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DATACLUB S.A. ANTI MONEY-LAUNDERING (AML) POLICY

Policy

It is the policy of DATACLUB S.A. and its affiliates, (hereinafter "DATACLUB S.A.") to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. DATACLUB S.A. is committed to AML compliance in accordance with applicable laws of jurisdictions where DATACLUB S.A. offers corporate and legal services. DATACLUB S.A. requires its officers, employees and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

Each employee of DATACLUB S.A., whose duties are associated with the provision of products and services of DATACLUB S.A. and who directly or indirectly deals with the clientele of DATACLUB S.A., is expected to know the requirements of the applicable laws and regulations which affect his or her job responsibilities, and it shall be the affirmative duty of such employee to carry out these responsibilities at all times in a manner that complies with the requirements of the relevant laws and regulations.

The laws and regulations include, but not limited to: "Customer Due Diligence for Banks" (2001) and "General Guide to Account Opening and Customer Identification" (2003) of Basel Committee of banking Supervision, Forty + nine Recommendations for Money Laundering of FATF, USA Patriot Act (2001), Prevention and Suppression of Money Laundering Activities Law of (1996).

To ensure that this general policy is carried out, management of DATACLUB S.A. has established and maintains an ongoing program for the purpose of assuring compliance with the relevant laws and regulations and the prevention of money laundering. This program seeks to coordinate the specific regulatory requirements throughout the group within a consolidated framework in order to effectively manage the group’s risk of exposure to money laundering and terrorist financing across all business units, functions, and legal entities.

Each of the affiliates of DATACLUB S.A. is required to comply with all aspects of the group’s policy as well as their own AML policies which specifically consider the local AML laws and requirements to which they are subject. Failure by the group and its affiliates to comply with the all applicable local AML laws and regulations could result in severe regulatory sanctions, possible fines and criminal penalties and damage to the group's business reputation.

Risk Assessment

An assessment of the risk of exposure to money laundering issues across all customer relationships shall be completed using the DATACLUB S.A. standardized risk rating model. The risk rating model shall be approved by the Board of Directors on an annual basis.

Suspicious Activities

There are signs of suspicious activity that suggest money laundering. These are commonly referred to as "red flags." If a red flag is detected, additional due diligence will be performed before accepting client’s requests or providing services.

Examples of red flags are:

Customer Identification

DATACLUB S.A. will document and maintain written customer identification procedures ("CIP") that will enable to form a reasonable belief that DATACLUB S.A. knows the true identity of each customer. If the DATACLUB S.A. is not able to verify the identity of a customer within a reasonable period of time after services or account opening request, that services shall be suspended and account will be closed. Such an account and services will be subject to increased due diligence until such time as the customer’s identity has been verified or the account has been closed and services suspended.

CIP for Natural Persons


For natural persons the following information should be obtained, where applicable: DATACLUB S.A. shall verify this information by at least one of the following methods:

CIP for Institutions

The underlying principles of customer identification for natural persons have equal application to customer identification for all institutions. Where in the following the identification and verification of natural persons is involved, the foregoing guidance in respect of such persons shall have equal application. The term institution includes any entity that is not a natural person.

For corporate entities (i.e. corporations and partnerships), the following information should be obtained: This information should be verified by at least one of the following methods:

Recordkeeping

All identification documentation and services records shall be kept for the minimum period of time required by local law.
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