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I. PRELIMINARY CONSIDERATIONS

CRYPTOMKT is ensured by the Manual de Prevención de Delitos (Crime Prevention Manual) which has been mainly written to prevent Illegal Laundering Assets and terrorist financing. This Manual which is considered essential for this company development on regular daily basis, has elaborated the required policies and procedures to avoid web platform www.cryptomkt.com illegal use or participation in these crimes or others included in applicable national laws.

This Manual was drawn up by taking into account CRYPTOMKT activities i.e. cryptocurrency intermediation. In other words, this is a web platform which allows trading over them, thus, this platform permits some digital asset exchange between sellers and buyers in a technologically safe environment (Blockchain). User activities permitted by this platform are besides the already mentioned trading; market observation transactions, other user contacts through public media, money deposits and withdraws by means of bank transactions.

This activity has permitted the development of a global and decentralized economy where public information relies as a key element. However, even though this technology benefits such as people interactions could be countless, its positioning has raised many challenges from the legal compliance approach. Therefore, being CryptoMKT completely aware of these challenges and taking account of the essential technological component of this business development, it has decided to use this technological component in many procedures to prevent illegal laundering assets and terrorist financing. With the purpose of reaching the required law and regulation standards from different countries and from Chile.

Following the same topic, and in accordance with Nº49 Unidad de Análisis Financiero Chilena UAF newsletter (Chilean Financing Analysis Unity), this document includes many contents, this is the case of; definitions for understanding the manual, client knowledge procedures and policies, procedures for identifying and reporting suspected operations, procedures for timely and reserved notice regarding operations performed by subjects included in United Nations lists or by subjects belonging to non-cooperating countries, and law and ethical standards of company’s employees. Due to this Manual relevance, CRYPTOMKT has led training courses for all its employees.

It is important to point out the fact that procedures and policies to be described are a summarised version of CRYPTOMKT Crime Prevention Manual. Thus, there will not be included all its parts in details.

II. POLICIES AND PROCEDURES FOR KNOWING THE CLIENT (KYC AND DDC)

Within the framework of due diligence, it is CRYPTOMKT’s responsibility to identify and know all its clients, in order to have an effective tool which would allow us from a risk management perspective to prevent Illegal Laundering Assets and terrorist financing.

This is why CRYPTOMKT has a preventing system based on “KYC” (English acronym for “Know your costumer”). This concept infers a sequence of procedures and protocols which allow us to identify our clients, to know their activities, their most important characteristics in terms of their operations and of their supporting principles, i.e. where they are underlain in accordance with the risk profiles identified by CRYPTOMKT.

Based on information gathered within the framework of KYC processes, CRYPTOMKT creates a digital “Client file”, where personal data, client number, plus a detailed operation register be identified.

Therefore, CRYPTOMKT’s KYC considers the international structure of operations permitted to be performed through its platform. This provides digital mechanisms that allow dynamic and particular condition analyses of its users. Thus, patterns and profiles are possible to be made, plus monitoring, detection and eventually it is possible to report a client operations might the case be qualified as under suspicion.

Due Diligence and Knowledge of the Client (acronym in Spanish DDC Debida Diligencia y Conocimiento del Cliente DDC) are revealed mainly in the following procedures.

1. REGISTER PROCESS

CRYPTOMKT identifies and knows its clients by dividing them into segments and by restricting its trading volumes in accordance with their “verification levels”.

The verification levels in turn correspond to the stages of the register process. In order to reach a determined level, the platform demands the client to provide a certain information which would later be verified, in case of being trustworthy and enough in quantity it will be approved by CRYPTOMKT group. Once all the level demands are fulfilled, the client will be then enabled to make deposits and withdraws of pre-established amounts.

Hence, by considering information diversity in terms of its requirements, there are in the platform accounts for natural and legal persons. These last ones are called “institutional accounts”.

1.1. KYC Natural Persons.

Verification levels for natural persons are:

1.1.1. Observer: this user is only authorised to observe the market. Legal currency and cryptocurrency deposits and withdrawals are not permitted

Information to be provided:

• Name
• Email
• The client will only be able to operate as observer as soon as the e-mail checking procedure is done, a code is sent to the client’s address.

1.1.2. Basic: user enabled to make money deposits and withdrawals in legal currency in small amounts, the maximum is associated with a defined period

Required information:

• Name and surname.
• Gender.
• Date of birth.
• Nationality.
• Place of residence (address, districts, city, country and zip code).
• Cell phone.
• Identity Card Number.
• Photocopy of ID both sides.
• Face photography or selfie.
• Bank account information if withdrawals or deposits are needed.
• PEP declaration.
• Clients could be in Basic level once their documents and data are approved. For this purpose, it should be necessary that:
  
  • The client verifies its telephone number by means of a received code.
  • CryptoMKT verifies its identity document and personal data. For this purpose, records and personal data are cross checked with state and private database.

