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Manual for thePrevention of Money Launderingand Countering the Financing of Terrorism

Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism

Table of contents

I.

Introduction ............................................................................................................................................ 4

II. Enforceable law ......................................................................................................................................... 5
A. International law .................................................................................................................................... 5
III. Definition of money laundering and financing of terrorism ............................................................ 6
A.

Definition of Money Laundering and Laundering of Assets ...................................................... 6

B.

Definition of Financing of Terrorism ...............................................................................................7

Important notice ............................................................................................................................................ 8
IV. Company identification .......................................................................................................................... 9
V. Customer identification and know your customer policy ................................................................ 10
A.

Definition of Customer .................................................................................................................... 10

B.

Customer Acceptance Policy ......................................................................................................... 10

C.

Risk Factors ......................................................................................................................................... 11

D.

Customer identity verification ....................................................................................................... 13

E.

Registration Process ........................................................................................................................ 14

F.

Funding Limits ................................................................................................................................... 17

G.

Sanctions List Screening ................................................................................................................. 18

H.

Updating information and documentation ................................................................................. 18

I. Follow-up regarding the Relationship with the customer ............................................................ 18
VI. Monitoring policy and suspicious transactions reports .................................................................. 20
A. Definition of Suspicious Transactions ............................................................................................. 20
B. Detection and control of Suspicious transactions ........................................................................ 20
C.

Investigation Procedure .................................................................................................................. 21

D. Suspicious Transactions Report (STR) to the Money Laundering Reporting Office ofPanamà (Reporting Office) ..................................................................................................................... 22
E. Confidentiality ...................................................................................................................................... 22VII. Record keeping ..................................................................................................................................... 23
VIII. Staff training policy ............................................................................................................................. 24
IX. Register Producer .................................................................................................................................. 25
X. Logistics ..................................................................................................................................................... 26
IX. Organisational structure ....................................................................................................................... 27
A.

The Committee for the Prevention of Money Laundering and Terrorism Financing ......... 27

B.

Compliance Officer ......................................................................................................................... 28

X. Internal control System .......................................................................................................................... 29
XI. External control ....................................................................................................................................... 31

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I. Introduction

In response to the international community’s growing concern about the problem ofmoney laundering and the financing of terrorism, many coun tries around the world are enacting
or strength ening their laws on the subject.
Along with the society and the authorities of various countries, LESCOVEX PANAMA, INC
and Blackhole Consulting OÜ (hereinafter “Lescovex” or “The Company”) recognizes theimportance of the fight against money laundering and terrorism financing, since it impacts
fundamental aspects of social life.
Lescovex understands that the best way to fulfill this commitment is to establish effective
internal policies and procedures that are conducive to:1) Carrying out the activities and services provided in accordance with strict ethical standards
andcurrent law regulations;2) The implementation of codes of conduct and monitoring and reporting systems to preventthat
The Company is used for money laundering and terrorism financing;3) Ensuring that all the employees observe “Know Your Customer” policies and procedures; 4)
Strictcompliance with applicable anti-money laundering and terrorism financing laws, as wellas with the recommendations issued on this subject by the International Financial Action Task
Force and international and Panamà authorities.
As a result, Lescovex management and employees must be vigilant for any suspicious
activity and report it immediately to the established internal bodies, in accordance with specified
policies and procedures, so that they may in turn notify the relevant authorities.
Only through the commitment of all Lescovex executives and employees will it bepossible to guarantee that the products being marketed and the services being provided cannot
be used for money laundering or terrorism financing purposes.
Adherence to this policy is absolutely fundamental to ensuring that Lescovex complies
fully with anti-money laundering and terrorism financing legislation. The Company should
therefore be actively involved in the policy’s implementation and development.
This policy establishes minimum standards which Lescovex should observe and is definedaccording to the principles contained in the 49 Recommendations of the International Financial
Action Task Force (FATF), Law No. 23 dated 27 April 2015 Adopting measures for the PreventionofMoney Laundering, Terrorism financing and Financing of Proliferation of Weapons of Mass
Destruction and other provisions and the obligations and principles of the European Parliamentand Council Directive 2005/60/RC dated 26th October 2005, regarding the prevention of theuse of the financial system for money-laundering and the financing of terrorism.

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Compliance with the contents of this Manual is required for all LESCOVEX PANAMA, INC
executives and employees. Non-compliance with the criteria and guidelines contained in thisManual will lead to the corresponding responsibilities and sanctions.
The contents of the Manual will prevail over other internal regulations that could comeinto conflict with these, except for those that establish stricter conduct code and/or prevention
measures.

II. Enforceable law

A. International law
The Financial Actions Task Force (FATF): It is the main international body established tocombat money laundering and terrorist financing. It has issued the “Forty Recommendations”
report and the “Nine Special Recommendations on Terrorist Financing” report. The international
community considers these to be the universal standards;•

The Basel Committee: It develops standards, guidelines and best practices for a wide
range of banking supervisory matters. It has issued three documents about the prevention ofmoney laundering:•

1) “Prevention of Criminal Use of the Banking System for the Purpose of Money Laundering”(1988); 2) “Customer Due Diligence” (2001); and 3) “Know your Customer Risk Management”(2003);
Wolfsberg Group Principles: Statement Against Corruption (2007); Risk Based Approachfor Managing Money Laundering Risks (March 2006); Statement on Monitoring Screening
Transactions (September 2003); Anti-Money Laundering Principles for Correspondent Banking(November 2002); Statement on the Financing of Terrorism (January 2002); AntiMoney
Laundering Principles for Private Banking (revised version May 2001);•

Directive 2005/60/EC of the European Parliament and of the Council dated 26th October2005 on the prevention of the use of the financial system for the purpose of money launderingand terrorist financing;•

Commission Directive 2006/70/EC dated 1st August 2006 laying down implementing
measures for Directive 2005/60/EC of the European Parliament and of the Council with regards
to the definition of ‘politically exposed person’ and the technical criteria for simplified customer
due diligence procedures and for exemption on grounds of a financial activity conducted on an
occasional or very limited basis.

