Anti-Money
Laundering Policy

LA BANDA NEGRA SL ("LA BANDA NEGRA SL," the "Company") is committed to conducting business with the highest standards of integrity and to supporting the anti-money laundering ("AML") and counter-terrorist financing ("CTF") obligations that apply to our business. This AML Policy sets forth the framework for our compliance program and applies to all employees, contractors, and agents of the Company.

This Policy applies to all Services provided by LA BANDA NEGRA SL, including but not limited to cross-border payment processing, multi-currency payouts, digital trade facilitation, and API services. We support the compliance programs of our licensed payment partners and cooperate with their AML/KYC requirements, and this Policy describes how we carry out our own onboarding and monitoring responsibilities for the merchants we serve.

The Company maintains a compliance function responsible for overseeing the implementation and enforcement of this Policy, including the day-to-day operation of our onboarding and monitoring procedures. Contact: [email protected].

We conduct regular risk assessments to identify, assess, and mitigate money laundering and terrorist financing risks associated with our Services, customers, geographic footprint, and delivery channels. Risk assessments are reviewed at least annually and upon significant changes to our business model or regulatory environment.

We implement risk-based Customer Due Diligence procedures for all customers. Our CDD program includes:

• Identification and Verification: Collecting and verifying customer identification information including legal name, physical address, date of incorporation, and tax identification numbers.
• Beneficial Ownership: Identifying and verifying the beneficial owners and control persons of our business customers.
• Nature of Business: Understanding the customer's business activities, expected transaction patterns, and purpose of the account.
• Ongoing Monitoring: Periodic review of customer information and transaction activity to ensure consistency with the customer's risk profile.

Enhanced Due Diligence measures are applied to higher-risk customers and transactions, including:

• Politically Exposed Persons (PEPs) and their close associates and family members.
• Customers from high-risk jurisdictions identified by FATF or other international bodies.
• Complex or unusually large transactions with no apparent economic or lawful purpose.
• Customers in high-risk industries including virtual asset services, precious metals, and shell banks.
• Additional documentation, senior management approval, and enhanced transaction monitoring.

LA BANDA NEGRA SL takes sanctions risk seriously. Sanctions screening of customers, transactions, and counterparties is performed by our regulated payment partner as part of its own compliance program, and we cooperate fully with that screening and act on its outcomes. We do not knowingly engage in transactions prohibited by applicable sanctions laws.

We employ automated transaction monitoring systems to detect potentially suspicious activity. Our monitoring framework includes:

• Rule-based scenarios designed to detect known money laundering typologies.
• Behavioral analytics to identify deviations from expected customer activity patterns.
• Threshold-based alerts for transactions exceeding specified monetary values.
• Cross-border transaction monitoring for unusual patterns, structuring, or layering.
• Regular tuning and validation of monitoring rules to reduce false positives.

When potentially suspicious activity is identified through our monitoring or other means, our compliance team reviews it and, where warranted, escalates the matter to our licensed payment partner in line with its reporting procedures. We cooperate with our payment partner's reporting obligations and handle all related information confidentially.

We maintain comprehensive records to demonstrate compliance with AML/CTF requirements. Records are retained for a minimum of five (5) years following the termination of the customer relationship or completion of the transaction, whichever is later. Records include:

• Customer identification and verification documents.
• Transaction records including amounts, currencies, counterparties, and purposes.
• Risk assessments and due diligence reviews.
• Suspicious activity investigations and related escalations to our payment partners.
• Training records and compliance program documentation.

All employees receive mandatory AML/CTF training upon hire and at least annually thereafter. Training is tailored to employee roles and responsibilities and covers:

• AML/CTF legal and regulatory requirements.
• Red flags and money laundering typologies relevant to our business.
• Customer due diligence and enhanced due diligence procedures.
• Suspicious activity identification and escalation procedures.
• Sanctions compliance and screening procedures.

Our AML compliance program is subject to periodic internal review at least annually to evaluate its effectiveness. The review is conducted by personnel who are not involved in the day-to-day operation of the AML program, and findings and recommendations are reported to senior management and acted on as part of our continuing improvement.

This Policy is administered by our compliance function and is reviewed at least annually. Violations of this Policy may result in disciplinary action, up to and including termination of employment or business relationship. Any questions or concerns regarding this Policy should be directed to [email protected].