Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Prevention Manual

1.1. Manual Objectives
This manual (hereafter referred to as the "Manual") aims to reflect the policies in the prevention
and control of Money Laundering and Terrorism Financing (ML/TF) developed by QUANTIA,
establishing the structure of internal control and implementing the necessary institutional
procedures to mitigate risks arising from ML/TF crimes.

This Manual seeks to establish policies and procedures in the prevention and control of ML/TF
for QUANTIA and to design the necessary mechanisms to achieve the standards required
nationally and internationally in this area.

The application of the procedures, guidelines, and precautions mentioned in the Manual is
mandatory for all QUANTIA staff.

1.2. Updates and Availability
The Manual will be updated by the Compliance Officer in the event of any modification of legal
or regulatory norms or upon the publication by the Financial Information Unit (UIF) of new
typologies detected in the fight against money laundering and terrorism financing.

For the preparation of this Manual, special consideration has been given to the “Guidelines for a
risk-based approach to virtual currencies” issued by the FATF in 2015 and the Report on “Virtual
Assets – Red Flags of ML and TF” issued by the same Group in 2020.

It will also be updated as changes occur in marketing mechanisms when circumstances justify it.
The Manual will always be available in all QUANTIA offices where its permanent consultation is
necessary due to the nature of the tasks. Its reading by the recipients will be documented in
writing. It will also be available to the UIF in case it is required.

1.3. Definitions

Risk Self-Assessment
It is the internal ML/TF Risk assessment exercise carried out by QUANTIA for each of its
business lines covered by the applicable regulations in order to determine its risk profile, the
level of inherent exposure, and evaluate the effectiveness of the controls implemented to
mitigate the identified risks concerning at least its Customers, products and/or services. The risk
self-assessment will also include an analysis of the sufficiency of the resources assigned, added
to other factors that make up the system as a whole, such as compliance culture, demonstrable
preventive effectiveness, and the adequacy of internal controls and training plans, if applicable.

Beneficial Owner
Any natural person who owns at least ten percent (10%) of the capital or voting rights of any
legal structure.

The natural person who otherwise exercises the ultimate control over them. Ultimate control
shall be understood as that exercised directly or indirectly by one or more natural persons
through a chain of ownership or by any other means of control or when, due to factual or legal
circumstances, the same has the power to form the social will for decision-making by the
governing body of the legal person or legal structure, or for the appointment or removal of
members of its administrative body.

When it is not possible to identify the natural person who meets the condition of Beneficial
Owner according to the preceding definition, the Beneficial Owner will be considered the natural
person who is in charge of the administration, management, or representation of the legal
person, as appropriate.

Customer
Any natural person, legal person, or legal structure without legal personality with whom an
occasional or permanent financial, economic, or commercial contractual relationship is
established.

It will be understood that those who acquire virtual assets through the QUANTIA platform act as
Customers.

Due Diligence
The Customer knowledge procedures adapted for Medium Risk customers.

Enhanced Due Diligence
The Customer knowledge procedures appropriate for High-Risk levels.

Simplified Due Diligence
The Customer knowledge procedures appropriate for Low-Risk levels.

LA/FT Risk Tolerance Statement
The written manifestation of LA/FT Risk Tolerance approved by QUANTIA regarding the
Customers, products and services, distribution channels, and geographical areas with which it is willing to operate and those with which it will not, due to the level of inherent risk of the same
and mitigating actions for their proper monitoring and control. The LA/FT Risk Tolerance
Statement must be duly founded.

Unusual Transactions
Those transactions, attempted or carried out in isolation or repeatedly, regardless of the amount,
that lack economic or legal justification, are not related to the Customer's risk level or
transactional profile, or that, due to their frequency, habituality, amount, complexity, nature, or
other particular characteristics, deviate from market practices and customs.

Suspicious Transactions
Those transactions, attempted or carried out, that raise suspicion of ML/TF, or that, having been
previously identified as unusual, do not allow the unusualness to be justified after the analysis
and evaluation carried out by QUANTIA.

Politically Exposed Persons (PEP)
Persons included in the current regulations in the various jurisdictions where QUANTIA
operates.

Virtual Currencies
The digital representation of value that can be subject to digital commerce and whose functions
are to constitute a medium of exchange or a unit of account or a store of value, but do not have
legal tender nor are they issued or guaranteed by any country or jurisdiction.

ML/TF Risk
From the point of view of an Obligated Subject, risk is the prospective measure that
approximates the possibility (in the case of proven metrics, the probability weighted by the size
of the operation) that an operation executed or attempted by the Customer through a distribution
channel, product or service offered by QUANTIA is used by third parties for criminal purposes of
ML/TF.