•

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III. Definition of money laundering and financing of terrorism
A. Definition of Money Laundering and Laundering of Assets

Asset laundering is also referred to as money laundering, whitewashing, laundering of
capital, legitimizing capital, laundering of assets, etc.
All of these terms refer to the same process that is defined by the art.4 of the Panamà“AntiMoney laundering Law” as: “Money Laundering: predicate offensetypified at the Criminal
Code of the Republic of Panama.
The Directive 2005/60/EC of the European Parliament and of the Council dated 26th
October 2005 on the prevention of the use of the financial system for the purpose of money
laundering and terrorist financing, describes Money Laundering as the following activities:“The conversion or transfer of property, knowing that such property is derived from criminal activity
or from an act of participation in such activity, for the purpose of concealing or disguising the illicit originof the property or of assisting any person who is involved in the commission of such activity to evade thelegal consequences of his action.

1.

The concealment or disguise of the true nature, source, location, disposition, movement, rights
with respect to, or ownership of property, knowing that such property is derived from criminal activity orfrom an act of participation in such activity.

2.

The acquisition, possession or use of property, knowing, at the time of receipt, that such property
was derived from criminal activity or from an act of participation in such activity;

3.

Participation in, association to commit, attempts to commit and aiding, abetting, facilitating andcounselling the commission of any of the actions mentioned in the foregoing points.”

4.

As for the United Nations, Money Laundering is: “The surreptitious introduction of illegallyobtained funds into the legitimate channels of the formal economy”.
The International Monetary Fund considers that “Money laundering is the process through whichassets obtained or generated as a result of criminal activities are transferred or disguised, withthe purpose of concealing their ties to crime”.
Generally speaking, the money laundering process, very closely linked to the financing ofterrorism, consists of three stages:
Placement: Introduction of cash originating from criminal activities into financial or non-financial
institutions.
Concealment: Separating the proceeds of criminal activity from their source through the use oflayers of complex financial or non-financial transactions. These layers are designed to hamper
the control of the funds, disguise their origin and provide anonymity.
Integration: Placing the laundered proceeds back into the economy in such a way that they reenter the financial system as apparently legitimate funds.

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Given the nature of the financial operations used for laundering money, it is possible that
financial entities may be used inadvertently as agents for investing funds coming from illicit or
criminal activities, jeopardizing the stability, reliability and credibility of the institutions involved.

B. Definition of Financing of Terrorism

The United Nations has defined terrorist financing as follows:“A person by any means, directly or indirectly, unlawfully and willfully, provides or collects fundswith the intention that they should be used or in the knowledge that they are to be used, in fullor in part, in order to carry out:(a) An act which constitutes an offence within the scope of and as defined in the existingtreaties; or(b) Any other act intended to cause death or serious bodily injury to a civilian, or to any
otherperson not taking an active part in the hostilities in a situation of armed conflict,when the purpose of such act, by its nature or context, is to intimidate a population,or to compel a government or an international organization to do or to abstain fromdoing any act.”
In this sense, the Directive 2005/60/EC of the European Parliament and of the Council
dated 26th October 2005 regarding the prevention of the use of the financial system for the
purpose of money laundering and terrorist financing, describes Terrorism Financing as follows:“the provision or collection of funds, by any means, directly or indirectly, with the intention thatthey should be used or in the knowledge that they are to be used, in full or in part, in order tocarry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision
2002/475/ JHA of 13th June 2002 on combating terrorism”.

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Important noticeBusiness Purpose: The Company shall have as its main purpose the operating of a SWAP platform
based on blockchain technology in which different goods may be exchanged, as set forth on thewebsite: www.lescovex.com.
All FIAT-based deposits (such as $, €... understood as: Fiat money, in short, whose value does
not derive from the fact of being a physical good or merchandise, but from being issued andbacked by a government.) will be carried out by the bank of each client so by a third party. In thissense, the responsibility to identify and check the AML will be made at the origin at the time ofmaking the transfer from the FIAT customer’s account to Lescovex.
If in this document there is any discrepancy related to the identification of the clients, thepresent writing prevails:
Lescovex will identify its clients in specific cases and / or under suspicious behavior, it is in thissense that Lescovex can identify by claiming information from its clients, checking with Black
lists and performing video identifications if necessary and claiming all the necessary information.
All this process is described in this document.
In that sense and as mentioned, Lescovex is a platform based on SWAP and we will not store
tokens or have third-party deposits, only in the case of fiat currencies.
Countries without service: Republic of Panamá, Venezuela, Cuba, Switzerland.
Regarding the Swap and the Pool’s:
https://uniswap.org/disclaimer/

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IV. Company identification
Lescovex Group

Company Name: LESCOVEX PANAMA, INC

Registered Office: 71 Street, San Francisco, N.º 109, Panamá City, Panamá
Register Number: 18699-Company Name: Blackhole Consulting OÜCompany Registration Number: 16240154
Registered address: Harju maakond, Kesklinna linnaosa, Tornimäe tn 5, 10145, Tallin, Estonia
Contact
Email: support@lescovex.com
Phone number: +507 6845 6529

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V. Customer identification and know your customer policy

A. Definition of Customer

Regardless of the fact that there is no official definition of customer in the
aforementioned regulatory bodies, to the effect of this Manual we consider by “Customer” thefollowing: “any person, natural or legal entity, who has successfully passed all the Know Your Customer and Due
Diligence procedures established by The Company and with whom Lescovex has a business relationship, offered under
the scope of activities provided proper to the field of its expertise and in compliance with the established legal andregulatory framework”.

