AML Policy
‍Equito App

1. Purpose

The purpose of this document is to ensure that all staff and clients of Equito App S.L. (“Equito”) are aware of the strict anti–money laundering (AML) policy the Platform follows. Equito is committed to the highest standards of openness, transparency and accountability, and conducts its affairs in accordance with the requirements of relevant funding and regulatory bodies.
Equito has a zero-tolerance approach to money laundering, and this policy applies to all activity within the Platform.

2. Definitions & Legislative Context

• Money Laundering
  The process of transforming criminally-derived “dirty funds” into legitimate assets so they can re-enter commerce, concealing their true origin.
• Three stages of money laundering
  1. Placement: Illicit proceeds enter the financial system.
  2. Layering: Transactions distance the funds from their illegal source.
  3. Integration: Funds re-enter legitimate commerce with a false paper trail.
• Regulations
  The Money Laundering, Terrorist Financing & Transfer of Funds Regulations 2017 (MLR 2017) came into force on 26 June 2017, implementing the EU’s 4th Anti-Money Laundering Directive and replacing MLR 2007. MLR 2017 adopts a risk-based approach to AML and customer due diligence.

3. Scope

This policy applies to:

• All employees and contractors of Equito and its subsidiaries
• All clients, partners and third parties acting on behalf of Equito

In Spain, money laundering is a criminal offence punishable by up to six years’ imprisonment and fines up to three times the value laundered. Offences include:

• Failing to report knowledge or suspicion of money laundering
• Failing to maintain adequate AML procedures
• Assisting money launderers
• “Tipping off” suspects
• Recklessly providing false or misleading statements in an AML context

Non-compliance may also trigger sanctions from the AEAT (Tax Agency) and/or CNMV (National Securities Market Commission), and disciplinary action within Equito.

4. Risk Assessment

Under MLR 2017, Equito must assess its exposure to money laundering across four dimensions:

1. Product/Service Risk
   — E.g., collecting investor funds, transferring money to projects.
2. Jurisdictional Risk
   — Country of operation, location of customers, suppliers, agents.
3. Customer/Third-Party Risk
   — Individuals or entities (including beneficial owners, suppliers, vendors); special attention to PEPs and sanctioned parties.
4. Distribution Risk
   — Channel of interaction (face-to-face, online, via intermediaries).

4.1 Red Flags

Be vigilant for signs such as:

• Large, unexpected payments without ID or justification
• Circular transactions (payment followed by refund requests)
• Invoices lacking company registration details or VAT numbers
• Very low supplier quotes suggesting “clean money” subsidies
• Unexplained involvement of unconnected third parties

Report any concerns immediately to the Money Laundering Reporting Officer (MLRO).

5. Unusual or Large Payments

• Investigate purpose and origin of any unusual or large payments.
• Consult our bankers for guidance on high-risk jurisdictions.

6. Payment Thresholds

• MLR 2017 reduces the cash transaction threshold from €15 000 to €10 000, applying equally to cash receipts and payments.

7. Know Your Customer / Supplier (KYC)

To be “reasonably satisfied” of a customer’s identity, obtain at minimum:

• Legal name
• Clear copy of a government-issued ID
• Verified telephone number

For third parties, collect proof of name, address and relationship. For unknown corporate investors, perform document, website and credit checks. Always document the purpose and intended nature of the business relationship.

8. Processing Refunds

• Conduct AML checks before any refund.
• Refunds must be made to the original payer’s account—no third-party refunds.
• International refunds go back to the original foreign account.

9. Financial Sanctions Targets

Consult the Spanish government’s updated sanctions list before engaging with entities or individuals in high-risk or embargoed jurisdictions, including but not limited to:

Afghanistan, Belarus, Burma, DR Congo, Iran, Iraq, Libya, North Korea, Somalia, South Sudan, Syria, Venezuela, Yemen, Zimbabwe…

Always check with the MLRO to confirm no contact with sanctioned parties.

10. Roles & Responsibilities

• Board of Directors
  Ultimately responsible for AML compliance.
• Money Laundering Reporting Officer (MLRO)
  – Name: Naji Bizri, Co-founder & Director
  – Phone: +34 651 027 311 / +33 6 16 77 48 76
  – Email: naji.bizri@equito.app

MLRO duties include:

1. Receiving and evaluating Suspicious Activity Reports (SARs)
2. Filing SARs with AEAT when required
3. Seeking AEAT consent before proceeding with flagged transactions

11. Reporting Suspicious Activity

All members of Equito must report suspicions via the Suspicious Activity Report (see Annex A). Provide full details in strict confidence, avoiding any “tipping off” of suspects. The MLRO reviews reports and escalates to the Board as necessary.

12. Training

The MLRO shall ensure all financially responsible staff receive AML training upon hire and refresher sessions each time this policy is updated.

13. Review, Approval & Publication

This policy is reviewed at least every three years by the Board or sooner if EU AML legislation changes.
Last reviewed and approved on July, 2025.