ML/TF Prevention System
Includes the policies, procedures, and controls established by QUANTIA for the management of
ML/TF Risks and the compliance elements required by current regulations in the field of ML/TF
prevention.

1.4. Scope of Application
This Manual applies to QUANTIA, including all its employees, directors, managers, and any
other person who, directly or indirectly, is linked to the operations of the company.

The Manual is mandatory for all QUANTIA areas and personnel, regardless of their level or
function. All employees must be aware of its content and comply with the procedures
established herein.

The Manual includes the following aspects:
●Policies for the prevention of Money Laundering and Terrorism Financing (ML/TF).
●Coordinated policies for control and monitoring.
●Functions of the audit and internal control procedures that are established aimed at
preventing ML/TF.
●Roles assigned to the Compliance Officer.
●Deadlines and terms that each director or employee must comply with, according to the
responsibilities of their tasks, with each of the control mechanisms for prevention.
●Training program.
●Policies and procedures for document preservation.
●Procedure to follow to attend to the information requests made by the Financial
Information Unit (UIF) and other regulators.
●Methodologies and criteria for analyzing and evaluating information that allow the
detection of unusual and suspicious operations and procedure for the reporting of the
same.
●Development and description of other mechanisms conducive to preventing and
detecting ML/TF operations.
●Market segmentation procedures according to the specific nature of the operations, the
transactional profile of the clients, the characteristics of the market, the classes of the
product or service, and adequate criteria to generate alert signals.
●The sanctioning regime, in case of non-compliance with specific procedures against
ML/TF according to current labor legislation."

2.1. Applicable Norms and Regulations
● Law No. 25,246 on Concealment and Money Laundering of Criminal Origin, enacted on
April 13, 2000, which created the Financial Information Unit (UIF). In its Article 20, it
listed the entities obligated to report "suspicious" operations. It defined the crime of
money laundering, prescribing imprisonment as a penalty, and established an
administrative criminal regime with a fine penalty.
● Law No. 26,087 of April 21, 2006, amended Law No. 25,246, establishing the lifting of
bank, stock market, or professional secrecy before the UIF in the analysis of a
suspicious transaction report.

●Law No. 26,268 incorporates penalties of imprisonment or reclusion into the Penal Code
with respect to terrorist criminal associations and the financing of terrorism. It also
amends Law No. 25,246, in that the UIF must prevent and impede the crime of financing
terrorism in addition to the crime of money laundering.
●Law No. 26,683 makes modifications to the Penal Code and replaces and incorporates
articles into Law No. 25,246, such as the authority of the UIF to supervise the obligated
subjects regarding compliance with the prevention of Money Laundering and Terrorism
Financing.
●Law No. 26,733 replaces and incorporates articles into the Penal Code related to
operations linked to negotiable securities or other financial instruments.
●Law No. 26,734 on terrorism and its financing, enacted on December 22, 2011. It
introduced a new article in the General Part of the Penal Code (art. 41) that increases
the penalty scale of all crimes -to double the minimum and maximum- when they have
been committed with the purpose of terrorizing the population or forcing national public
authorities, foreign governments, or agents of an international organization to perform an
act or abstain from doing so. It also establishes a new type of FT crime, within the Title
of "Crimes against the economic financial order," including the financing of crimes
committed with the purpose stated in the new art. 41 and of the organization or individual
who commits or attempts to commit them. Finally, the Law authorized the UIF to order
the administrative freezing of assets linked to the financing of terrorism.
●Law No. 27,446 replaces articles 19, 21 paragraph c), and 21 bis of Law No. 25,246 and
its amendments.
●Law No. 27,693 creates the UIF – Peru, its regulations, and complementary laws.
●Legislative Decree No. 1106, norms for effective combat against ML and other crimes.

2.2. Resolutions of the Financial Information Unit (UIF)
●UIF Resolution No. 50/2011, Official Bulletin (B.O.) of April 1, 2011, which imposed the
computerized registration of all obligated subjects and their compliance officers on the
website www.uif.gov.ar/sro.
●UIF Resolution No. 51/2011, Official Bulletin (B.O.) of April 1, 2011, which approved the
Online Suspicious Transaction Reporting System for Money Laundering/Terrorism
Financing (LA/FT), which must be submitted at www.uif.gov.ar/sro.
●UIF Resolution No. 70/2011, Official Bulletin (B.O.) of May 30, 2011, which regulates the
procedure for submitting systematic reports on the UIF website.
●UIF Resolution No. 29/2013, Official Bulletin (B.O.) of February 18, 2013, which requires
obligated subjects to report to the UIF suspicious operations of Terrorism Financing.
●UIF Resolution No. 300/2014, Official Bulletin (B.O.) of July 10, 2014, which establishes
that certain obligated subjects must pay special attention to the risk involved in
operations carried out with virtual currencies. It also adopts the definition of “virtual
currencies” from the Central Bank of the Republic of Argentina.
●UIF Resolution No. 35/2023, Official Bulletin (B.O.) of February 28, 2023, which
approves the list of Politically Exposed Persons.
●UIF Resolution No. 112/2021 of October 19, 2021, on the definition of the Ultimate
Beneficial Owner.
●SBS Resolution No. 789-2018: Regulation for the prevention of ML/FT applicable to
subjects obligated under supervision of UIF-Peru.
●SBS Resolution No. 6338-2012: Regulations for the registration of Companies and
Individuals who carry out financial operations or currency exchange, supervised by the
UIF-Peru.
●Resolution 2755-2018: Regulation of infractions and sanctions of the SBS
(Superintendencia de Banca, Seguros y AFP).