B. Customer Acceptance Policy

Lescovex shall lay down a customer acceptance policy, which shall include a customer
classification attending to different risk factors in which they may incur (activity carried out,
country or residence, etc.). In that sense, The Company shall not admit as customer nor,
therefore, establish a business relationship with the following persons, whether individual or
legal entities:

1. Those persons about whom information is available indicating possible involvement incriminal activities or which are included in any public list concerning criminal activities(such as US Office of Foreign Assets Control –OFCA–, etc.), mainly related to drugtrafficking, terrorism and organized crime;

2. Persons with businesses that due to the nature of their business make it impossible toverify its legitimacy or the source of its funds, or those whose funds are inconsistent
with their financial status;

3. Persons who refuse to provide the information or documentation required to obtain
verification of the activities or the source of the funds or who provide documentationof doubtful legality or legitimacy or which has been manipulated;

4. Legal entities whose shareholders or control structure cannot be determined;
5. Casinos, gambling/betting establishments, exchange offices, money transmitters andother similar entities that are not officially authorized;

6. Financial institutions resident in countries or territories without being physicallypresent there (also referred to as “shell banks”) and which do not belong to a regulated
financial group.

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On the other hand, the following persons, whether individuals or legal entities, shall only
be accepted as customers by The Company with prior authorization from the Compliance Officerof The Company:
Customers involved in the production or distribution of weapons or other militaryequipment;

1.

Duly authorized casinos, gambling establishments or Bureaux de change, moneytransmitters orother similar entities;

2.

Customers who are highlevel public officials and their family members or close
associates as defined in art.2a of the AMLA (Politically Exposed persons “PEṔs”).

3.

C. Risk Factors

For Money-laundering and Terrorism financing, The Company shall take into accountvarious risk factors when evaluating and verifying the information and documentation provided
by customers and, depending on these, Lescovex shall classify its customers as Low, Medium orHigh Risk Customers. The risk factors are, amongst others:
Geographic location: there are certain geographic locations considered as having a higher
risk for money laundering and terrorist financing, such as those that are not members of the
Financial Action Task Force (FATF), or regional FATF-like bodies or groups of similar nature; andthose countries subject to sanctions by the aforementioned groups for not being compliant, orfor not being sufficiently compliant, with FATF recommendations.

1.

Customers considered as high risk due to their geographic location are those who havesubstantial connections in a high risk country/city, that is to say:a) Those who hold property, residence, offices or headquarters in a high risk country;b) Companies which have the majority of shareholders or beneficiary owners located insuch countries;c) Any other substantial connections/links that might be identified.Although Nationality
is an important element it is not a determining factor for classifying someone as a highrisk customer.

Activity: There are certain business and/or industrial activities that due to their nature are
more likely to be used for money laundering and terrorist financing. Some activities consideredas high risk are as follows: Casinos, Gaming Centers, Racetracks; Financial Investment
Corporations (S.A.F.I.); Arms, weapons manufacturers, distributors and dealers; Precious metals
distributors and dealers; Professionals who act as intermediaries (lawyers or accountants thatmanage their customers’ funds in their accounts); etc.

2.

Clients may be considered High Risk Customers if possessing significant connections to activities
considered to be high risk. The Compliance Officer will have to determine whether theconnection is significant or not. There is always a significant connection if the firm is involved inor if a large portion of the firm’s turnover comes from high risk activities.

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Politically Exposed Persons (PEPs): Public corruption is considered to be a prominent
cause for money laundering. This is why having ties with people who hold or have held
prominent public functions or others who are closely connected to them (such as family
members or close associates) might pose a legal or reputa-tional risk to our Company. Politically
Exposed Persons (PEPs), as defined in art.2a of AMLA, are:1.

“a) Individuals who are or have been entrusted with prominent public functions by a foreign country, such asheads of state or of government, senior politicians at national level, senior govern-ment, judicial, military or
political party officials at national level, and senior executives of state-owned corporations of nationalsignificance (foreign polit-ically exposed persons);b)

Individuals who are or have been entrusted with prominent public functions at national level inPanama in politics, government, the armed forces or the judiciary, or who are or have been senior executivesof state-owned corporations of national significance (domestic politically exposed persons);c)

Individuals who are or have been entrusted with a prominent function by an intergovernmentalorganisation or international sports federations, such as secretaries general, directors, deputy directors andmembers of the board or individuals who have been entrusted with equivalent functions (politically exposed
persons in international organ-isations);”

Having business relationships with PEPs’ family members or close associates, or companies
controlled directly or indirectly by PEPs, represents risks to the reputation of The Company
similar to the damages caused to the reputation of PEPs themselves.
Materially: The materiality of the relationship with a customer is also a risk. In order toevaluate it, The Company will pay attention to the volume or amount of transactions channelled
through the Lescovex platform, the source of the funds and the funds in their financial status. A
limit to the funding will also be set in order to control those transactions, above which customers
must obtain an authorisation.

2.

Legal Entities: Relationships with legal entities may pose a risk for The Company, as
persons who directly or indirectly control those entities may use them to hide their identities
and carry out illegal activities related to money laundering or terrorism financing.

3.

In such cases, additional due diligence proce-dures are required in order to get information
about the beneficiary owners of the legal entity, the type of operations related to The Company,
the purpose of using the Lescovex platform, the source of the funds channelled throughLescovex, etc.
Beneficial owners are considered to be those natural persons who ultimately control thelegal entity in that they directly or indirectly, alone or in concert with third parties, hold at least
25% of the capital or voting rights in the legal entity or other-wise control it. If the beneficial
owners cannot be identified, the most senior member of the legal entity’s executive body mustbe identified.
In addition, for record-keeping purposes and to know our customers, we shall request
information that will allow us to not only identify and validate the identities of the Beneficiaryowners of the entity and the funds of the latter, but also to monitor their financial and businessactivity and the source of the funds channeled through Lescovex.

