Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Last updated: January 24, 2025.

1. Introduction

Bitron is committed to combating money laundering and terrorist financing in compliance with applicable laws and regulations, including Law No. 9,613/1998 (Brazil’s Money Laundering Law) and international standards such as the FATF/GAFI guidelines.

This policy establishes AML (Anti-Money Laundering) and KYC (Know Your Customer) procedures to ensure that our platform is used ethically and securely.

2. Objectives

• Preventing and detecting activities related to money laundering, terrorist financing and other illicit practices;
• Ensuring that only legitimate individuals and companies use Bitron’s services;
• Comply with legal regulations and collaborate with the competent authorities in investigations of suspicious activities.

3. KYC (Know Your Customer) process

3.1 Collection of User Information

All users wishing to use Bitron’s services must provide the following information:

For Individuals:

• Full name;
• CPF;
• Date of birth;
• Home address;
• E-mail and contact telephone number;
• Official photo ID (RG, CNH or passport);
• Selfie holding your ID card.

For Legal Entities:

• Company name and CNPJ;
• Company address;
• Full name, CPF number and identification document of partners/legal representatives;
• Updated articles of association or statutes;
• Proof of company address.

3.2 Identity verification

The documents and information provided by users will be verified by:

• Automated systems for identity validation;
• Manual procedures, where necessary, to guarantee the legitimacy of the data.

The user’s account will only be activated once the verification process has been completed.

4. Continuous Monitoring

4.1 Suspicious Transactions

Bitron continuously monitors all transactions carried out on the platform to identify suspicious activity, such as:

• Deposits or withdrawals of large or unusual amounts;
• Transfers to portfolios or accounts linked to high-risk jurisdictions;
• Attempts to circumvent the limits set by the platform.

4.2 Transaction Limits

Bitron sets daily and monthly limits for user transactions, based on their verification level. Requests to increase the limit are subject to further analysis.

4.3 Suspicious Activity Reports (SARs)

Suspicious activities will be reported to the competent authorities, such as COAF (Conselho de Controle de Atividades Financeiras), as required by Brazilian law.

5. Compliance Policy

5.1 Employee training

All Bitron employees receive regular training on AML and KYC, including:

• Identifying suspicious activity;
• Escalation procedures for internal investigations;
• Updates on regulatory changes.

5.2 Internal audits

Periodic audits are carried out to assess the effectiveness of AML and KYC policies and ensure compliance with applicable regulations.

6. Data Retention Policy

Bitron stores the information and documents provided by users for a minimum period of 5 years, as required by law, even after the account has been closed. The data is stored securely and only accessible by authorized personnel.

7. Penalties and Suspension of Accounts

Bitron reserves the right to:

• Suspend or close accounts that do not meet KYC requirements;
• Block transactions considered suspicious;
• Informing the competent authorities of potentially illegal activities.

8. Compliance with Sanctions

Bitron does not allow the use of its services by individuals or entities included on economic sanctions lists, such as those issued by the UN, OFAC (Office of Foreign Assets Control) or other authorities.

9. Policy changes

Bitron may update this policy from time to time to take account of legal or operational changes. We will notify users of any significant changes via our website or email.

10. Contact

For questions or complaints regarding our AML and KYC policy, please contact us.