3.1. Internal Control and Prevention Structure

3.1.1. Responsibilities of the Board of Directors and Management
The Board of Directors and Management of QUANTIA have the ultimate responsibility for the
implementation and maintenance of an effective ML/TF Prevention System. This includes:

Establishing and promoting a culture of compliance throughout the organization.
Approving and periodically reviewing the policies and procedures for the prevention of ML/TF.
Ensuring that sufficient resources are allocated for the effective functioning of the ML/TF
Prevention System.

Overseeing the proper functioning of the Compliance area and supporting its activities.

3.1.2. Compliance Area
The Compliance Area is responsible for the development, implementation, and monitoring of the
ML/TF Prevention System. Its responsibilities include:

Developing and updating this Manual and ensuring its compliance.
Advising the Board of Directors, Management, and other areas of the company on matters
related to ML/TF prevention.
Coordinating and supervising the implementation of the ML/TF Prevention System.
Reporting to the Board of Directors and Management on the functioning of the ML/TF
Prevention System.
Providing training to all personnel on ML/TF prevention.
Monitoring and reporting Unusual and Suspicious Transactions to the UIF.

3.1.3. Compliance Officer
The Compliance Officer is the person designated by the Board of Directors to oversee the
implementation and functioning of the ML/TF Prevention System. The Compliance Officer’s
main responsibilities are:

●Ensuring compliance with this Manual and the applicable regulations.
●Coordinating the development and updating of the Manual.
●Providing advice and guidance to the company on ML/TF prevention matters.
●Reporting to the Board of Directors and Management on compliance issues.
●Acting as the main point of contact with regulatory and supervisory authorities.

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3.2. Customer Knowledge
Customer knowledge stands as the essential principle in the prevention of Money Laundering
and Terrorism Financing (ML/TF) and implies that QUANTIA must collect from its customers
documents that reliably prove their identity or legal entity, their address, their activity, their
economic and financial solvency, and the origin of their funds. All this will allow QUANTIA to
define the customer's transactional profile.

The “Know Your Customer” policy will be an indispensable condition to initiate or continue the
commercial or contractual relationship with the customer. Such a relationship should be based
on the knowledge of its customers, paying special attention to their operation or evolution - as
applicable - with the purpose of avoiding ML/TF.

It should also always be kept in mind that all documentation and information gathered for
customer knowledge must be preserved for the period established by the regulations (10 years)
and be available to the UIF in case the Unit requests it from QUANTIA.
Under such circumstances, it is appropriate not to maintain commercial relationships with
customers who have not been identified according to the provisions of the Manual,
recommending at this stage to consider the pertinence of filing a suspicious transaction report
when there is a refusal by the customer to identify themselves.
On this basis, those customers are not accepted from whom there is information suggesting that
they may be related to criminal activities; or who carry out businesses whose nature makes it
impossible to verify the legitimacy of the activities or the origin of the funds; or who refuse to
provide the documentation required to justify the legal origin of their funds.

3.2.1. Basic Obligations
Before starting a relationship with clients, QUANTIA must comply with the basic obligations of:
●Identifying them according to the guidelines that will be indicated later.
●Complying with provisions related to Politically Exposed Persons (PEPs).
●Verifying that they are not included in the sanctioned lists used by the company.
●Requesting information about the products they require and the reasons for their choice.

The minimum information that QUANTIA must require from clients includes:

Individuals:
a) Full names and surnames.
b) Tax ID (CUIT), Social Security ID (CUIL), Key of Identification (CDI), or any other
identification key that may be created in the future by the Federal Administration of Public
Revenue (AFIP).
c) Type and number of the document that certifies identity. Accepted documents to verify identity
include the National Identity Document issued by competent national authority, and the Identity
Card or passport issued by competent authorities of the respective issuing countries.
d) The identity of the Client must be verified using information and, where appropriate,
documentation that can be obtained from the client or from reliable and independent sources,
which allow reasonably certifying the veracity of its content, with the safeguarding of the
corresponding evidence of such process.
e) Work or professional activity.
f) Nationality and date of birth.
g) Phone number and email address.