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D. Customer identity verification

The Company considers that the most effec-tive means of preventing the use of our services formoney laundering or terrorism financing is to identify and apply “know your customers”(hereinafter “KYC”) procedures, including enhanced due diligence for those customers
presenting higher risks, such as Politically Exposed Persons (PEPs), irrespective of whether they
are established customers or otherwise.
KYC and all due diligence procedures followed are not merely formal requirements thatcan be met by simply filling out a form. Nor is it a passive transaction whereby The Company
simply requests information and documentation and the Customer provides everything. Instead,
it is a dynamic, ongoing process through which The Companyrequests information, screens it tomake sure it is complete and then requests supporting documen-tation when it is appropriate
to do so. The informa-tion is then validated and finally all the documenta-tion and data collected
are evaluated to make sure they are consistent.
To verify the identity of the customer, The Company will apply various KYC
procedures if they are necessary:a) Paper-based verification:
This is the most common approach among digital assets exchanges across the globe.
Users must provide personal details and upload several related documents such as
passports, ID cards and proof of residence documents, which include bank statements orutility bills. Then, The Company verifies that all the personal details and submitted
documentation match with the information stored in the identification documents’Machine-Read-able Zone (MRZ).

b) Blockchain Certification Authority (BCA):
Another way of certifying the identity of customers is by using the Lescovex BCA
desktop application, which enables users to sign the KYC form with their qualified
electronic signature issued by an authorized entity, within which all the personal detailsof the customers are included.
BCA integrates a method to add trusted certifi-cation entities (e.g. governments andbanks) and their root certificates into a smart contract run on Ethereum’s blockchain. Lescovex
easily and securely adds these root certificates into the smart contract. Corporations andindividuals then submit their identity certificates that are verified by the BCA smart contract
once the root certificates and those submitted match.
Since encrypted root certificates belong to the public domain, it is not necessary to trust
the entity responsible for managing the contract. Anyone can query fingerprints vetted by asmart contract and, thereby, confirm whether they are the same as in the official website or
database available of the certification entity which issues those certificates.

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After recording the fingerprint and the public key of the certification entity, it is possible
to confirm, unequivocally, that the certificates submitted by users relate to the root certificates,
and thus to attest whether entities have performed the appro-priate controls necessary toauthenticate the iden-tity of any corporation or individual.
c) Video Identification:
Apart form the foregoing, in both cases Lescovex will carry out audiovisualcommunication (automatic vídeo recording) with customers to verify their identity. The
transmission will be recorded and filed in The Company’s database. Customers will have toanswer targeted questions related to the personal details they have provided in the KYC form
set forth in the following section. Additionally, they will have to show the documents uploaded
during the onboarding process, so that The Company can take a photograph of them during thetransmission. For that purpose, a facial recog-nition application called “Open Computer Vision”
will be used, which allows to take snap shots.
Before starting with the aforesaid procedure, The Company will have to obtain explicit
consent from the customer to carry out this communica-tion process, record it and takephotographs mean-while. If the consent is not obtained, the customer may ask to go through aconventional identification procedure, by which he or she will have to send an authenticatedcopy of an identification document by postal delivery or other equivalent methods.

E. Registration Process

Steps (not always needed):
Because when the customer send his fiat from his personal account the KYC and the AML will bedone in origin by the bank of the customer.
Sing up on the website www.lescovex.com: Customers will be asked to introduce a valid
emailaddress and password. Then a message will be sent to the email address provided so as tovalidate it by clicking on the link sent together with the aforesaid message.

1.

Once the email account is validated, customers will have to create a Lescovex account,either a “Personal Account” or a “Corporate Account”:

2.

A) PERSONAL ACOUNT: Customers must verify their identity by following the paper-based
procedure or by signing the KYC form with the BCA desktop application. In the former case,customers must fill in the “know your customer form” (here-inafter “KYC form”) displayed on thewebsite, where personal information shall be required, such as name, last name, ID or Passportnumber, date of birth, address, City, Nationality, occupation, monthly income, if they are
citizens, residents or tax payers of the USA, etc.
Those customers who have authenticated their identities by using the BCA proceduremust also fill in a KYC form to provide other information which is not included in the electronic
certificate, such as occupation, monthly income, annual income, etc.
In addition, customers must upload a colour copy of their ID or Passport together with aphoto of themselves. This documentation must have an MRZ (Machine-Readable Zone) and

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optical secu-rity features. The copy must be a readable copy so that the date of issue, date of
expiration and date of birth of the customer can be read easily. Expired or deteriorated copies
shall not be accepted.
They must also upload a bank statement, tax bill, utility bill or any other such document,
as a proof of residence. The address shown on this document must be the same as the one
indicated in the form filled out or in the BCA signature.
Finally, aside from the foregoing, identifica-tion will be channelled via audiovisual realtime (live transmission) communication between the customer and The Company. Thisaudiovisual interview will be made using Skype or the Google Hangout application. Explicit
consent must be obtained from the customer before starting the video interview so as toconduct this audiovisual identification, to record it and to take photos during the process.
Customers will have to answer targeted ques-tions related to the information provided
in the KYC form, as well as to show the documents uploaded, so that The Company can check
whether the documents match with those provided during the onboarding process by reading
and decrypting the information stored in the document’s Machine-Readable Zone. To that
effect, Lescovex will use “open computer vision” to take snapshots of the interview when thecustomer is showing the documents, so as to get facial recognition of the customer and to checkthe authenticity of the documents shown.
Customers may ask for any other conven-tional channel in order to carry out theverification process, such as sending an original notarized copy of their documents by postaldelivery.
In some cases, and due to the type of customers, especially those who might fall under
one of the risk factors categories set forth before, The Company may enhance the due diligenceby asking for more information or documentation in order to decide whether or not to admit
them as customers.
B) CORPORATE ACCOUNT: Firms must also verify their identity, either by using the paper-based
procedure or by using the BCA procedure. If they choose the first option, the person who isacting on behalf of the firm will have to fill out the KYC form for Corporate Accounts displayedon the website, where, among other things, the following informa-tion will be required:

1) Firm’s name;2) Firm’s registration number or Tax ID, if different;
3) Firm’s website (URL);
4) Registered address;
5) City;6) Postal Code;
7) Country;
8) Main purpose of the account:(i) Accepting or converting payments from customers for services rendered or goods
sold;(ii) Depositing or withdrawing funds to busi-ness accounts;(iii) Managing funds of other individuals;(iv) Any other business activities (must be specified).

