Compliance Policy

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1. Principles

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• Integrity: transparent and auditable operations.

• Compliance: adherence to local and international regulations.

• Prevention: mitigation of risks related to money laundering, terrorist financing, and sanctions.

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2. Structure

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• Independent Compliance Committee.

• Compliance Officer responsible for regulatory reporting.

• Continuous training of employees.

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3. International Standards

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• FATF Recommendations.

• UN, EU, and OFAC sanctions.

• ISO 37301 (Compliance Management Systems)

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🇧🇷 3. Compliance Policy – Brazil

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• Cryptoassets Legal Framework (Law No. 14.478/2022).

• Central Bank of Brazil: CMN Resolution No. 4.893/2021, BACEN Circular No. 3.691/2013.

• COAF: mandatory reporting of suspicious transactions.

• LGPD: personal data protection.

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🇦🇷 4. Compliance Policy – Argentina

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• Law 25.246 (AML/CFT).

• UIF: reporting of suspicious transactions.

• BCRA: foreign exchange restrictions and PSP regulations.

• Law 25.326: personal data protection.

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🇺🇸 5. Compliance Policy – United States

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• FinCEN: registration as a Money Services Business (MSB).

• Bank Secrecy Act (BSA) and USA PATRIOT Act.

• OFAC: blocking of transactions with sanctioned parties.

• State Licensing: Money Transmitter License (MTL).

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🇲🇽 6. Compliance Policy – Mexico

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• Fintech Law (2018).

• Banxico: restrictions on financial institutions’ use of cryptoassets.

• UIF: reporting of suspicious transactions.

• Federal Law on Protection of Personal Data Held by Private Parties.

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🇪🇺 7. Compliance Policy – European Union

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• Markets in Crypto-Assets Regulation (MiCA – Regulation (EU) 2023/1114): establishes uniform rules for crypto-asset issuers and service providers (CASPs).

• Anti-Money Laundering Directive (AMLD5 and subsequent updates): strict KYC/AML requirements and reporting obligations to national Financial Intelligence Units (FIUs).

• Anti-Money Laundering Regulation (AMLR – Regulation (EU) 2024/1624): harmonized EU-wide AML/CFT framework.

• GDPR (Regulation (EU) 2016/679): personal data protection and user rights.

• Consumer Rights Directive (2011/83/EU): transparency in contracts and consumer protection.

• Sanctions: compliance with EU restrictive measures and alignment with UN sanctions.

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📌 Note: In the EU, TradeTrend must operate as a licensed Crypto-Asset Service Provider (CASP) under MiCA, comply with AMLD5/AMLR, GDPR, and consumer protection directives. Stablecoins are regulated as “asset-referenced tokens” or “e-money tokens,” depending on their structure.