Legal Entities:
a) Name or business name.
b) Activity.
c) Registered office (street, number, town, province, and postal code).
d) Phone number of the registered office and email address.
e) Actual address (street, number, town, province, country, and postal code).
f) Tax ID (CUIT), CDI, or any identification key that may be created in the future by the AFIP.
g) Identification of the proxy, additional, representative, and authorized persons, in terms of the
identification corresponding to Individuals.
h) Final Owners/Beneficiaries: To identify the owners and final beneficiaries, a sworn statement
from the Client or public information that allows identifying the ownership and control structure
of the client may be used. In cases where the share capital has a high level of atomization due
to the specific characteristics of the entity, this requirement will be fulfilled by identifying the
members of the administrative body or equivalent and/or those who exercise effective control of
the entity.

Identification of Other Types of Clients:
In the case of other types of Clients, the following identification rules should be followed:
a) For bodies, entities, and other legal structures that make up the National Public Sector, as
well as those that make up the Provincial, Municipal Public Sectors, and the Autonomous City of
Buenos Aires, QUANTIA must exclusively identify the individual who will operate the account
and obtain a faithful copy of the instrument in which the assignment of competence to execute
such acts is recorded, whether provided by the Client, or obtained by QUANTIA through
publications in the corresponding Official Bulletins.

b) UTES, groupings, and other similar commercial entities will be identified according to the
general rules for legal entities, applied to their members, in addition to identifying the legal
structure itself, as appropriate.
c) In the case of Simplified Stock Companies (SAS) and other commercial companies
constituted by digital means, QUANTIA may identify the legal entity and start the commercial
relationship with the digital constitutive instrument, generated by the respective public registry,
with digital signature of said body, which has been received by QUANTIA through official
electronic means.
d) Societies, their subsidiaries, and subsidiaries, that list on authorized local or international
Markets and are subject to requirements on transparency and/or disclosure of information, may
open an account and start the commercial relationship without any other procedure than: (i) the
identification of the individual who will operate the account under the terms of this Title; and (ii)
the delivery of a copy of the instrument by which said individual has been appointed for such
purposes.
e) Clients who operate exclusively with the Electronic Credit Invoice product, under the terms of
articles 12 and 13 of Law No. 27.440 on Productive Financing, may be identified in accordance
with the provisions of this Title and also through information regarding their level of activity. The
identification procedure may be carried out in person, or through the Remote Procedures
System (TAD) or another tool with identical characteristics.

3.2.2. Additional Obligations.
QUANTIA must:
In all cases, adopt reasonable additional measures to identify the true identity of the person
(holder/final or real client) on whose behalf they act.
Pay attention to prevent individuals from using legal entities as a method to carry out their
operations.
Avoid operating with legal entities that pretend to carry out a commercial activity or a non-profit
activity.
Pay special attention to the risk involved in commercial relationships and operations related to
jurisdictions where the Recommendations of the Financial Action Task Force (FATF) are not
applied, or are not sufficiently applied. For these purposes, jurisdictions classified as High Risk
and Non-Cooperative by the FATF (www.fatf-gafi.org) should be considered.
Similarly, commercial relationships and operations related to jurisdictions classified as High Risk
and Non-Cooperative according to the criteria established by the FATF should be taken into
consideration.
When operating with obligated subjects, request from them a sworn statement about
compliance with current provisions in the prevention of ML/TF.

3.2.3. Client Profile
QUANTIA must define a Client profile, which will be based on information and documentation
related to the economic, financial, and tax situation (sworn tax statements; authenticated copy
of the deed by which the funds used for the purchase are justified; certification issued by a registered public accountant, duly intervened by the Professional Council, indicating the origin of
the funds, specifying in detail the documentation that has been reviewed to carry out the same;
banking documentation from which the existence of the funds arises; or any other
documentation that supports the holding of sufficient lawful funds to carry out the operation)
provided by the client and that QUANTIA could obtain by its own means, justifying the origin of
the funds involved in the operations they carry out.
According to the particular characteristics of each Client, QUANTIA will develop a risk profile,
applying reinforced measures for those Clients classified as higher risk, establishing a higher
frequency for the update and analysis of information regarding their economic, financial, and tax
situation, as well as their corporate and control structure.
Having Clients and their operations identified by risk levels will allow QUANTIA to design and
implement measures and controls to mitigate such risks and will enable them to focus on Clients
and operations that present a higher risk.
The assignment of risk levels will be based on a series of factors, whose existence, by
themselves or in combination with several, could alert QUANTIA in its function of ML/TF
Prevention.
Factors to be taken into account to classify Clients based on their risk (high, medium, or low), if
these recommendations are followed, are the following:

● The type of Client.
● The type of activity.
● The type of income (amount).
● The amounts operated (per year and month). The products purchased.
● The number of annual transactions.

