Transparency Center

Identification and regulatory status

Swapo Finance Sociedade Prestadora de Serviços de Ativos Virtuais Ltda
CNPJ 52.854.278/0001-20

Status: virtual asset service provider company (SPSAV) in the authorization process. Category requested: intermediary virtual asset service provider (BCB Resolution No. 520/2025, art. 4, § 1, I).

• Operation as an SPSAV, intermediary category: two-phase process for companies that were already operating (BCB Resolution No. 519/2025, art. 26). The request is in phase 1.
• Operations in the foreign exchange market with virtual assets: request based on BCB Resolution No. 277/2022, as amended by BCB Resolution No. 521/2025. Operations in cash are prohibited.
• Taking office and exercise of the elected officers: authorization request for the board of officers elected on October 27, 2026.

Transition regime

Swapo declared to the BCB that it was operating on February 2, 2026, the date BCB Resolution No. 520/2025 entered into force. A company already operating that filed its request on time may keep providing the services until the process is concluded, and may not take on another category in that period (art. 88, § 6). The BCB is responsible for assessing the conditions of the request.

Licenses

No regulatory license or authorization has been granted to Swapo, in Brazil or abroad, as disclosed on this date. A third party's license is also not presented as if it were Swapo's. See the Central Bank's register of institutions to check authorizations granted.

Activities

Swapo intermediates, on behalf and at the order of the client, the purchase of USDT with reais received by Pix and the sending to the designated wallet, including to pay overseas suppliers. It does not provide custody, credit, discretionary management, staking, asset issuance, intermediation of securities or any product promising returns. Details in the Service description.

Responsible officers

Officers elected in the second amendment to the articles of association, dated October 27, 2026, for a four-year term. Taking office and exercising the role depend on BCB authorization. One officer holds both the Risk and Capital and the Integrity and Compliance positions, as art. 14, § 1, of BCB Resolution No. 520/2025 allows.

Risks, guarantees and insurance

• Market and liquidity: prices can change; the provider may not have the liquidity to execute the order at the desired time.
• Stablecoins: the peg to the dollar can be lost. The composition and availability of reserves depend on the issuer.
• Counterparty: issuers, liquidity providers and institutions can fail, restrict operations, block assets or become insolvent.
• Technology: networks and smart contracts can suffer failures, attacks, congestion or forks.
• Transfer: the wrong network or address and loss of keys can cause irreversible loss.
• Regulation and taxes: changes can alter availability, costs, obligations and redemption conditions.

Swapo has not purchased insurance for clients' balances, for fraud or for cyber risks. Do not assume coverage from logos, security measures or issuers' reserves. The Risk policy details the risks to the user.

Before trading, assess your knowledge and your ability to bear losses. An operation that does not match your profile requires a specific risk acknowledgment statement (BCB Resolution No. 520/2025, art. 59), and Swapo may guide you to seek independent financial advice.

Fees and how the quote is formed

Compare the total cost, not just an isolated rate. Swapo does not set the price of the asset: the quote comes from the liquidity provider, and the intermediation fee is applied on top of it.

Request-for-quote pricing

Each operation uses a request-for-quote: the liquidity provider states the price and the quantity available, and Swapo shows the base quote, the fee, the final quote and the amount that reaches the destination. The quote is valid for 30 seconds. After the Pix payment clears, the USDT is sent on the TRON network. Swapo is not the counterparty, and execution depends on the provider: Swapo does not guarantee completion if the provider does not honor the quote within the stated deadlines and conditions; in that case, you are informed of the situation and the alternatives, including a new quote, and acceptance of different conditions is not presumed.

The receipt shows the asset, quantity, quote, fee, taxes, net amount, date, time and transaction hash. Do not confirm an operation with incomplete costs or conditions.

The home page simulation is illustrative: it uses a fixed sample quote, not linked to the market, and does not execute orders. It is not a real quote, a promise of the best price or a recommended exchange strategy; the quote, fee and final amount are confirmed on the platform before each operation.

Offered asset: USDT on the TRON network

Current list of offered assets: USDT, on the TRON network (TRC-20 standard). No other asset or network is available. Swapo does not issue the USDT, and mentioning the issuer does not represent a partnership or endorsement. Information consulted on October 29, 2026.

USDT — Tether

Nature and purpose: token pegged to the United States dollar, used for payment and transfer on blockchain networks. It is not dollars deposited in a bank and it does not earn interest.