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As in the foregoing case, when users verify their identity through the BCA procedure, theymust also fill out the KYC form in order to provide the infor-mation that is not obtained throughthe aforemen-tioned procedure.
Apart from that, Lescovex’s support staff shall send a message to the contact email
address provided, asking for more information and docu-mentation to verify and validate thecorporate customer. This documentation could be sent by postal delivery, provided it is theoriginal documentation, or by email, provided it is signed with a qual-ified electronic certificate
pursuant to the Federal law on certification services in the area of elec-tronic signature dated
19th December 2003:• Powers of attorney of the person who is acting on behalf of the corporate customer
duringthe creation process of the corporate account. If it is the firm’s director, anotarized document of the appointment must be provided;• Attestation of the entry in the appropriate register (normally, the Commerce Register);•
Memorandum of Association and Corporate bylaws or articles of association;• Copy of
the taxpayer register;• Statement of the director or the board of direc-tors’ agreement by which it is expressly
declared that there is the will to acquire LCX token from Lescovex. A copy of the ID(front and back) or passport must be attached to this statement.
• Affidavit stating the following:- Business activity and services provided;- Typical customer profile;- Type of payment systems accepted and the price of the services;- Specification of the purposes of opening an account in Lescovex and using its
services;- The type of trading that is going to be carried out on the Lescovex platform;- Identification of the shareholders, primarily the beneficial owners, considering
themto be those natural persons who ultimately control the legal entity in thatthey directly or indirectly, alone or in concert with third parties, hold at least 25%of the capital or voting rights in the legal entity or otherwise control it. If thebeneficial owners cannot be identified, the most senior member of the legal
entity’s executive body must be identified (full first and last names; address;
postal code; ID –front and back– or pass-port number; Readable copy of the ID
or Passport).

- Identification of the firm’s Directors (full first and last names; address; postal
code;
ID or passport number; Readable copy of the ID or Passport);- Source of the firm’s funds;- Name, address and SWIFT code of the legal entity’s bank;16

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Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism- If the business is AML regulated, the policy must be stated, as well as how thefirm performs KYC for the customers and any other due diligence measure.
Additionally, AML and CFT Policy must be provided;- Estimated monthly volumes, amount in USD (last two balance sheets must be
attached);- Financial situation (balance sheet or any other related documents may berequired);-Declaration, if applicable, that the firm has another account in othercryptocurrency exchanges;-How users can normally reach the services provided;

Depending on the characteristics of the firm and any other circumstances, Lescovex may
enhance the due diligence and ask for any other information and documentation which isdifferent to what has been set out before.
Apart from the foregoing, audiovisual identifica-tion through the process described in theprevious section (Personal Account) will be carried out to check the identity of the person who
is acting on behalf of the corporate customer.

F. Funding Limits

Daily Limits

Monthly Limits

Deposit Fiat

600 USD

2500 USD

Withdraw Fiat

600 USD

2500 USD

In any case, if Lescovex identifies any suspi-cious transactions, it will ask the customer for more
information or documentation, and if neces-sary, a report will be filed with the Reporting Office.
For both personal and corporate accounts the deposits and withdrawals of Fiat will only beallowed from and to their own bank accounts, and never to third party accounts.
Regarding the SWAP of tokens Lescovex will not have any kind of deposits or withdrawal limits
because it’s a swap process. So Lescovex will not have any time any token of anybody. It’s just a
SWAP.

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G. Sanctions List Screening

The documentation and information provided by the customers will be verified andevaluated by The Company, namely by the Compliance Officer. Customers who have one orseveral risk factors and those who the Compliance Officer considers to do so, will have to provide
more documentation and information so that the Compliance Officer can decide whether or not
to accept them as customers.
Before deciding about whether or not a customer should be accepted, and in order tocomply with the customer acceptance policy stated in this section, the Compliance Officer will
check all persons, natural or legal entities, using the watchlists. If a customer is found to be on
one of the watchlists, all ties of that potential customer with The Company will be terminatedand a report to the Reporting Office in Panamà will be issued. If any potential customer is
included in the PEPs list, the Compliance Officer’s approval will be necessary.

H. Updating information and documentation

The information and documentation provided must be complete, accurate and current, andmust be kept up-to-date at all times so that it complies with the requirements of authenticity
and certainty, as long as the customer continues to be a user of the services provided by
Lescovex, being in all cases the customer’s responsibility the lack of updating and theconsequences that may arise from it.
A customer’s information and/or documenta-tion must be updated annually or under oneof the following circumstances:a) Lescovex modifies its customer identification regulations;b) If customer information is insufficient or out of date;c) At the request of the Compliance Officer within the framework of an ongoinginvestigation;d) At the request of the auditors;f) If there are any significant changes in the customer’s behavior patterns.
No transactions will be carried out with the customer if their identification information ispending or out of date.

I. Follow-up regarding the Relationship with the customer
The type of transactions the customer conducts or requests as well as the amounts
involved in such transactions should always be controlled to make sure that they are consistent
with the customer’s business activity and the information provided. If the documentation
available does not validate such transactions then appropriate records must be obtained in orderto do so.

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Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism“Know Your Customer” should be enforced throughout the relationship with thecustomer, not just at the beginning of it. The factors to monitor are: types of transactions
conducted, amounts involved and how these transactions are carried out.

