The present Report aims to describe the internal criteria and processes for identification, measurement, evaluation, and monitoring of risks related to FacilitaPay itself, the use of Products and Services provided and offered by FacilitaPay, execution of operations and transactions by FacilitaPay, and the risks involving Clients and Collaborators, Partners and Service Providers of FacilitaPay in relation to AML/CFT practices.

In line with current regulations and best market practices, and in accordance with the AML/CFT Policy and related internal documents, FacilitaPay adopts a risk-based approach as the main tool for governance of AML/CFT-related matters.

To this end, FacilitaPay conducts an internal risk assessment process aimed at ensuring that internal measures intended to prevent and mitigate the risks of Money Laundering, Terrorism Financing, or proliferation of weapons of mass destruction crimes are proportional to the identified risks, as well as having an adequate AML/CFT risk management structure, allowing for intelligent and efficient resource allocation.

Thus, this Report, in addition to assessing AML/CFT risks, also presents an analysis of the internal conducts necessary for the maturation of FacilitaPay's internal controls to reach an adequate level proportional to the identified risks applicable to FacilitaPay, Clients, Collaborators, Partners and Service Providers, Products and Services, as well as operations and transactions executed by FacilitaPay.

This Report was prepared in a manner consistent with the nature, size, complexity, structure, risk profile, and business model of FacilitaPay, in order to provide effective AML/CFT risk management in the exercise of its activities, and was approved by the AML/CFT Director prior to its implementation.

This Report is applicable to all FacilitaPay Collaborators, but is the object of analysis and dissemination by FacilitaPay's Compliance, Legal, and Senior Management areas.