This Policy aims to establish guidelines and responsibilities that govern FacilitaPay's internal procedures, controls, and systems to ensure that FacilitaPay's internal ecosystem, products, and services are not used or involved in illicit activities, especially those described in the Money Laundering Law and the Anti-Terrorism Law.

This Policy was developed in accordance with FacilitaPay's risk profiles, its Clients, operations, products and services offered, and Employees, as well as in compliance with the legislation and regulations applicable to FacilitaPay, notably in accordance with Circular No. 3,978/20. This Policy is applicable to all FacilitaPay Employees and Clients, as applicable.