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VI. Monitoring policy and suspicious transactions reports

A. Definition of Suspicious Transactions“Those transactions that, considering the prac-tices and customs of the business activity
in ques-tion, seem unusual, appear to serve no financial, business or other legal purpose and are
extremely complex for no reasonable explanation as well as those financial transactions thatinvolve funds of dubious source.”

B. Detection and control of Suspicious transactions
Irrespective of the funding limits set forth in the previous section, Lescovex will carefully
examine all the operations and trasactions chan-neled through the platform in order to detect
any unusual or suspicious transactions. To determine what is unusual or suspicious about atransaction, Lescovex will mainly pay attention to the trans-actions which show a lack ofcorrespondence with the volume of activity or previous operational records of the customer,
provided that there is no economic, financial, business or legal purpose for carrying them out,
based on the characteristics and business-financial profile of the customer set during theregistration process.
In addition, no transaction of Fiat to third parties will be allowed on the Lescovex
platform. It will solely permit deposits or withdrawals of Fiat that are made with the customer’sbank account. If several people own the bank account, these others will have to be identified
and will have to follow the KYC procedure, so that The Company can know at any time who they
are and screen them on any sanctions list.
Thanks to Blockchain technology, Lescovex will be able to examine, analyse and trace all
the transactions performed, knowing at any time all the circumstances related to them. Thereby,
the system will verify several aspects of each trans-action made, such as the amount or thedigital address the transaction goes to and comes from, which allow The Company to identify
any suspicious or irregular transactions, such as the address to which the money is sent to being
on a blacklist or the amount of the transaction not corresponding to the profile of the customer
or otherwise.
The Company has established various mecha-nisms inside its system in order to identify
these transactions. Thus, all the addresses to which the money is sent are screened at any timeusing blacklists so that Lescovex can verify if it is related to any illegal activities. The Company
has also fixed daily and monthly transaction amount limits, above which an authorisation isneeded to carry out transactions. Even the ones which are within the authorised range are at alltime controlled by the system, so that it is always possible to check and verify any suspicioustransactions made on the Lescovex platform.
If any suspicious transactions are identified, a warning will be generated by the system and thetransaction will be rejected or frozen. In addition, an “Internal Operation Report” will be issued
by The Company’s employees, with all the supporting documentation and analysis evidence
enclosed and this report will be sent to the Committee for the Prevention of Money Launderingand Terrorism Financing (hereinafter “The Committee”).

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The Committee, namely the Compliance Officer, will investigate the documentation
related to the reported transaction. The analysis will be carried out as quickly and in depth as
possible. After this investigation, the Compliance Officer will submit the results to theCommittee, which will have the final say on whether or not to communicate the transaction to
the Reporting Office. If so, all the documentation and details related to the suspi-cioustransaction will be filed with the Reporting Office as set out in the next section. Otherwise, theincidence will be archived in The Company data-base.
The communicating employee will be notified in writing regarding the results of the study
carried out in relation to the suspicions of money laundering or terrorism financing within aperiod not exceeding 7 business days, starting from the receipt of the communication.
In compliance with the applicable regulations, it is totally forbidden to disclose either thecommuni-cations or the identity of the caller. As such, all this will be strictly confidential.
In turn, all members of The Company are warned of the absolute prohibition to reveal tothe client or third parties that information has been transmitted to the Reporting Office or thata suspicious opera-tion is being examined. Failure to comply with the disclosure prohibition isclassified as a very serious breach by current regulations, which may result in the application of
the sanctions provided.
All communications of suspicious activities will be filed together with the subsequent
study and monitoring of the specific case. Access to such files will be restricted to thecomponents of the Control Body.

C. Investigation Procedure

The investigation procedure shall be as follows:a) Analysis Protocol:
Each suspicious operation studied by the Committee (Compliance Officer), will haveanindividualized file, which will be assigned denomination in accordance with the following
model: case number according to order/year (i.e.: Exp 03/18) to facilitate its ordering. These
records will refer to each operation investigated, client, reason for the alert, extension of data
made if necessary, decision adopted for remis-sion or file and reason, as well as any other dataor background information that will be relevant for evaluation. And also the reference to otherfiles that could be related by inspecting the same individuals etc.

1.

Priority will be given to the operations in which a greater number of risk indicators concur,
or inwhich the risk is of greater intensity or relevance.

2.

b) Analysis:
The documentation and information of the customer will be analyzed. The history ofopera-tionsperformed by the customer will be reviewed in the The Company‘s register ofoperations in order to check the correspondence between amounts, destinations, documents
provided, frequency, etc.

1.

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If the available information is insufficient to draw a conclusion about the suspicious
nature of theoperation, the Compliance Officer will contact the customer directly in order torequest addi-tional information or documentation that is required according to each case. The
Compli-ance Officer can also address the person who reported the operation.

2.

In the event that a lack of clear correspondence is detected, the accreditation of thelawful originof the funds must be requested.

3.

c) Analysis outcome:
After in-depth investigation, the Compliance Officer will submit the research results to theCommittee, which will then decide whether or not to communicate the incident to the Reporting
Office. If the answer is affirmative, the operation will be communicated by the Compliance
Officer, enclosing the documentation that supports the research carried out. Otherwise, theincident and all the details related to it shall be archived in the database of The Company.

D. Suspicious Transactions Report (STR) to the Money Laundering Reporting
Office of Panamà (Reporting Office)If the Committee deems that there is enough evidence to consider that a transaction oropera-tion has been made as part of an activity related to Money Laundering, Terrorism
Financing or Fraud, the Compliance Officer will file a report with the Reporting Office in a timely
form and manner. Cases in which The Company has terminated a relationship with a customer
due to the reasonable suspicion of the customer being involved in such activities shall also bereported, just like when a customer has not been accepted for registration due to some of the
Official Sanction Lists.
Once the report has been filed, Lescovex will act as set out in the arts.9a and 10 of theAMLA, in order to execute or freeze the transaction carried out by the customer which wasreported, and at all times will act as is required by the Reporting Office.