 Once these factors have been assessed, it would be possible to classify each Client according
to their potential ML/TF risk (high, medium, or low).
The risk classification of each Client will be subject to update as a result of the continuous
monitoring of the relationship, including the monitoring of their operations, in order to verify that
they match the knowledge that is had of the Client and their risk profile, thus ensuring that both
the risk classification, as well as the documents, data, and information available, are updated.
The update of the risk classification will be reviewed when the Client contracts a new service or
when the Client and operation analysis software detects a relevant change that could influence
their risk profile.
At all times, the risk classification of Clients will determine the degree of application of due
diligence, the frequency of the processes for updating their files, and the need, where
appropriate, to apply reinforced monitoring measures regarding their operations.
If these recommendations are followed, QUANTIA will be in a position to design and implement
appropriate measures and controls to mitigate the potential risks of ML/TF in relation to Clients
considered at risk.
Such risk analysis policies will be gradual, applying reinforced measures for those Clients
classified as higher risk, establishing a higher frequency for the update and analysis of
information regarding their economic, financial, and tax situation, as well as their corporate andcontrol structure. Likewise, parameters for each type of Client will be defined based on their
initial profile and subsequent evolution and according to the risk analysis policies implemented.
Consequently, Clients will be classified as low, medium, or high risk, as the case may be; and
depending on their classification as low, medium, or high risk, simplified, standard, or reinforced
due diligence will be developed regarding them.
Simplified Due Diligence regarding Low-Risk Clients.
QUANTIA must identify its human and legal entity Clients in accordance with the provisions of
Title 3.2.1. Basic Obligations. Additionally, verification against the lists of sanctioned terrorists
and PEPs will be carried out.
These Simplified Due Diligence measures do not exempt QUANTIA from the duty to monitor the
operations carried out by the Client.
Failure to comply with some of the preceding rules will prevent the application of Simplified Due
Diligence, applying the Due Diligence procedures that correspond to the determined risk level.
The request, participation, or execution in an operation with suspicion of ML/TF, obliges the
immediate application of the rules of Reinforced Due Diligence. Likewise, the Operation must be
reported as Suspicious, without prejudice to the resolution of the commercial relationship that,
where appropriate, QUANTIA may adopt.
Due Diligence regarding Medium-Risk Clients.
Due Diligence for Medium-Risk Clients
In cases of Medium Risk, in addition to the identification information, the following documentary
support will be required from the Client:

a) For Individuals:
Information and documentation that verifies the origin of the client's income, funds, and/or
assets.
If there is a proxy, guardian, curator, representative, or authorized person, documentation that
verifies such links.
b) For Legal Entities:
Date and number of registry inscription.
Copy of the social contract or constitution deed.
Copy of the updated corporate statute, which must be verified using original documents or
reliable data and information from independent sources, safeguarding the corresponding
evidence of such process.
Information and documentation that verifies the origin of the client's income, funds, and/or
assets.
List of the members of the administrative body or equivalent.
If there is a proxy, representative, or authorized person, documentation that verifies such links.
Ultimate Beneficiaries:
Documentation verifying the identity of the ultimate beneficiaries will be required, for which
QUANTIA may obtain on its own or request from the client copies of shareholder registers, orother public documentation or information that identifies the client's control structure. When the
majority participation of legal entity clients corresponds to a company listed in an authorized
local or international market and is subject to transparency and/or information disclosure
requirements, they will be exempted from the identification requirement in this section.
QUANTIA may request other data that allows proper identification and knowledge of its clients,
including requesting copies of documents that allow for proper understanding and management
of the risk of these types of clients, according to DECRYTPO's risk management systems.
Enhanced Due Diligence for High-Risk Clients
In High-Risk cases, in addition to the identification and documentation required for Medium-Risk
clients, the following documentary support will be required:
a) Copy of invoices, titles, or other evidence that reliably verifies the address.
b) Copy of documents that verify the origin of the funds, assets, or other documents that verify
income or earned income (such as financial statements, employment contracts, pay slips).
c) Copy of the minutes of the decision-making body appointing authorities.
d) Copies of other documents that allow proper knowledge and management of the risk of these
types of clients.
e) Verification of possible backgrounds related to ML/FT and sanctions imposed by the UIF, the
regulatory body, or the Judiciary (public databases, Internet, and other appropriate means).
f) Any other document that QUANTIA deems appropriate.
Additional Enhanced Due Diligence measures may be applied depending on the different
profiles of clients and operations.

