Money Laundering Prevention Policy

Objective

In accordance with the best market practices, through its Money Laundering Prevention Policy, Terrorism Financing and Concealment of Assets, Rights, and Values (PPTFCA) (“Policy” ), the principles and guidelines for risk management in its operations, in order to guide professionals on an efficient process of identifying and monitoring customers, establishing objectives and real responsibilities, at their various levels.

Practical Application

This PLD Policy is effective from the date of its approval. If, during the period, there is a change in the regulatory environment or in the Brazilian legislation, the PLD Policy must contemplate this change.

Policy Applicability

TFX, responsible for solutions for implementing payment methods via cryptocurrency through the companies “Coinbase” and “Coinpayments”, by establishing this Policy, seeks to prevent any illicit activities and protect the image of TFX before customers, partners, suppliers, regulators, and society. To this end, we adopt processes, and integrated systems, in addition to a corporate governance structure, in compliance with the best market practices.

Practical Concept of PPTFCA

In a very practical and conceptual way, the crime of money laundering is characterized by a set of commercial or financial operations that seek to hide, or conceal the origin, location, movement, or ownership of goods, rights, or amounts arising, directly or indirectly, from illicit activities.

In addition, the crime of corruption is constituted by means of an act harmful to the Public Administration in the act of promising, accepting, offering, or giving, directly or indirectly, an undue advantage of the public agent or the third person related to him.

The financing of terrorism is configured by structuring sources of financial resources (licit or illicit), moved in a hidden or disguised way, in order to allow terrorist groups to carry out their activities.