AML POLICY TETHWAY

Effective Version: May 2025

Operations involving digital assets must comply not only with efficiency and decentralization objectives but also with high standards of legality and transparency. At TETHWAY, we maintain a zero-tolerance stance against the misuse of our services for illicit purposes.

This policy defines the mechanisms through which we prevent, detect, and report potential money laundering or terrorist financing activities, in compliance with current legislation in Mexico.

User Identification and Validation

All users interacting with our services must undergo a mandatory verification process. This procedure is part of our "Know Your Customer" (KYC) practices, aimed at ensuring that all activities on the platform come from legitimate sources.

The following information will be requested:

• Official identity document.
• Recent proof of address.
• Valid contact information.
• Information about the user’s economic or professional activity.
• User’s experience with purchasing digital assets.

The scope of this review may vary based on the perceived risk level and the transactional volume associated with each profile.

Ongoing Monitoring of Operations2. Supervisión continua de operaciones

We implement automated systems to monitor transaction behavior in real-time within the platform. This monitoring allows us to detect transactions that exceed unusual limits without justification, are inconsistent with the user’s history, or originate from or are directed toward high-risk jurisdictions.

Each transaction flagged as unusual will be analyzed by an internal review team and, if necessary, escalated to the relevant authorities.

Risk Assessment

TETHWAY assigns risk levels to its users based on various factors, including:

Nature of economic activity, Frequency and amount of transactions, Relationship with high-risk territories according to international lists (such as OFAC or FATF). Accounts with high-risk indicators may require additional validation processes or be subject to operational restrictions.

Record Retention and Protection

In accordance with Mexican legal provisions, TETHWAY will securely retain all relevant information related to users and their transactions for a minimum period of five years. This includes:

• Identity records,
• Transaction details,
• Documentary evidence related to verifications and risk assessments.

These records will be available for delivery to regulatory authorities when legally required.

Staff Training

All operational and administrative staff involved in sensitive processes receive continuous training on national and international regulations concerning the prevention of financial crimes.

The team's constant updates ensure prompt and well-founded responses to any irregular situation.

Reporting to Competent Authorities

In cases where there are reasonable indications of money laundering, terrorist financing, or illicit use of digital assets, TETHWAY will fulfill its obligation to report to the Financial Intelligence Unit (UIF) and any other relevant authority in a timely manner, providing all available complete information.

Changes to the Policy

TETHWAY reserves the right to update or modify this policy at any time to respond to regulatory changes or emerging risks. We recommend periodically reviewing this section to stay informed about our compliance measures.

Contact

If you have any questions related to this policy, you can write to or call us at:

+52 55 5596 6141 contacto@tethway.com