AML and due diligence

5.1Application. To open an Account you must submit an application through the Platform or another channel we approve and provide the information and documents we request, which may include:

1. (a)your certificate of incorporation, articles of association or equivalent constitutional documents, and evidence of good standing;
2. (b)your tax identification number and registered and operating addresses;
3. (c)a description of your business, products, customers, counterparties, jurisdictions of operation, expected activity and the intended use of the Services;
4. (d)the identity of your directors, officers, authorised signatories and Authorised Users, with identity documents and proof of address;
5. (e)the identity of your ultimate beneficial owners and controllers, including every natural person who directly or indirectly owns or controls twenty-five per cent (25%) or more of your shares or voting rights, or a lower percentage where Applicable Law or our risk assessment requires, and of any person who otherwise exercises control over you;
6. (f)your ownership and control structure chart;
7. (g)copies of licences, registrations or authorisations relevant to your business;
8. (h)information and evidence regarding the source of funds and source of wealth relevant to your Account and Transactions;
9. (i)financial statements, bank references or other evidence of your financial standing; and
10. (j)your anti-money laundering, sanctions and compliance policies, where you carry on a regulated activity.

5.2Verification and screening. We will verify the information you provide and screen you, your beneficial owners, controllers, directors and Authorised Users against Sanctions lists, lists of politically exposed persons, adverse media and other sources. We may use third-party identity verification, screening and blockchain analytics providers for this purpose. You authorise us to make any enquiries we consider necessary.

5.3Risk rating and enhanced due diligence. We assign every Client a risk rating. Where you, your beneficial owners or your activity present a higher risk, including where a politically exposed person is involved, we will apply enhanced due diligence, which may include additional documents, senior management approval, lower limits and more frequent reviews.

5.4Ongoing due diligence. We review Accounts periodically and whenever events require it. You must respond promptly, and in any event within the period we specify (which will normally be not less than five (5) Business Days), to any request for information or documents. Failure to respond may result in restriction or suspension of your Account.

5.5Accuracy of information. You warrant that all information and documents you provide to us are true, accurate, complete, current and not misleading. Certified, notarised, apostilled or translated copies may be required for documents issued outside El Salvador or in a language other than English or Spanish.

5.6One Account. Unless we agree otherwise in writing, you may hold only one Account. You may not open an Account on behalf of, or allow the use of your Account by, any other person, including your own customers.

5.7Account activation. Your Account will be activated only after we have completed our due diligence and approved your application. Approval of your Account does not mean that every Service, Supported Digital Asset, Network or limit is available to you. We enable Services and set limits individually.

14.1Our obligations. We are subject to laws and regulations on the prevention of money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, including the Special Law for the Prevention, Control and Sanction of Money Laundering, Terrorist Financing and Proliferation Financing of El Salvador and the instructions of the Financial Investigation Unit, as well as Sanctions. Our Payment Partners are subject to similar obligations in their own jurisdictions.

14.2Monitoring and screening. We monitor Accounts, Transactions, deposits, withdrawals and payments on an ongoing basis, including through blockchain analytics, Sanctions screening and transaction monitoring systems. We may hold any Order, deposit, withdrawal or payment pending review, request information or documents from you, and refuse to process any Order where we have not been able to complete our checks to our satisfaction.

14.3Information requests. You must provide promptly any information and documents we request in connection with our compliance obligations, including information about the purpose and nature of a Transaction, the source of funds or Digital Assets, your counterparties and your customers.

14.4Reporting and confidentiality. We may be required by Applicable Law to report suspicious or regulated transactions and other information to the Financial Investigation Unit or other Governmental Authorities. We may be prohibited by law from informing you that a report has been made or that an investigation is being carried out. We will not be liable to you for any action taken, or not taken, in good faith to comply with these obligations.

14.5Freezing and blocking. We may freeze, block, hold or refuse to release Client Assets or Client Funds where required by Applicable Law, Sanctions or an order of a Governmental Authority, or where we reasonably suspect that they are the proceeds of crime or connected with fraud, Sanctions evasion or other illegal activity. We may release, return or transfer such Client Assets or Client Funds only in accordance with Applicable Law and any instructions of the competent Governmental Authority.

14.6Travel Rule. We collect, hold and transmit originator and beneficiary information for transfers of Digital Assets and Fiat Currency as required by Applicable Law and our policies. For each deposit or withdrawal you must provide accurate information about the originator or beneficiary and, where applicable, the service provider that holds the counterparty's account or wallet. We may refuse or delay a transfer to or from a service provider that does not provide or accept the required information, or to or from an Unhosted Wallet whose ownership or control cannot be verified.

14.7Your customers. If you are a regulated business and use the Services in connection with your own customers' activity, you are solely responsible for conducting due diligence on your customers in accordance with Applicable Law. You may not use the Services to provide services to third parties, or to act as a payment intermediary or nested service provider, unless we have expressly approved this in writing following enhanced due diligence and you have agreed to any Supplementary Terms we require.

14.8Record keeping. We keep records of your identity, your Account, your Orders and Transactions and our communications with you for the period required by Applicable Law, which may extend beyond the termination of the Agreement.