AML/CFT PolicyAML/CFTPolicy

As a virtual asset service provider, Garnet is subject to the duties of Law No. 9,613/1998 (anti-money laundering), Law No. 14,478/2022 (Brazil's virtual asset framework) and the regulations of the Central Bank of Brazil — in particular Circular No. 3,978/2020 and BCB Resolution No. 520/2025 —, as well as Law No. 13,810/2019 on compliance with United Nations Security Council sanctions.

We assess the risk of clients, transactions, products, channels and partners and apply controls proportionate to that risk — stricter where the risk is higher. The assessment is reviewed periodically and whenever we launch a new product or service.

Before starting a relationship, and throughout it, we identify and assess clients and their representatives — and, for companies, their ultimate beneficial owners. This includes:

• verifying identity and the documents provided;
• identifying politically exposed persons (PEPs) and people related to them;
• assessing the source of funds and whether transactions match the client's business and financial capacity;
• updating client records periodically, at a frequency set by risk.

Due diligence also applies to relevant partners, counterparties and service providers, including other virtual asset service providers, in Brazil and abroad.

We monitor transactions and virtual asset transfers, supported by blockchain analytics tools, to identify unusual or suspicious activity. Cases are analysed and, where appropriate, reported to COAF, Brazil's financial intelligence unit, within the regulatory deadlines.

Reports to COAF are confidential: we do not tell the client or third parties that a report has been made.

We screen clients, beneficial owners, counterparties and wallets against national and international sanctions and restrictive lists, including those of the United Nations Security Council, and comply without delay with asset-freezing orders.

In virtual asset transfers, we collect and pass on the originator and beneficiary information required by the regulations (the so-called travel rule) and keep the records for the required period.

In transfers to or from self-custody wallets, we identify the wallet's owner and document the verification of origin and destination. Such transfers may be reported to COAF and, from January 1, 2027, be subject to a precautionary hold of up to 24 hours, as the regulations provide.

We do not carry out virtual asset transactions intended to conceal the origin, destination or ownership of funds, such as mixing services (mixers).

We may refuse, suspend or end relationships and transactions when a client does not provide the required information, when there are signs of wrongdoing, or when the risk is incompatible with this policy.

We keep client records, transaction records and the documentation of our analyses for the periods set by law and regulation, with access and confidentiality controls.

The policy provides for a designated director responsible for compliance with it, periodic staff training and periodic assessment of the effectiveness of the controls. It is reviewed whenever there are relevant changes in the law, the regulations or our activities.

Questions about this policy can be sent to contato@garnet.finance. Through the same channel, you can report a suspected irregularity involving Garnet; your report will be handled confidentially.