E. Confidentiality
Lescovex will not disclose the fact that informa-tion has been sent to or requested by theReporting Office to any person involved or connected to the suspicious transaction or operation
reported or to any third party. No reference whatsoever to the case will be made.
The self-regulatory organisation to which The Company is affiliated and theSUPERINTENDENCIA DE BANCOS DE PANAMÁ (SBP) are not regarded as third parties.
Any actions taken connected to the prevention of money laundering or terrorism
financing shall be treated with utmost reserve and confidentiality.

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VII. Record keeping

The following information and documentation must be kept by Lescovex for at least 10
years, so it can be available if it is ever requested by the Reporting Office, theSUPERINTENDENCIA DE BANCOS DE PANAMÁ (SBP) or any other authority:
Documentation obtained during the KYC and Due Diligence procedures for identification
ofcustomers, which shall be kept for at least 10 years after the termination of the business
relationship with the customer;

1.

Original documentation or certified copies of the transactions carried out by customers
throughthe Lescovex platform and the infor-mation related to them, which shall be kept for aminimum of 10 years after the completion of the transaction or operation carried out;

2.

Any Report of Suspicious Transactions issued and the documentation and information
attached toit, which shall be kept during the 10 years following the date of the report.

3.

Lescovex has its own database in which all this documentation and information will be
stored so as to guarantee the due conservation and retriev-ability for both internal control andpetitions from authorities. Once a person applies to be a Lescovex customer, the informationand documentation will be registered in the Lescovex database, where it will be stored on an
encrypted hard drive solely accessible by Lescovex through an internal VPN.

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VIII. Staff training policy

Lescovex believes that one of the best tools to combat money laundering and terrorims
financing is to create a culture of compliance and control among its staff. For this Purpose, thisManual and all the regulation issued by The Company related to the Prevention of Money
Laundering and Terrorism Financing will be part of the internal procedures of The Company andknowledge and compliance will be mandatory for all those who are a part of it.
Lescovex’s staff will have access to the updated version of this Manual and other internal
regula-tions related to it and will be involved in the task of prevention, for which they will be
duly informed and instructed.
If there are any legal or regulatory modifications or improvements with regards to thePrevention of Money Laundering, Terrorism Financing or Fraud, the entire staff will be informed
so that the new implementations can be applied and complied with properly.
Courses aimed at informing and training The Company’s staff to learn about the policy
and how to apply the procedures related to the Prevention of Money Laundering and Terrorism
Financing at Lescovex will be periodically provided for the staff by The Company.

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IX. Register Producer
In Lescovex our customers can buy diferent raw materials. For that purpose we need toknow info regarding the producers of those raw materials. To know that there is a KYC processthat will verify the identity and the production of our producers.
We will ask for diferent information like:-Name of the company- Address- Country- Description of the company- Raw products: Almond – Carob – Olive oil – Gold – Silver – Copper.
- Price of the raw product.
- Year production in Tons.
- Contact.
- Logistic Details. Incoterms.
You can choose different types of transport.
- EXW – FOB – DAP- The weight per m3- The Tax %- Transport Notes.

And then connect the wallet.

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X. Logistics
Lescovex allows to our customers a way to recieve the raw materials that they alreadybought.
For the register of a transporter:
Name
Address
Country
Contact
Cost
Description
Then the transporter should choose the capabilities of the transport like thetype of container, the km…

-

And other information that could be important for the logistics.
The information that we ask to our Logistics partners could change by the time
but always with the intention to know the capabilities and the service that they
could offer to our customers.

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IX. Organisational structure

To comply with the policies set forth in this manual and with the requirements of theSUPERINTENDENCIA DE BANCOS DE PANAMÁ (SBP) and other legal authorities regarding thepreven-tion of Money Laundering and Terrorism Financing, Lescovex will set up the Committee
for the Preven-tion of Money Laundering and Terrorist Financing, which will be composed ofthree members:

1. Two members of the Board of Directors;
2. The Compliance Officer: the person, natural or legal entity, that may be a member of the BoardofDirectors or any other one hired to carry out the tasks related to this.
The Board of Directors will evaluate the perfor-mance of the Committee and theCompliance Officer annually.

A. The Committee for the Prevention of Money Laundering and Terrorism
Financing

The Committee will work as a collegiate body responsible for planning, coordinating andsafe-guarding the compliance of the legal framework and the policies established in the Manual
for the Prevention of Money Laundering and Terrorism Financing (hereinafter “The Manual”). For
this purpose, The Committee will have full access to any and all information and/or
documentation it deems necessary in order to fulfill its duties.
The Committee will meet at least every three months and will deal with all the issues
related to the implementation and compliance of the Preven-tion of Money Laundering andTerrorist Financing within The Company. When a specific issue related to it must be dealt withurgently, the Compliance Officer will convene an extraordinary meeting of the Committee.
The Committee will have, amongst others, the following duties and responsibilities:• To draft the Manual for the Prevention of Money Laundering and Terrorist Financing tobeapproved by the Board of Directors;• To report annually (through the Compliance Officer) to the Board of Directors
regardingcompliance with The Manual and all of The Company‘s internal regulations related to
the Prevention of Money Laundering and Terrorist Financing, suggesting, if needed, any
pertinent modification to improve them or to implement any legal modifications, justifying thereasons and the manner in which this shall be done;• To spread among the staff of The Company the information and documentation necessary interms of Prevention;• To design the training staff plan and its imple-mentation;

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Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism• To acknowledge and promote compliance with the remedial measures to be taken based on
thereports of Internal and/or External Audits regarding the prevention of money launderingand terrorist financing;• To decide on enhancements to the monitoring and control measures suggested by theCompli-ance Officer regarding the prevention of money laundering;• To analyze the “Internal Operations Reports” submitted by The Company’s staff and approveor dismiss relaying suspicious transactions to the Reporting Office;• To cooperate with the Reporting Office so as to provide all the documentation andinformationrequired;• To preserve all the documentation and informa-tion generated by all the transactions andoper-ations reported, as set out in Section VII of this Manual.

