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AML Policy Compliance Program

#### I. Introduction

NexTech Blockchain e Investimentos Ltda. ("NexTech") is committed to the highest standards of Anti-Money Laundering (AML) compliance and seeks to prevent the misuse of its platform and services for money laundering or illicit activities. We uphold a stringent AML Policy to safeguard our community, adhere to legal obligations, and maintain the integrity of our blockchain and investment services.

#### II. Compliance with Laws

NexTech strictly adheres to all applicable laws and regulations concerning AML and Counter-Terrorist Financing (CTF) across jurisdictions we operate in, including but not limited to, the Bank Secrecy Act (BSA), the USA PATRIOT Act, and international AML standards.

#### III. Risk-Based Approach

NexTech adopts a risk-based approach to AML compliance, which involves identifying and assessing the money laundering and terrorist financing risks associated with our users and transactions.

#### IV. Know Your Customer (KYC) Procedures

We implement robust KYC procedures to verify the identity of our users and assess the risks associated with their activities. These procedures include collecting and verifying user identification information, monitoring transactions, and reporting suspicious activities.

#### V. Third-Party Services

NexTech partners with reputable third-party services, CompyCube and MetaMap, to conduct AML verifications every three months. These services aid in the identification and monitoring of suspicious activities, ensuring a thorough analysis and assessment of AML risks.

#### VI. Monitoring and Reporting

NexTech conducts continuous monitoring of user transactions to identify and report suspicious activities. We promptly report any suspicious transactions to the relevant authorities in compliance with applicable regulations.

#### VII. Record Keeping

NexTech maintains records of all user identification information, transaction data, and AML verifications for a minimum of five years, as per regulatory requirements.

#### VIII. Training and Awareness

All NexTech employees undergo regular AML training to stay abreast of the latest developments, risks, and compliance requirements in the crypto asset environment.

#### IX. Policy Review and Updates

NexTech regularly reviews and updates its AML Policy to address changes in regulations, risks, and business activities. We encourage users to review this policy periodically for any updates.

#### X. Contact Information

For any queries or concerns regarding our AML Policy, please contact our Compliance Officer at

#### XI. Conclusion

NexTech Blockchain e Investimentos Ltda. is committed to maintaining a safe and compliant environment for our users and stakeholders. We continuously strive to prevent, detect, and report money laundering and other illicit activities to uphold the integrity of our platform and contribute to the global fight against financial crime.

This document is for informational purposes only and is subject to change. NexTech reserves the right to modify this policy at any time without notice.

_Date of Last Update: 11/03/2023

© 2023 NexTech Blockchain e Investimentos Ltda. All Rights Reserved.

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