SAC (hereinafter referred to as the “Company”), is regulated by Superintendence of Public Registries (SUNARP). The Company is committed to the highest standards of Anti-Money Laundering (AML) compliance and Counter-Terrorism Financing (CTF). The Companys AML policy is designed to prevent money laundering activities and the Company is committed to the following:

1. Continuously monitoring client and third party transactions to ensure conformity with our protocols.

2. Creating and maintaining records on accounts, transactions, communications with clients and designated third parties, internal corporate matters and specific procedures.

3. Managing our exposure to money laundering risks while dealing with clients and designated third parties.

4. Applying enhanced risk protocols in case of dealing with individuals and entities whose profiles fall outside the norm, politically exposed persons, clients from non-reputable jurisdictions and similar instances of risk exposure.

5. Regular AML training for all staff, especially for those who deal directly with our clients.

6. Reporting all suspicious activity to the Superintendence of Public Registries (SUNARP).

7. Monitoring changes to relevant legislation, following relevant guidance and adopting new measures when called for

Money laundering – the process of converting funds received from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that look legitimate to hide or distort the true source of funds. The Companys overarching policy is to prevent any action that seeks to convert funds derived from criminal activities. The Company does not accept or pay out physical cash and does not directly accept digital currency. The Company reserves the right to suspend any client operation that the staff suspects may be related to money laundering.

Know Your Customer and Due Diligence

The Companys AML and KYC policies require all potential clients to complete the Companys verification procedure. Before the Company establishes a business relationship with a client, the Company will ensure satisfactory evidence of the identity of any customer or counterparty is received. The Company also applies heightened scrutiny to residents of countries identified by credible sources as having inadequate AML standards; to clients from countries that may otherwise represent a high risk for crime and corruption and to beneficial owners who reside in and or whose funds are sourced from such high risk countries.

Monitoring of client activity

In addition to gathering information from the clients, the Company monitors client activity to identify and prevent suspicious transactions that appear to be inconsistent with the clients legitimate business or the clients transaction history.

Record keeping

Records of all transactions and data obtained for the purpose of identification, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports, documentation of AML account monitoring, etc.) are retained for a minimum of 5 years after the account is closed.

Measures taken

In cases of an attempt to execute transactions which the Company suspects are related to money laundering or other criminal activity will be reported to Superintendence of Public Registries (SUNARP) in accordance with the applicable law. The Company reserves the right to suspend client activity if, in the opinion of staff, any transaction undertaken by a client is suspicious.

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