Issuer: Tether International, S.A. de C.V., El Salvador, according to the terms consulted.

Technology: on the TRON network, USDT is a smart contract under the TRC-20 standard. The official USDT contract on TRON is TR7NHqjeKQxGTCi8q8ZY4pL8otSzgjLj6t, according to Tether. The TRON network is a public blockchain coordinated by the TRON DAO community. Each transfer generates a public hash that can be looked up on network explorers. Sending over another network or to an incompatible address can cause irreversible loss.

Stabilization and reserves: the issuer discloses reserves and issuance and redemption conditions. The composition should be checked at the up-to-date source. Reserves declared by the issuer are not equivalent to deposit insurance.

Redemption and rights: direct redemption depends on eligibility, registration, limits, fees and Tether's terms. Anyone who holds USDT through third parties should not assume direct access to the reserves. There are risks of loss of the peg, freezing, unavailability and insolvency of the issuer.

Market: liquidity, volume and price change over time. Volatility, trading volume and price history can be checked at an independent public source, such as the USDT page on CoinGecko. Issuer sources: terms and redemption, reserves and transparency and supported protocols.

Risk rating: S&P Global Ratings downgraded its stability assessment of USDT to 5 (“weak”), the lowest level on its scale of 1 to 5, on November 26, 2025. We did not find a credit rating for the issuer or for the custodians of the reserves. El Salvador, the issuer's home country, has a sovereign rating of B3 at Moody's (positive outlook since February 2026) and B- at S&P, according to public sources consulted on November 1, 2026. Check the current ratings with the agencies themselves.

If the issuer stops its activities, contact support to obtain the records of your operations and guidance. Redemption at face value and automatic access to the reserve assets are not guaranteed; how to make a claim depends on the issuer's terms and the competent jurisdiction.

Guidelines for selection, suspension and delisting

Asset selection must consider purpose, technical documentation, issuer, technology, traceability, liquidity, volatility, fraud risks and legal restrictions. For stablecoins, it must also consider the stabilization mechanism, the nature and proof of the reserves, the reserve custodians and the redemption conditions.

Stablecoins whose reserve control depends on algorithms are not offered, nor are assets intended to facilitate unlawful anonymity. Loss of the peg, technical failure, a significant drop in liquidity, irregularity, unavailability of the issuer or an authority's order may lead to suspension or delisting, with notice to the client about dates, pending orders, alternatives and costs, except for mandatory urgent measures.

These are public information guidelines. The formal policy on offering, listing, suspension and delisting, with technical committee decisions (art. 64, § 1), is not yet published.

Institutions involved in providing the services

List of the institutions that take part in providing the services (BCB Resolution No. 520/2025, art. 52, § 1, V). Hiring third parties does not remove Swapo's responsibility.

Identification, address and responsible persons according to the public CNPJ register (Brazilian Federal Revenue Service, Receita Federal); contact channels according to each institution's official website, consulted on November 1, 2026.

Tether is identified as the issuer of the asset, not as a partner institution. The Liquidity supplier relationship policy describes the selection, due diligence, contract and monitoring of the providers.

Existing conflicts of interest and mitigation

• Compensation tied to volume: the intermediation fee disclosed to the client may be shared with the OTC desk that supplies the liquidity, and Swapo may receive a share of the commission generated in each operation, according to the contract with each desk. Mitigation: costs itemized before confirmation and on the receipt, a ban on undisclosed rebates and on steering orders out of self-interest, and Compliance review in the choice and review of the provider.
• Data protection officer and OTC desk: Swapo's data protection officer (DPO), Matheus Luiz Puppe Magalhães, appears in the public CNPJ register as an administrator of Onda Finance, one of the OTC desks. Mitigation: the enhanced controls that the liquidity supplier policy provides for a related supplier, such as a formal declaration of the link, approval by an independent body, comparison with unrelated suppliers, monthly monitoring of prices and execution quality, and Compliance review.

Swapo does not act as a counterparty in clients' operations and does not hold a proprietary trading position, according to the Service description. Other conflict situations and the measures provided for are in the Policy on identifying, preventing and mitigating conflicts.

Custody, self-custody and transfers

Swapo does not provide custody of virtual assets and does not hold clients' private keys. The USDT may pass, automatically and for less than 24 hours, through a Swapo transactional wallet and then goes on to the wallet designated by the client or to the operation's destination. This wallet is not offered as safekeeping and does not allow a balance to be kept. See the Custody model and operational wallets.

