Anti-money laundering policies and procedures

Policy statement

Inverte is committed to fully complying with all applicable laws and regulations regarding money laundering procedures. Inverte has adopted and will enforce the provisions established in the Anti-Money Rules and Regulations to prevent and detect money laundering, terrorist financing, and other illegal activities.

If Inverte, its personnel, and / or premises are inadvertently used for money laundering or other illegal activities, Inverte may be subject to potentially serious civil and / or criminal penalties. Therefore, it is imperative that each member, officer, director, and employee (each, an "Employee") is familiar with and complies with the policies and procedures outlined in this Compliance Manual.

This statement of compliance is designed to help all customers comply with Inverte's policy and procedures, which, if followed diligently, are designed to protect themselves, Inverte, its employees, its facilities, and its activities. against money laundering or other illegal activities.

To ensure that the policies and procedures are followed, Inverte will appoint an Anti-Money Laundering Compliance Officer (the "Compliance Officer"). The Compliance Officer is responsible for establishing and conducting Employee training programs to ensure that all appropriate Employees are aware of the applicable Anti-Money Laundering Laws and Regulations, the Anti-Money Laundering Policies and Procedures and their responsibilities concerning these policies.

Goals

Concepts

Money Laundering (ML):

It is the process by which Natural or Legal Persons and criminal organizations, seek to give a legitimate appearance to illicit goods or assets.

Terrorism Financing (TF):

It is the act committed by the one who intentionally finances, subsidizes, hides, or transfers money or goods to be used or, knowing that they will be used, in the commission of any of the crimes of terrorism.

Financing of Proliferation of Weapons of Mass Destruction:

Refers to any act that provides funds or uses financial services, in whole or in part, for the manufacture, acquisition, possession, development, export, transfer of material, fractionation, transportation, transfer, deposit or use of nuclear, chemical or biologicals, their launch media, and other related materials.

Competent Authorities:

They are the authorities that, by the powers conferred by the laws, are guarantors of the prevention, prosecution, and sanction of money laundering, the financing of terrorism, and the proliferation of weapons of mass destruction.

Obliged Subject:

It is the Natural or Moral Person who, in the Rules or regulations, is obliged to fulfill obligations aimed at preventing, preventing, and detecting money laundering.

Compliance officer:

It is the high-level executive designated by the Mandated Subject, with technical capacity, who oversees monitoring the strict observance of the compliance program. Said officials will serve as a liaison of the obligated subject with the Financial Analysis Unit (UAF) and the supervising entity.

Suspicious Operations:

They are those transactions, carried out or not, complex, unusual, significant, as well as all patterns of unusual transactions or insignificant but periodic transactions, that do not have an evident economic or legal basis, or that generate suspicion of being involved in the money laundering, a previous crime or terrorist financing.

Politically Exposed Person (PEP):

Refers to any individual who performs or has held, during the last three (3) years high public functions, by-election, or executive appointments, in a foreign country or national territory, including senior officials of international organizations. Includes, but is not limited to heads of state or government, high-ranking government, judicial or military officials, senior executives of state companies or officials, as well as those determined by the National Committee on Money Laundering, after consultation with the Ministry of Public Administration.

Controls to prevent money laundering

Any employee should immediately notify the Compliance Officer if they suspect or have any reason to suspect that potentially suspicious activity has occurred or will occur if a transaction is completed. Employees are encouraged to seek the assistance of the Compliance Officer with any questions or concerns they may have regarding the Inverte Anti-Money Laundering Policies or Procedures.

The Compliance Officer's responsibilities include the following:

To ensure continued compliance with Inverte's anti-money laundering policies and procedures, all Employees must confirm their knowledge of the content of this Compliance Manual by signing the acknowledgment form annually, or more frequently, as required by the Compliance Officer. Compliance.

All employees are required:
  • Inverter's anti-money laundering policies and procedures are intended to ensure that, before accepting funds from Clients, all reasonable and practical steps are taken to confirm the identities of Clients.
  • These customer identification procedures are based on the premise that Inverte will accept funds from a new and existing customer only after:
  • The statement on the simplified KYC application form that includes:Additional information that may be requested includes:

    The Compliance Officer will continuously provide and update a list of the types of Clients that Inverte considers to be 'high risk', so that improved due diligence procedures are ensured compared to Routine Client Identification Procedures.

    The following are examples of clients who are at high risk of money laundering:

    Retention of customer records

    Copies of all documents related to Inverte's Client Identification Procedures will be retained for an appropriate period and, at a minimum, the period required by applicable law or regulation.

    The documents that Inverte retains are copies of documents reviewed about the Client Identification Procedures or enhanced due diligence procedures, client identification checklists if any, or similar due diligence documentation, and any other document that must retain the applicable anti-money laundering legislation.

    Inverte will retain documents for as long as a Client is an Inverte customer and for a minimum of five years after this relationship ends.

    Audit

    A periodic review of the program should be carried out to ensure that it works as designed. Such a review could be carried out with external or internal resources and should be accompanied by a formal evaluation or a written report.

    If the regulations regarding the notification of suspicious activities are modified, AHL will modify this Compliance Manual to comply with said regulations.