Prohibited Activities and Sectors

Prohibited Activities and Sectors

As part of our commitment to ensure compliance with our regulatory obligations and taking into account the risks involved in our services, Attrus has decided to place limitations and restrictions on specific business activities and sectors in which it and/or its Customers may operate. Any requests from Customers involved in the industries or activities listed below will be automatically rejected. Attrus cannot engage in commercial relationships with Clients who fall into the following situations:

• Adoption agencies;

• Alcohol, tobacco, nicotine or related products;

•Asbestos;

• Biological material of human origin (i.e.: hormones, human hair, etc.);

• Products or services for augmentation of body parts;

• Cash, paper money or any other bearer securities;

• Controlled substances and/or other products that pose a risk to consumer safety;

• Corrosive and explosive materials, compressed gases and aerosols, flammable liquids, oxidizing materials, flammable solids;

• Debt collection;

• Drugs or any type of illegal substance, including products that simulate the effects of any illegal drug; as well as any substances for the manufacture of drugs

and any equipment used to produce, compound, convert, process, prepare, conceal, and consume illicit drugs;

• Live animals;

• Medical practices;

• Military weapons and ammunition, simulacra and controlled equipment (archery, sporting weapons, hunting equipment, replica weapons, etc.);

• Multi-level marketing companies, pyramid schemes, Ponzi schemes or any other

program that promises profit or cashback with any term;

• Pawn shop;

• Poisons: liquid, solid or gaseous;

• Political parties (i.e.: campaign financing, donations and subscriptions to politicians, political causes);

• Precious metals, jewelry or any other product manufactured from these materials - Purchase or exchange;

• Products prohibited by the local Public Health Agency, Health Authority or equivalent (i.e., Anvisa, Cofepris, ISPCH, etc.);

• Products related to pedophilia, child pornography, nudity of minors, as well as articles that involve in any way the illegal participation of minors;

• Products that infringe trademarks, patents, copyrights, and other intellectual property rights (i.e.: counterfeit products);

• Prostitution agencies;

• Radioactive material;

• Religious institutions (donations or charities);

• Schedule appointments for public services;

• State-owned companies;

• Products that are stolen, stolen in any way, smuggled, counterfeit, adulterated or replicated;

• Any other product, service, or activity in jurisdictions where it is considered illegal.

ESTRICTED AND INCREASED MONITORING JURISDICTIONS

The following is a comprehensive table that displays ATTRUS’s compliance with FATF/GAFI and OFAC standards by keeping up with the current sanctioned jurisdictions lists.

The table columns refer to:

Banned:

The verdicts of immediate reproval to any prospect client or supplier based on the jurisdictions in question, marked as “Banned” as seen above.

Low Risk:

a. Countries that have submitted a high-level written political commitment to remedy identified high deficiencies and who have developed an action plan with the FATF, or –

b. Countries that have submitted a high-level political deficiencies written commitment to remedy identified and who have developed an action plan with the FATF.

Medium Risk:

Countries/territories with strategic weaknesses in their measures to combat ML/TF, but already subject to close monitoring by the FATF (having assumed, at the highest level, the commitment to adopt an action plan developed in conjunction with the FATF.

High Risk:

High-risk countries that currently have persistent and substantial money laundering and terrorist financing problems, having repeatedly violated the obligation to remedy identified deficiencies within the FATF.

ATTRUS may choose to engage in business with entities located on the jurisdictions presented above, provided the appropriate due diligence level is applied, directly proportional to the risk presented. However, it should be noted that FacilitaPay does not encourage the sales of its services being targeted to customers based in such jurisdictions.

The entity in question should be able to provide a commitment plan to adhere to international compliance requirements, as a part of the enhanced due diligence process.

The banned jurisdictions shall not be considered, and business discussions within them are expressly forbidden.