AML POLICY - MXT DIGITAL

Operating in the digital asset sector requires a firm commitment to legality and ethics. For this reason, MXT-DIGITAL has implemented a Comprehensive Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CFT), designed in accordance with current regulations and the highest standards in the field.

This policy aims to ensure a controlled, secure environment that complies with applicable regulatory obligations.

This document establishes the principles, operational guidelines, and internal mechanisms necessary to identify, mitigate, and timely report any suspicious activity related to money laundering or terrorist financing on our platform.

Customer Identification and Due Diligence

MXT-DIGITAL has developed a rigorous Know Your Customer (KYC) procedure as a core component of our Due Diligence approach. This process is applied proportionally based on the risk level assigned to each customer and includes, at a minimum, the following elements:

Collection and documentary verification of:

• Valid government-issued photo ID.
• Proof of address dated within the last three months.
• Information regarding source of funds and nationality.
• Automated and manual screening against official and restrictive lists, including:
• OFAC (Office of Foreign Assets Control) list.
• Politically Exposed Persons (PEP) lists.
• UN Security Council lists, and other national and international sanctions lists.
• Cross-verification of wallet addresses associated with clients to detect prior exposure to illicit activities or links with sanctioned entities.

For clients classified as high risk, an Enhanced Due Diligence process is applied, which includes ongoing monitoring and periodic reviews of the customer’s transactional profile.

Transactional Monitoring

MXT-DIGITAL operates an Automated Transaction Monitoring System designed to detect significant deviations from a client’s risk profile. This system includes:

• Analysis of transaction volume, frequency, behavior, and typology.
• Detection of unusual patterns or signs of structuring, smurfing, layering, triangulation, or other techniques commonly used to conceal the origin of illicit funds.

Information Retention MXT-DIGITAL ensures the complete and secure retention of information obtained during the identification process and user transactions for a minimum period of five (5) years.

Documents and records are stored in secure environments with backup systems and restricted access, ensuring their availability for inspection, auditing, or cooperation with competent authorities.

Training and Compliance Culture

MXT-DIGITAL has implemented a Mandatory Internal Training Program for all personnel, including senior management, operational areas, and key compliance-related roles. This program includes:

• Initial and ongoing training on AML/CFT regulations.
• Practical workshops on identifying red flags and handling suspicious transactions.
• Regular updates on regulatory changes, emerging risks, and industry best practices.

We foster a compliance-driven culture throughout the organization, based on the values of integrity, legality, responsibility, and zero tolerance for the illicit use of our platform.

Policy Review

This policy will be reviewed annually or whenever significant changes occur in the regulatory framework or in MXT-DIGITAL’s operations.

Reviews will be carried out by the Compliance Committee, with the support of the Compliance Officer, ensuring the constant adaptation of our internal regulatory framework to the actual risks of the business.

MXT-DIGITAL reaffirms its institutional commitment to preventing money laundering and terrorist financing by designing and implementing a comprehensive, efficient, and internationally aligned compliance system. By fulfilling our regulatory obligations, we actively contribute to the integrity of the financial system and the strengthening of trust in the digital asset ecosystem in Mexico.

UPDATED AS OF MAY 2025