With self-custody, you manage your own keys and are responsible for safeguarding them: protect the recovery phrase, never share it and check the network before receiving. If you choose a custodian, safekeeping follows your contract with them, and Swapo only sends the asset to the address you designate.

The Asset segregation policy requires that clients' reais be held in accounts segregated from Swapo's own accounts and not be used for the company's expenses, guarantees or investments. In the authorization process, the independent audit of the financial statements and the technical assessment of the software were completed. The report of the asset segregation audit required by art. 30 (every two years, with reasonable assurance) will be published on this page (art. 30, § 1).

Funds come in by Pix, and go out to a registered and validated TRC-20 wallet. Proof of control of the wallet may be requested, by message signature or test transfer. Request receipts and statements through the app or the support channels.

Identification, profile and AML/CFT/CPF

Operations follow the policies on preventing money laundering and the financing of terrorism and of the proliferation of weapons of mass destruction. At registration, you may be asked for an identity document (RG, CNH or passport), recent proof of residence and, for companies, the articles of association and data on the partners and the ultimate beneficial owner. Depending on the risk, a liveness check or an interview may be required.

A transfer may be held until data is completed, and a match on a sanctions list leads to an immediate block. Reports to COAF (Brazil's Financial Intelligence Unit) are confidential and are not disclosed to the client; being the subject of a mandatory report does not mean having committed any wrongdoing. There is no promise of anonymity or exemption from identification.

Policies: AML/CFT, KYC, KYB, KYT, KYW, Travel Rule and reporting to COAF.

Security and continuity

The public summary of the information and cyber security policy is in the Information security policy. Safekeeping of the control instruments of the operational wallets follows the Key management and recovery procedure, and interruptions follow the Business continuity plan. The Cybersecurity Officer is responsible for the policy and for the incident response plan.

Uninterrupted availability is not promised. The technical assessment of the software carried out in the authorization process is not a security certification, and Swapo does not claim SOC 2 or ISO 27001 certification.

Recommended measures: use two-factor authentication, check the official address before signing in, never share a password, code or private key, and do not install a remote access app at the request of a supposed support agent. If you suspect fraud, stop the operation, preserve evidence and contact the official channel.

Incidents involving personal data follow the Privacy Policy and the rules of the LGPD (Brazil's General Data Protection Law) and the ANPD (Brazilian Data Protection Authority).

Human support

Human support in Portuguese, Monday to Friday, 9 a.m. to 6 p.m., for questions, documents, complaints and guidance on security incidents, breaches or service interruptions, including those of the contracted institutions. Security incidents take priority. Ask for a protocol number.

• WhatsApp and phone: +55 (11) 91004-2300.
• E-mail: [email protected].
• Mail: Rua Fidêncio Ramos, 100, Vila Olímpia, São Paulo/SP, CEP 04551-010.

Complaints are handled independently of the sales area. Provide the operation reference, the date and what happened, without including passwords or keys. You may also turn to consumer protection bodies and the competent authorities.

Ombudsman

The ombudsman, provided for in the articles of association under BCB Resolution No. 28/2020, handles as a last resort the demands not resolved by support and acts in conflict mediation. Contact: [email protected].

• Reply within 10 business days, extendable only once, for the same period, with justification and notice of the reason to the complainant.
• Demands are kept on record for at least five years.
• The ombudsman is appointed by the partners for a 12-month term and designated before the BCB.

Keep protocol numbers and receipts. You can file a complaint with the Central Bank. Access to Procon (consumer protection agency) and the courts does not depend on exhausting the internal channels.

Policies and official sources

Institutional policies (22 public versions) · Terms of Use · Privacy Policy and cookies

References consulted on November 1, 2026. Applicability depends on the service, the institution's status and the transition rules.

• BCB Resolution No. 519/2025 — authorization.
• BCB Resolution No. 520/2025 — operation and disclosure duties, as amended by BCB Resolution No. 589/2026.
• BCB Resolution No. 277/2022 — foreign exchange market, as amended by BCB Resolution No. 521/2025.
• Circular No. 3,978/2020 — AML/CFT.
• Joint Resolution No. 17/2025 — naming and presentation.
• BCB Resolution No. 85/2021 — cyber security.
• BCB Resolution No. 28/2020 — ombudsman.
• Law No. 14,478/2022, the Consumer Protection Code and the LGPD.