OBJECTIVE

This Manual aims to describe the internal criteria and processes used for continuous monitoring, selection, evaluation, and communication of operations and situations that contain indications of money laundering and terrorist financing crimes. Through the application of appropriate monitoring, selection criteria, controls, and processes, FacilitaPay is able to decide on making Communications to COAF.

FacilitaPay conducts the monitoring, selection, analysis, and communication processes of Suspicious Operations and Situations in line with market best practices, with FacilitaPay Group's international guidelines, with the provisions of Circular No. 3,978, the Anti-Money Laundering Law, and Circular Letter No. 4,001/20. These processes are reviewed annually or whenever there are changes in applicable legislation and regulations, as well as material changes in products offered and/or services provided by FacilitaPay, always previously analyzed and approved by the responsible authorities, as described in this Manual.

This Manual has been duly approved by FacilitaPay's Senior Management.