Anti-Money Laundering (AML) Policy

General Objective

This policy aims to align Trader Money’s operations with applicable anti-money laundering (AML) legislation, ensuring the operational and legal integrity of the company.

Scope and Responsibility

This policy applies to all interns, employees, service providers, consultants, partners, and any agent connected to Trader Money. All are expected to follow the established guidelines for customer identification and registration, as well as to adopt recommended practices for the prevention and detection of money laundering, as defined by applicable laws, regulations, and this policy.

Definition and Concept of the Offense

Money laundering is defined as the process of converting capital obtained through illicit activities into apparently legal funds. This policy covers the definition of the crime, its stages, and indicators of individuals and products that may be susceptible to involvement in such crimes.

Monitoring and Control Structure

Detailed descriptions of activities considered suspicious will be cataloged, and control methods adopted by Trader Money will be specified, including practices for the effective implementation of “Know Your Customer” (KYC) procedures. All identified indications of money laundering must be immediately reported to the Internal Control and Compliance Department, responsible for investigating reports and communicating with regulatory bodies when necessary.

Applicable Legislation

Trader Money’s activities are guided by current regulations governing anti-money laundering, including:

• Law No. 9.613/98, its amendments, and regulations issued by COAF;
• Regulations from the Brazilian Securities Commission (CVM) and the Central Bank of Brazil (BACEN) applicable to AML prevention and enforcement.

Customer Registration and Due Diligence

The “Know Your Customer” (KYC) practice is essential to preventing and combating money laundering, requiring a strict and updated registration process for both individuals and legal entities. Special attention must be given to clients classified as “politically exposed persons” and those identified as high-risk, according to criteria established by regulation and Trader Money’s internal policy.

Reporting Suspicious Clients and Transactions

Any employee who identifies suspicious activity must report it to the Compliance Department, which will handle the matter with confidentiality and conduct the necessary investigations.

Management of Indicators and Alerts

Trader Money’s monitoring system will generate alerts for unusual transactions or behaviors, which will be carefully analyzed by Compliance. Depending on the case, measures may include updating customer records, requesting additional clarifications, or even formally reporting to regulatory bodies.

Organizational Commitment

Trader Money is committed to maintaining and regularly updating this policy, ensuring its effectiveness and compliance with applicable laws. All stakeholders are encouraged to fully cooperate with anti-money laundering initiatives.