3.2.4. Due Diligence Performed by Another Supervised Obligated Entity
QUANTIA may rely on the Due Diligence tasks performed by third-party legal entities that are
obligated subjects supervised by the National Securities Commission (CNV) or the Central Bank
of the Republic of Argentina (BCRA), except for the rules established for the execution of
Ongoing Due Diligence and monitoring, analysis, and reporting of operations. In such cases, the
following rules will apply:
a) There will be a written agreement between QUANTIA and the third party.
b) Under no circumstances will there be a delegation of responsibility. The responsibility will
always lie with QUANTIA.
c) The third party executing the Due Diligence measures will immediately inform QUANTIA of all
the required data.
d) The third party executing the Due Diligence measures must promptly send copies of the
obtained documents.
e) The mentioned agreements and their functioning and operations will be subject to periodic
review by the internal audit manager of QUANTIA, who will have full and unrestricted access to
all documents, tables, procedures, and supports related to them.Agreements of this type may only be made with foreign financial entities when they are banks,
credit, securities, or insurance companies, authorized to operate and properly regulated in terms
of ML/FT prevention in jurisdictions not considered non-cooperative or high-risk by FATF.
In all cases, QUANTIA must observe the provisions of Law No. 25,326 or those that modify,
complement, or replace it, regarding the processing of personal data.

3.2.5. Ongoing Due Diligence
All clients must be subject to continuous monitoring to identify, without delay, the need to modify
their transactional profile and associated risk level.
Client information and documentation must be kept up to date at a frequency proportional to the
risk level, according to the terms set in this Title.
Under no circumstances should client files be left unupdated for more than FIVE (5) years. For
clients assigned a High-Risk level, the frequency of file updates should not exceed ONE (1)
year, and for Medium-Risk clients, TWO (2) years.
QUANTIA may implement policies and procedures regarding the updating of files for those
clients assigned a medium or low-risk level, and who have not been subject to any process
involving the presentation of updated documentation and/or information. In such cases,
QUANTIA may evaluate whether there is a need to update the client file, applying a risk-based
approach and criteria of materiality concerning the transacted activity and the risk it may pose.
For updating the files of clients considered Low Risk, QUANTIA may rely solely on information,
and in the case of Medium-Risk clients, on information and documentation, whether provided by
the client or obtained by QUANTIA itself, keeping the corresponding evidence. In the case of
clients assigned a High-Risk level, the updating of files must be based on documentation
provided by the client or obtained by QUANTIA itself, keeping the corresponding evidence in the
client's file.
The lack of updating of client files, due to the lack of collaboration or reluctance on the part of
the clients to provide the required updated data or documents, will necessitate an analysis with
a risk-based approach to evaluate the continuity or not of the relationship with them and the
decision to report the client's operations as suspicious, if appropriate. The lack of documentation
does not in itself constitute the existence of a Suspicious Operation; QUANTIA must evaluate
this circumstance in relation to the client's operations and associated risk factors, to analyze the
need to make an STR.

3.2.6. Data Preservation
QUANTIA must maintain a file for each client, containing the data and records necessary to
accredit the proper application of Due Diligence measures. When there are centralized systems
to control the suitability of the documentation and information required by due diligence
measures, client files may be subject to centralized archiving.
The following documentation will be preserved, always available to the competent authorities:Regarding the identification and knowledge of the client, the file and all additional information
required will be preserved for a period of ten (10) years from the end of the relationship with the
client.
Regarding transactions or operations, the original documents or copies certified by the entity will
be preserved for a period of ten (10) years from the execution of the transactions or operations.
The record of the analysis of reported suspicious operations must be kept for a period of ten
(10) years.
Computer supports related to transactions or operations must be preserved for a period of ten
(10) years.

4.1. General Information on Alerts
In the presence of any data revealing the existence of an operation that cannot be economically
or legally justified, whether attempted or carried out in isolation or repeatedly, not related to the
economic, financial, asset, or tax profile of the client, or deviating from the usual practices and
customs in market operations due to their frequency, habituality, amount, complexity, nature,
and/or particular characteristics; QUANTIA will activate all mechanisms at its disposal to discern
the true nature of the operation, given that it could be a suspicious Money Laundering operation.
In this regard, it should especially:

●Refer to the client's file to verify if the cause for the alert is justified according to the
activities declared in a timely manner, and/or with the history, knowledge of the
account/service, and documentation provided. Also, consider the history of operations
maintained with the client.
●Analyze the information obtained within the characteristics of the client's profile and from
there determine the next steps.
●Request additional data and/or documentation from the client, if deemed appropriate,
beyond what QUANTIA already has (tax declarations, balance sheets, deeds, etc.) that
justify the origin of the funds involved in the operation.
●Analyze the information, verifying the correspondence of the data in the documentation
presented with the type and amount of the detected operation.
●If, after conducting the verifications, the unusual nature of the operation has not been
fully dispelled, the Compliance Officer will assess the relevance of making a Suspicious
Transaction Report (STR) to the UIF. Otherwise, that is when the operation is justified, it
will proceed to file the operation.