1.1.3. Trader: user enabled to make deposits and withdrawals in legal currency in larger amounts, the maximum of this quantity is associated with a defined period

Required Information:

• Document certifying its address
• Profession or occupation

This level can only be reached by clients if address document is approved. For this purpose, CRYPTOMKT is in charge of approval by taking into account characteristics such as: integrity, appearance, time of issue and consistency with personal data and client information.

1.1.4. Trader Plus: user enabled to make money deposits and withdrawals in legal currency in large amounts

Required Information:

• Trader Declaration.

The client could only reach this level once its Trader Declaration is approved. This declaration is an affidavit where it is stated: origin and destination of funds, origin and destination of cryptocurrency that are traded in the platform, expected quantities to be deposited and withdrawn, among other additional records.

Besides Trader Declaration, CryptoMKT has the right to require any document considered necessary to validate all the provided information, depending on the client’s country of residence, destination(s) and purpose(s) of its operations and operation’s amount.

1.2. KYC Legal Persons.

Even though documents required to open an account may vary depending on the country and on the type of client, CryptoMKT will require this information to be validated.

• Legal current existence of the legal person.
• Activity or developing business.
• Validated and in force registration in their country tax records.
• Rights depending on the person who represents the clients when concluding the Terms of Service and Privacy Policies.
• Legal entity address.
• Final payee identification.
• Partners and owners.

The legal entity client can only make operations by means of the corporate account once all documents are approved. CRYPTOMKT will also require a form “Trader Declaration” to be filled. Without limiting the foregoing, it can always be required either at the opening of the account or later further information and records, in accordance with the client profile.

2. ABOUT POLITICALLY EXPOSED PEOPLE (PEP) AND CONNECTED PEOPLE

Within the framework of the Client Due Diligence, CryptoMKT has adopted the following concrete measurements:

2.1. System Implementations to identify whether a prospective client, a client or final payee of a legal entity or CryptoMKT supplier is or not a PEP or connected with a PEP.

2.2. Protocol implementation approved by the board to open and follow-up accounts whose account holder is a PEP or connected with one.

2.3. Information requests or records to identify fund origins of PEP clients or connected with one, besides this, reasons for performing operations.

3. PERMANENT RECORDS

CryptoMKT keeps in electronic format, records that indicate the national laws where they are applicable in order to accurately fulfil obligations when applicable. The existence of this records arise from the need to detect evidence that would identify suspicious actions which will then be created and updated into the form of risk profiles.

This record information is kept within the legally prescribed period. CRYPTOMKT, as it is important to point out, doesn’t have a Register of Cash Operations due that it doesn’t accept cash either as paper or plastic currency.

III. MONITORING PROCEDURE AND OPERATION ANALYSIS

For CRYPTOMKT, it is essential to monitor and asses on regular basis its Prevention system through either an appropriate follow-up or by controlling detected activities as potentially risky. This is done so as to guarantee that its design and functioning is effective and meets the platform context.

Monitoring is under the Compliance Officer and his Team responsibility, and it is led to support functioning and operation of procedure and policies of prevention.

Within the same purpose, the Compliance Officer, together with the Head of Customer Service and its Team, will be in charge of monitoring operations done in the platform and of creating risk profiles specific to the field of cryptocurrencies. In order to achieve an effective monitoring, the Compliance Officer uses different tools which follow-up operations done in legal currency and in cryptocurrencies.

Thus, with reference to prevent asset laundering, it is essential to detect and report in time operations that could enter laundering money in the economy, CRYPTOMKT has implemented a set of measurement to its identification on a timely basis. Such is the case of a warning sign system, auditing on monthly basis or every three months, technological tool deployment, creation of risk profiles, requirements of information and many whistle- blower channels.

IV. OPERATION PROHIBITION

CRYPTOMKT will not be able to operate neither with shell banks nor with countries, entities and people included on OFAC lists or on United Nations settlements.

V. ABOUT CRYPTOCURRENCY THAT IS TRADED IN CRYPTOMKT

To select digital assets that will be traded in our platform, a process is activated that includes many factors. Among them; openness, technology, legality, government, scalability, reputation, liquidity, work roadmap, international presence, history, distribution, economic incentive such as inflation, utility and token type.