1. The Company

The FINTEX based in Zürich is affiliated with VQF (http://www.vqf.ch/), an organ of selfregulation of official intermediation companies recognized by the Swiss Authority FINMA (http://www.finma.ch/)

2. Objectives

The purpose of this policy is to establish the general framework with Fintex AG for the fight against money laundering (MT) and financing of terrorism (FT). Fintex AG also puts reasonable measures in place to control and to limit ML/FT risk, including dedicating the appropriate means. Fintex AG is committed to high standards of anti-money laundering/ counter the financing of terrorism (AML/CFT) compliance and requires management, employees and subsidiaries to adhere to these standards in preventing the use of its products and services for money laundering or terrorism financing purposes.

3. Money Laundering and Terrorism Financing

Money laundering is the process by which resources originating from illegal activities are transformed into assets of apparently legal origin This practice generally involves multiple transactions, used to hide the source of financial resources and allow them to be used in a way that appears to be lawful. Those responsible for this operation make sure that the values obtained through illegal and criminal activities (such as drug trafficking, corruption, arms trade, prostitution, white collar crimes, terrorism, extortion, tax fraud, among others) are hidden or hidden, appearing as a result of legal commercial operations and that can be absorbed by the financial system, of course.

The Money Laundering process consists of three phases:

(I) Placement: entry into the financial system of funds from illegal activities, through deposits, purchase of financial instruments or purchase of goods. At this stage, it is common to the use financial institutions to introduce funds obtained illegally.

(II) Concealment: execution of multiple financial operations with the resources already entered the financial system, aiming at concealing illegal resources, through complex transactions and in large numbers to make it difficult to track, monitor and identify the illegal source of money;

(III) Integration: formal incorporation of money into the economic system, through investment in the capital market, real estate, works of art, among others.

Financing for terrorism consists of the process pf disguised distribution of resources to be used in terrorist activities. These resources generally come from the activities of other criminal organizations involved in the trafficking of drugs, arms and ammunition and in smuggling, or can be derived from illicit activities, including donations to “front” charities.

4. Organization of the AML/CFT Function

4.1 Corporate Organization

Accordance with the AML/CFT legislation, Fintex AG has appointed a responsible at the “highest level” among its Board of Directors for the prevention of ML/TF: The CEO at Group level Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures.

4.2 Policy Implementation Requirements

Each major change of Fintex AG AML policy is subject to approval by the Company Management Board.

4.3 Enterprise-Wide Risk Assessment

The prevention of the use of the financial system for the purposes of money laundering or terrorist financing requires financial institutions to take a risk based approach to combating ML and TF. The risk assessment is a critical component of the Fintex AML/CFT compliance management program As a part of its risk-based approach, Fintex has conducted an AML “Enterprise-wide risk assessment” to identify and understand risks specific to Fintex and its business lines. The Fintex AML risk profile is determined after identifying and documenting the risks inherent to its business lines offered, transactions performed by these customers, delivery channels used by the company, the geographic locations of the company’s operations, customers and transactions and other qualitative and emerging risks. The identification of AML/CFT risk categories is bases on Fintex understanding of regulatory requirements, regulatory expectations and industry guidance.

5. Minimum Standards

FINTEX has established standards regarding Know-Your-Customer (“KYC”). These standards require due diligence customer begins with identification of the customer by means of the necessary identification documents.

5.1 Customer Identification and Verification (KYC)

Fintex AG has established standards regarding Know-Your-Customer. These standards require due diligence on each prospective customer before entering into a business relationship:

• via identification and verification of his identity and, as the case may be, his representatives and beneficial owners on the basis of documents, data or information obtained from a reliable and independent source compliant with the anti-money laundering legislation and regulations;
• via obtaining information on the purpose and intended nature of the business relationship

The customer must provide all the registration information requested:

a) KYC Form
b) Declaration of Form A
c) Identification document

All clients are submitted to the analysis of restrictive lists:

(I) List of Sanctions, which contains the names of natural persons (including suspects, accused, convicted or fugitives);

(II) List of Politically Exposed Persons, which contain the defined persons an PEP and its associates in the form of the current regulation.

In each transfer, the customer is submitted to restrictive lists described above through our system. The results presented are evaluated by Compliance analysts who classify the occurrences as “False Positive” (false positive) or “ True Match” (positive identification). In case an analysis raises doubts regarding the status, the case may be escalated to the Compliance Superior who will decide on the filing or positive classification – “ True Match”

FINTEX will not accept customer relations with persons or entities not meeting the above acceptance criteria, or whose legitimate intentions do not immediately appear to be sufficient, or included in the SECO list.

5.2 Reinforced Due Diligence Process

The costumer, at the beginning of the relationship with Fintex, must self-declare his situation as a politically exposed person. Additionally, Fintex has a list of PEPs, prepared by a private company. The consultation is carried out automatically on the system. Fintex not accept relations with politically exposed persons (PEP) customers.

5.3 Risk Profile Calculation

To assist in determining the level of AML/CFT due diligence to be exercised with regard to the customer, a “Compliance” risk profil is calculated first of all on entry into relations (Low, Medium, High), and is the recalculated daily.

5.4 Ongoing Customer Due Diligence

For some dedicated higher risk customer categories, a periodically risk-based review is carried out to ensure that customer-related data or information is kept up-to-date. The current KYC review process regarding the other customer categories is essentially based on an “awareness principle” following the examination of a dedicated file by the AML team. This awareness principle consists in asking the customer`s relationship manager henceforth to closely perform a periodic KYC review of the customer.

5.5 Ongoing Transaction Monitoring

AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the costumer profile. The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore more rapidly be considered atypical (as they are not directly justifiable)

6. Organization of Internal Control

6.1 Suspiciouss Transactions Reporting (STR)

A Money Laundering Reporting Officer (MLRO) is appointed to ensure that unusual transactions detected are reported to the VQF and FINMA. The reporting of suspicious transactions must comply with the laws and regulations of the respective local jurisdiction.

6.2. Procedures

The AML/CFT rules, including minimum KYC standards, into operational procedures taking into account their type of activities, their volume and their size together with the local legal and regulatory requirements.