4.2. Special Circumstances to Consider
For the purpose of identifying possible alerts, the following circumstances should be particularly
valued, described here by way of example:
The amounts, types, frequency, and nature of the operations carried out by clients that do not
relate to their background and economic activity.Unusually high amounts, the complexity, and the unusual modalities of the operations carried
out by clients.
When transactions of a similar nature, amount, modality, or simultaneity suggest that it is a
fragmented operation for the purpose of avoiding the application of detection and/or reporting
procedures.
When clients refuse to provide data or documents requested by QUANTIA or when it is detected
that the information and/or documentation provided by them is inconsistent or false.
When there are indications about the illegal origin, handling, or destination of the funds used in
the operations, for which there is no explanation.
When the client shows an unusual disregard for the risks assumed and/or costs of the
transactions, incompatible with their economic profile.
When operations involve jurisdictions considered as High-Risk and Non-Cooperative by the
FATF.
When the same address appears for different legal entities or when the same individuals appear
as authorized and/or proxies for different legal entities, and there is no economic or legal reason
for it, especially considering when any of the legal entities are located in jurisdictions considered
as High-Risk and Non-Cooperative by the FATF.
When it is known that the operations are carried out by people involved in investigations or
judicial proceedings for acts related to illicit enrichment and/or Money Laundering.
When transactions involving foundations, associations, or any other non-profit entity, which do
not conform to their social purpose, are routinely carried out.
Exceptionally low or high prices, relative to the goods involved in the transaction.
The attempt of operations involving individuals or legal entities whose identification data,
National Identity Document, C.U.I.L., C.U.I.T, or C.D.I. could not be validated or do not
correspond to the name and surname or corporate name of the person involved in the
operation.

5.1. Systematic Reports
These are the reports that must be sent to the UIF on a monthly basis, using the “online”
system, according to the obligations established in article 14, section 1, and article 21, section
“a” of Law No. 25.246 and its amendments.
In the event that a systematic reporting operation is considered by QUANTIA as a suspicious
operation, it must prepare the reports independently.

5.2. Technical Risk Self-Assessment Report
The results of the application of the methodology implemented by QUANTIA to identify and
evaluate risks will be recorded in a technical report prepared by the Compliance Officer, which
must meet the following requirements:
a) Have the approval of QUANTIA's Board of Directors.
b) Be kept, along with the methodology and the documentation and information that supports it,
at the address registered with the UIF.
c) Be updated annually.d) Be sent to the UIF, once approved, before April 30 of each calendar year.
In cases where QUANTIA carries out more than one activity regulated by the UIF, it must
develop the risk assessment for each of them. If it deems appropriate, it may prepare a single
technical report, in a consolidated document, which must clearly reflect the particularities of
each of the activities, as well as their risks and mitigants in terms of ML/FT prevention.
5.3. Suspicious Transaction Report (STR)
QUANTIA will report Suspicious Transactions to the UIF as follows:
a) The reports will include all data and documents that allow the UIF to properly use and benefit
from such communications. The reports will be made under the technical conditions established
in UIF Resolution 51/2011 or any that amend, complement, or replace it; fulfilling all required
fields and delivering or making available to the UIF all tables, documents, or supporting
information that justify the decision to report.
b) The Suspicious Transaction Report must be well-founded and contain a description of the
reasons why the operation is considered as such.
c) The deadline for issuing a report on a Suspicious Money Laundering transaction is FIFTEEN
(15) consecutive days, counted from the date QUANTIA concludes that the operation has such
a nature. Furthermore, the reporting date must not exceed ONE HUNDRED AND FIFTY (150)
consecutive days, counted from the date of the attempted or carried out Suspicious Transaction.
d) The deadline for reporting a Suspicious Terrorism Financing operation is FORTY-EIGHT (48)
hours, counted from the date of the attempted or carried out operation.
The Suspicious Transaction Reports are confidential and therefore cannot be shown to
independent external reviewers or regulatory bodies of the activity, in accordance with the
provisions of articles 21 section c) and 22 of Law No. 25.246 or any that amend, complement, or
replace it, except in cases where the BCRA acts in any on-site supervision procedure, within the
framework of the collaboration that the BCRA provides to the UIF, under the terms of section 7
of article 14 of Law No. 25.246 or any that amend, complement, or replace it. In such
circumstances, both QUANTIA and the BCRA must ensure the confidentiality of the information
and its chain of custody.
Nevertheless, independent external reviewers may access the necessary information to
evaluate the functioning of the monitoring and alert system, and the procedures for analyzing
Unusual and Suspicious Transactions. The information provided must omit any content that
could identify the subjects involved in the operations.
According to legal and regulatory standards, QUANTIA will communicate to the UIF any fact or
operation, attempted or carried out, that having been previously identified as unusual, after its
analysis and evaluation, does not correspond to the licit activities declared by the Client, or
when there are doubts regarding the authenticity, veracity, or consistency of the documentation
presented by the Client, causing suspicion of Money Laundering; or even when dealing with
operations related to licit activities, there is suspicion that they are linked to or will be used for
Terrorism Financing.
Especially, operations will be reported that, in relation to the activities mentioned above, show a
clear lack of correspondence with the nature, volume of activity, or background of the Client(s)involved, provided that in the special examination no economic, professional, or business
justification for the operation is appreciated.
Once facts or operations considered reportable are detected, according to the analysis carried
out, they must be reported to the UIF, as regulated in Resolution UIF 51/2011, electronically
through the website www.uif.gov.ar/sro.
This is without prejudice to the duty to preserve the supporting documentation of the reported
operations as required by this Manual, which will remain available to the UIF and will be sent
within forty-eight (48) hours of being requested.
The STR must be well-founded and contain a description of the circumstances that make the
operation suspicious.

