Know Your Transaction (KYT) Policy

Objective

The prevention of money laundering, terrorist financing and the proliferation of weapons of mass destruction does not end with the initial identification of the client. It requires continuous, contextualized monitoring of transactions.

The policy governs this monitoring, so that Swapo understands each client's transactional behavior throughout the entire relationship and verifies whether operations are consistent with the financial capacity, the declared economic activity, the history and the risk assigned in the KYC process. It also provides input for decisions on restriction, blocking, termination of the relationship and reporting of suspicious operations to COAF (Brazil's Financial Intelligence Unit).

Scope

The policy applies to all transactions carried out within Swapo's services, in fiat currency, virtual assets, tokens and related instruments, regardless of the channel, the technology or the form of execution.

Monitoring is integrated with the client's registration and behavioral information and uses data from the Know Your Customer (KYC), Know Your Wallet (KYW) and Travel Rule policies, in addition to Swapo's operational records.

Risk-based approach

Not all transactions present the same risk. For this reason, the degree of monitoring, analysis and due diligence must be proportional to the risk identified, taking into account objective and subjective factors related to the client, the transaction and the environment in which it takes place.

Monitoring and consistency analysis

Monitoring must be continuous and combine automated systems, blockchain analysis tools and manual analyses by the Compliance/AML area. It seeks to identify significant deviations from the client's historical pattern, abrupt changes in the volume, frequency or nature of operations, and transactions that, alone or together, have no plausible economic or operational justification.

Each transaction must be analyzed for consistency with the client's profile, taking into account the origin and destination of the funds, the amount, the frequency, the complexity of the routes, the geographic exposure and the degree of traceability. The assessment is contextual and dynamic, and not based only on fixed parameters.

On-chain and counterparty analysis

For virtual asset transactions, the policy provides for specific analysis of on-chain movements, with specialized traceability tools, to identify links to high-risk wallets, known unlawful activities and services designed to conceal the origin and destination of funds.

The analysis of counterparties includes, where applicable, checking high-risk jurisdictions, national and international sanctions lists, adverse media and relevant public information.

Risk classification and preventive measures

Transactions must be classified by risk according to materiality, context, the client's history and aggravating factors. Transactions consistent with the profile and history tend to be low risk; significant deviations, excessive complexity or links to risk factors lead to a medium or high risk classification. The classification is dynamic and may be revised at any time.

Medium- or high-risk transactions undergo in-depth analysis and may lead to:

• a request for clarification from the client;
• a requirement for additional documentation;
• a temporary restriction on operations;
• a preventive block on transactions.

In high-risk cases, the decision must be escalated to higher levels of governance, including top management, with segregation of duties and technical grounds.

Reporting of suspicious operations

When the analysis identifies indications of money laundering, terrorist financing or other unlawful activity, Swapo must report the operation to COAF in accordance with the law. The decision to report must be documented with its grounds.

Governance, records and data protection

Execution of the policy is the responsibility of the Compliance/AML area, which must act independently of the commercial and operational areas and report periodically to senior management on the effectiveness of monitoring, the risks identified and the measures adopted. Senior management must approve the policy, ensure resources and oversee its implementation.

Monitored transactions, alerts, analyses and decisions must be recorded in a complete and auditable manner for the minimum period required by the regulations, making it possible to reconstruct the entire decision-making process for audits and supervision.

The processing of personal data complies with the General Data Protection Law (Law No. 13,709/2018) and the internal information security policies.

Noncompliance, review and effective date

Noncompliance with the policy, by clients or employees, may lead to corrective measures, such as suspension or termination of the relationship, reporting to the competent authorities and internal sanctions.

The policy must be reviewed periodically and whenever there is a relevant change in the business model, in products or in regulation. It takes effect on the date of its approval by senior management and must be complied with by administrators, employees and third parties involved in Swapo's activities.

Regulatory basis

• Law No. 9,613/1998 (money laundering).
• BCB Circular No. 3,978/2020.
• Law No. 14,478/2022 (provision of virtual asset services).
• General Data Protection Law (Law No. 13,709/2018).
• FATF Recommendations, adapted to the context of virtual assets.

About this version

Public version of the document “Know Your Transaction (KYT) Policy”, dated September 21, 2026, which is part of the authorization request filed with the Central Bank of Brazil. Authorization has not been granted yet.

This text summarizes the internal document. Personal data (LGPD), monitoring parameters and technical details whose disclosure would undermine security, fraud prevention and anti-money laundering efforts have been omitted, as have terms subject to business confidentiality (BCB Resolution No. 520/2025, art. 52, § 2). This version does not replace the service agreement or the applicable regulations.

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