Know Your Customer (KYC) Policy

DEUNA's Know Your Customer (KYC) policy is designed to ensure that our company
complies with all applicable laws and regulations related to the identification and verification of our clients. This policy is essential to prevent fraud, corruption, money laundering, terrorism financing, and other illegal activities.

This policy applies to all DEUNA employees, directors, agents, and anyone acting on
behalf of the company. It also encompasses all products and services offered by DEUNA and applies to both new and existing clients.

Objectives:

• Legal Compliance: Ensure compliance with all local and international laws and
  regulations related to KYC and Anti-Money Laundering (AML).
• Fraud Prevention: Protect the company and its clients against fraud and other
  illicit activities.
• Customer Identification: Establish clear procedures for identifying and verifying
  clients' identities.
• Ongoing Monitoring: Implement mechanisms for the continuous monitoring of
  clients' transactions and activities.

Key Concepts

1. Fraud:
   Fraud involves an intentional act of deception with the aim of gaining an unfair or illegal advantage, causing harm to another person, organization, or entity. This deception can include manipulation, falsification, omission of critical facts, or any dishonest conduct used to induce a victim to act against their own interests.
2. Corruption:
   Corruption is the abuse of power, responsibilities, or resources, either public or private, to obtain undue personal benefits. This behavior includes bribery, embezzlement, favoritism, and nepotism, and it has serious consequences for society, the economy, and governance.
3. Money Laundering:
   Money laundering is the process of disguising the origin of funds generated through illegal activities such as arms trafficking, corruption, fraud, or human trafficking. The goal is to make assets obtained through illicit activities appear legitimate and integrate them seamlessly into the financial system.
4. Terrorism Financing:
   Terrorism financing refers to any form of financial support, direct or indirect, provided to individuals, groups, or activities associated with terrorism. This support includes the provision of funds or financial resources to plan, prepare, carry out, participate in, or facilitate acts of terrorism.

KYC Procedures:

1. Customer Identification: Before establishing a business relationship, DEUNA
   must obtain the following minimum information from each client:
   1. Natural Person:
      1. Full name
      2. Date of birth
      3. Nationality
      4. Proof of address (no older than 3 months)
      5. Occupation
   2. Legal Entity
      1. Company Name
      2. Proof of address (no older than 3 months)
      3. Articles of incorporation and extraordinary resolutions
      4. Identification of shareholders and legal representatives
      5. Contact information (phone, email)
2. Client Verification: The information provided by clients must be verified
   through the review of official documents and reliable sources. DEUNA must use public and private databases, as well as technological tools, to validate the authenticity of the documents and information.
3. Risk Assessment: All clients must be evaluated to determine their risk level,
   which may include:
   1. Assessing the client's geographic location.
   2. Reviewing sanction lists and Politically Exposed Persons (PEP) lists.
   3. Analyzing the nature of the business relationship and expected
      transactions.
4. Monitor and Review
   1. Continuous Monitoring: Systems must be implemented to monitor
      transactions and detect suspicious activities.
   2. Periodic Review: Client accounts and information must be periodically
      reviewed and updated to ensure their accuracy and relevance.
5. Reporting Suspicious Activities: Any detected suspicious activity must be
   immediately reported to DEUNA’s Compliance Officer, who is responsible for investigating the activity and, if necessary, reporting it to the relevant authorities.

Training

All DEUNA employees and agents must undergo periodic training on KYC policies and
procedures, as well as applicable AML regulations. This training should include:

• Methods for client identification and verification.
• Techniques for detecting and reporting suspicious activities.
• Updates on changes to applicable laws and regulations.

Responsabilidades

• Directors and Managers: Ensure that the KYC policy is implemented and
  followed across all company areas.
• Compliance Officer: Oversee the implementation of the KYC policy, conduct
  internal audits, and report suspicious activities to authorities.
• Employees: Comply with all KYC procedures and report any suspicious
  activities to the Compliance Officer.

Policy Review

This policy will be reviewed and updated at least once a year or as needed to comply
with changes in applicable laws and regulations. Revisions must be approved by DEUNA’s Compliance Committee.