5.4. Exemption from Liability
Well-founded and good faith STRs will not constitute a violation of restrictions on disclosure of
information imposed by contract or by any legal or regulatory provision and will not imply any
type of liability for QUANTIA, its directors, or employees.
5.5. Prohibition of Disclosure
It is strictly forbidden to inform the Client or third parties, except for the persons and bodies
specially designated internally, of the fact that information has been communicated to the UIF, or
that an operation is being examined or may be examined for potential links to ML/FT.
Non-compliance with this rule constitutes a crime and carries criminal and administrative
sanctions.

5.6. Requirements of the UIF
Requests for information on the policy for the Prevention of ML/FT made by the UIF will be
attended to by the Compliance Officer. Eventually, and when the seriousness of the case
requires it, they may be discussed within the Board of Directors of QUANTIA. Such requests
must be addressed promptly and within the deadline indicated by the competent authority in its
request. In the absence of a deadline, they will be answered within 10 business days.

6.1. Staff Performance Evaluation and Sanctions
Due Diligence in complying with ML/FT prevention regulations will be an important element
when analyzing each employee's work performance (as long as the employee's activity is
related to the preventive activity in question).
Non-compliance with the Policies of the Manual harms QUANTIA, its executives, and
employees. As the reputation of the staff is directly linked to that of QUANTIA, any
non-compliance will have a double impact. Also, the formal and timely non-compliance with
current regulations (see Title 2 of the Manual) could lead to legal sanctions for QUANTIA and its
Compliance Officer; thus, there should also be internal sanctions for those employees who have
failed to fulfill their obligations, as they put QUANTIA at risk.
Internal sanctions applicable to employees, according to the scale of severity, will be:

●Warning.
●Reprimand with notation in the file.
●Suspension without pay.
●Dismissal with just cause.

6.2. Training
QUANTIA will organize training mechanisms for its employees in order to prevent ML/FT with
the aim of generating awareness and training, and to achieve:
Generating real awareness of the Risk of ML/FT in all areas, and of the need to act within the
framework of a "Prevention Culture."
Improving employee knowledge of the Prevention Policy and the content of current regulations,
including the Manual.
Ensuring that critical staff have adequate knowledge in ML/FT Prevention.
Understanding that "Know Your Customer" is the most appropriate way to safeguard their
reputation.
Conveying that every employee is responsible for identifying and knowing the clients and
complying with prevention regulations.
Incorporating techniques and procedures that allow for better knowledge of the clients.
Knowing the internal rules and promoting the need to read the Manual.
The activities to be developed will consist of:

● Training provided to staff upon entry.
● Training with internal and/or external trainers.
● Sending questionnaires to evaluate the staff's knowledge.
● Distance training through the intranet or other elements such as videos, CDs, etc.
● The Compliance Officer will keep a record of the various trainings conducted.

6.3. Internal Audit
The Internal Audit will include in its planning the evaluation of the ML/FT Prevention Program
implemented by QUANTIA and the controls related to the matter, both in terms of its
performance in the market and the knowledge and application of these preventive norms by the
staff, executives, and the Compliance Officer.
As a result of the evaluation, a report should be issued on the existence and functioning of the
internal control procedures applied to comply with UIF norms in ML/FT Prevention, at least once
a year.