is unnecessary.
• Moderate: This scenario involves significant impacts that may entail notable risks for WEpayments. It is crucial to take action to prevent these impacts from worsening.
• Critical: This Indicates severe impacts on WEpayments, which could jeopardise its operations. Thus, immediate action is crucial to mitigate these impacts.

It is crucial to emphasise that all stakeholders (customers, staff, partners, suppliers) undergo initial due diligence when establishing the relationship. This results in assigning a RBA (risk-based approach) rating.

Qualification, verification and validation

WePayments has specific manuals for qualifying, verifying and validating identification information, ensuring compliance with regulations and requiring board approval.

During the qualification process, information is verified and validated based on the risk profile of the customer, staff member, business partner, or service provider and the nature of the business relationship. 

Reporting suspicious operations – COAF

WE may encounter suspicious or unusual transactions or situations during our activities and relationships with clients. However, recognising them is a complex task.

Such suspicious or unusual activities can be detected through:

• Contact with clients through meetings, telephone, e-mail, etc.
• Information obtained through insider knowledge: databases, documents, personal, professional or financial issues
• External information: political and social issues, newspapers, magazines, television, internet, networking, etc.
• Internal analyses and monitoring of clients and transactions.

The following list is not exhaustive and is intended to exemplify some suspicious or unusual situations related to operations and clients within the scope of WE’s activities:

• Unusual movement of funds or amounts
• Transactions involving amounts higher than the limits established in laws and regulations or lower amounts constitute a ploy to circumvent said limits due to their regularity and form. 
• Transactions involving the same person, financial conglomerate or group in the same calendar month that exceed the value of R$10,000.00 (ten thousand reais) per institution or entity as a whole

• A client’s reluctance to establish contact with WE or provide the required information and documents for opening an account, formalising a contract, or completing transactions
• Presenting or providing false information or information that is difficult or costly to verify 
• Transactions made or services provided, regardless of their value, to individuals known to have committed or attempted to commit terrorist acts or to have been involved in or facilitated such acts, as well as the presence of assets owned or controlled, directly or indirectly, by these individuals.
• Suspected acts of terrorist financing
• Transactions made near borders without reasonable cause
• Funds movements inconsistent with the client’s assets, economic activity, or professional occupation and presumed financial capacity        
• Consistently acting on behalf of third parties or without revealing the true identity of the final beneficiary 
• Any attempts at bribery or excessive gifts
• Acting in a way that discourages a WE staff member from reporting specific operations
• Withdrawals, transfers or deposits of significant or unusual amounts 
• Opening and operating an account with a power of attorney or any other type of authorisation
• Frequent requests to increase limits for transactions 
• Sudden and unjustified changes in the types of transactions used  
• Clients who have banking accounts at a bank branch situated in an international passenger station (such as an airport, bus station or port) or tourist attraction, unless they are the owner, partner, or staff member of a legally established company at that location.
• Proposals to initiate relationships and operations with politically exposed persons
• Evidence of bypassing of the procedures for identifying and recording transactions in general 
• Clients and transactions in which it is impossible to identify the final beneficiary 
• Situations in which it is impossible to keep client records up to date
• Transactions or proposals that exhibit specific characteristics, such as the parties involved, amounts, methods of execution, and instruments used, or which, due to their lack of economic or legal basis, suggest a risk of involvement in the crimes specified in Law 9.613/98, or related offences.

We emphasise that the above examples are not exhaustive and are intended to help our staff identify suspicious, unusual or illicit situations.

WE has adopted procedures and mechanisms to report suspicious situations to the relevant authorities. When staff members encounter such situations, they must promptly report the case to the Compliance department for analysis and action, as outlined in ANNEX I of this Policy. The Compliance department is the only department authorised by the Board of Directors to handle these communications.

Regarding these communications, it is the Compliance department’s responsibility to:

• Call the AMLCFT Committee to discuss the communications to be made
• Once the need for communication has been identified, it must be carried out within twenty-four (24) working hours as per the guidelines defined by the Central Bank of Brazil
• Provide an annual declaration through SISCOAF, attesting to the non-occurrence of reportable transactions under Circular 3.978/2020 and Law 9.613/98 ten (10) days after the end of the calendar year
• Ensure that communications are submitted by the deadlines and in the forms specified in Circular 3.978/2020.

It’s important to emphasise that everyone should pay particular attention and never inform a client, staff member, or third party if they are aware that the client or any operation carried out has been reported or is under investigation for suspected involvement in money laundering, terrorist financing, corruption, or fraud in general.

Assessments of clientes on UNSC lists

WEpayments monitors asset deprivation orders resulting from UNSC resolutions or the designations of its sanctions committees through the lists on external tools, per the website: http://www.un.org/securityconcil/

WEpayments will follow these procedures if any case of unavailability of assets of individuals, legal entities, or organisations is identified (prohibition to transfer, convert, move, make assets available, or dispose of them, directly or indirectly):

• block the identified case
• inform senior management and block the case
• inform the Central Bank of Brazil, the Prosecutor’s Office and any other competent body regarding those investigated or accused of terrorism who appear on the UN sanctions lists
• ensure that the assets are kept under review to enable them to be made unavailable
• immediately follow the measures established in the UNSC resolutions in the case of communication via the Central Bank of Brazil’s Mail system and addressed explicitly to the Deati/UNSC folder
• all communications to the Ministry of Justice and Public Security (MJSP) must be addressed to the institutional e-mail address csnu@mj.gov.br

Monitoring information to comply with the unavailability determinations includes adding or removing (de-listing and unfreezing) individuals, organisations, or assets from lists affected by sanctions or determinations made by the CSNU or its sanctions committees. This will be done based on the periodicity of the external tools contracted by WEPayments and detailed in the Know Your Client/Merchant (KYC) Procedures Manual.

Information confidentiality

Any information related to operations that could potentially be characterised as money laundering, financing of terrorism and illicit acts of the exact nature is confidential and will not, under any circumstances, be made available to third parties other than the bodies responsible for analysing and investigating possible crimes, always complying with the applicable legislation.

Document safekeeping

Documents relating to operations, services, and procedures designed to know your client, staff members, business partners, and service providers and the decisions on whether to report them to COAF are stored for at least ten (10) years. The deadlines are calculated as follows: (i) from the first day of the year following the end of the relationship with the customer; (ii) from the date the relationship with customers, staff members, business partners and service providers ends, and (iii) from the first day of the following year after the operation was completed and the service was hired.

Disciplinary procedures and penalties

Specific administrative penalties for violations or failure to comply with the guidelines may be enforced.

Non-compliance or negligence related to the rules set out in this Policy will be considered a serious or grave offence, as outlined in our Code of Ethics and Conduct.

In criminal law, involvement in money laundering is considered a grave offence with severe sanctions and penalties. Below are some examples:

1. warning
2. fine not exceeding: (i) twice the amount of the transaction; (ii) twice the actual profit obtained or presumably obtained by completing the transaction; or (iii) R$ 20,000,000.00 (twenty million reais) 
3. temporary disqualification for up to ten (10) years, and
4. annulment or suspension of the authorisation to do business, operate or function.

Final considerations

All must certify that they have read and fully understood this document and any future amendments.

The Compliance department should always be consulted in cases of doubt or uncertainty about the content of this Policy or its application regarding any specific matter.