B. Compliance Officer

This position will be held by the person, natural or legal entity, appointed by the Board of
Direc-tors. It may be possible to outsource the service by hiring any person who meets all thedue capa-bilities to carry out the tasks related to it. To this effect, The Company will draft anagreement listing all the tasks and responsibilities assigned to the Compliance Officer.
The appointment of the Compliance Officer will be communicated to theSUPERINTENDENCIA DE BANCOS DE PANAMÁ (SBP) and the Reporting Office (detailing name,position and branch). If there are any changes or updates in this information, theSUPERINTENDENCIA DE BANCOS DE PANAMÁ (SBP) and the Reporting Office must also be
noti-fied, within 5 days after the Officer’s appointment.
The Compliance Officer will have, amongst others, the following responsibilities andduties:• To convene the meetings of the Committee;• To file the reports to the Reporting Office regarding operations or transactions in which there
iscertainty or signs of money laundering or financing of terrorism;• To receive the petitions from the Reporting Office to provide information and documentation
andto execute the actions asked for;• To implement the Manual;• To monitor transactions carried out by customers;• To investigate reports of unusual transactions, as well as those detected in thecentralizedmonitoring process;28

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Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism• To keep the rest of the committee members informed of any circumstances that could alter
theprevention policy contained herein;• To present before the Committee suggestions to improve or implement new procedures for
TheManual;• To keep Lescovex informed and updated about any legal matters and regulations that affect
The Company in its management of the prevention against money laundering.

X. Internal control System

Due to the nature of the services provided by Lescovex, The Company will apply various methods
to guarantee the security of the transactions and to avoid that the platform be used as a system
to perform any illegal activity.
Thereby, The Company will apply policies and procedures in the area of due diligence,
document preservation, internal control and risk management so as to prevent transactions
related to money laundering and terrorism financing. These poli-cies and procedures, some ofwhich have been set out in this Manual, will be circulated among all the employees andexecutives of The Company.
The aforementioned policies will include a descrip-tion of the types of customers that
could present a higher risk, taking into account the risk factors set forth above and thosedetermined in accord-ance with the applicable international standards for each case. As has
been said, the customer must provide all the information and documenta-tion required so that
The Company is able to verify the customer’s identity and establish a profile for each of its
customers. If any of them has any of the risk factors mentioned, The Company will enhance thedue diligence by asking for more information or documentation to decide whether or not to
accept a person as a Lescovex customer.
On the other hand, and in order to control the transactions made by customers, Lescovex
will pay attention to the transactions carried out by customers and its correspondance with theprofile which has been established for each customer. If the system detects that any of thetransactions made do not correspond with the profile of the customer, whether due to theamount, frecuency, and so on, the system will issue a warning and the transaction will bereported to the Committee as a suspicious transaction in order to initiate an investigation. To
this effect, The Company has also established a daily and monthly amount for trans-actions, todeposit or withdraw cryptocurrencies or legal tender, above which an authorisation must be
granted by The Company, so as to keep all transac-tions under control.
Lescovex will also use blockchain technology to examine and analyse all the transactions
made on the platform and to check if any of the adresses to which the cryptocurrencies or legal
tender is sent are listed in any of the public blacklists.
The Company will always verify that the bank account to or from which the customer
deposits or withdraws legal tender is owned by the customer and nobody else. If any otherperson is a co-owner, Lescovex will also ask for information and docu-mentation related to that

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co-owner, in order to have the necessary information so as to know at all times where the money
goes.
In terms of security, transactions will not be made if customers are not verified and if they
do not use the two-factor authenticator system, so that it is guaranteed that the transaction has
been made only by them. Apart form that, an email wil be sent to their email account to verify ifthey have made that transaction.
The Committee will be in charge of applying and developing this Manual and all theregulation and policies related to the Prevention of Money Laun-deing and Terrorism Financing,keeping the afore-mentioned Manual updated at all times and avail-able for the relevant
authorities.

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XI. External control

The most important commitment by Lescovex is the compliance with all that has been
set forth in this Manual and any other regulations and poli-cies related to the Prevention of
Money Laundering and Terrorism Financing. This way, apart form the internal control measuresalready established, Lescovex will be audited by external audit entities, so that there isverification that the procedures to prevent money laundering and terrorism financing whichhave been established by The Company are effective and forceful.
This external audit will take place annually. The Company will entrust the external audit
to those persons who have the appropriate knowledge and are academically qualified to carryout the task.
The results of the verification will be recorded in a report, which will describe in detail theexisting internal control measures, evaluate their opera-tional efficiency and propose, if
necessary, any rectifications or improvements.
The report will be submitted within a maximum period of three months from the date ofissue to the Board of Directors, which will adopt the necessary measures to resolve thedeficiencies identified.The aforementioned report will be available to any authority during thefollowing five years after being issued.

Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism

Lescovex is an early-stage business project and therefore the information in this document
might be subject to change without Manual for the Prevention of Money Laundering andCountering the Financing of Terrorism notice, and should not be construed as a commitment by
Lescovex. Lescovex assumes no responsibility for any errors that may appear in this document.
In no event shall Lescovex be liable for incidental or consequential damages arising from use ofthis document. This document and parts thereof must not be reproduced or copied without
Lescovex‘s written permission, and contents thereof must not be imparted to a third party nor
be used for any unauthorised purpose.
Lescovex 2021. All rights reserved.

Manual for the Prevention of Money Launderingand Countering the Financing of Terrorism© 2021 Lescovex© 2021 Lescovex