AML Policy – GTECHSPRO S.A. (“Multibanq”)
Last updated January 1st  2026

This Anti‑Money Laundering and Counter‑Terrorist Financing Policy ("AML/CTF Policy") sets out the principles, controls, and procedures applied across the MULTIBANQ platform to prevent money laundering, terrorist financing, sanctions breaches, and other financial crime risks.
This Policy applies to MULTIBANQ, its affiliated entities, officers, employees, contractors, and, where relevant, to third‑party partners engaged in delivering services accessible through the MULTIBANQ platform.

1. Purpose & Scope
MULTIBANQ operates as a business‑to‑business financial technology and introducing platform. The purpose of this Policy is to:

• Support compliance with applicable AML/CTF laws and regulations

• Protect the integrity of the MULTIBANQ platform

• Support regulated partners in meeting their own AML/CTF obligations

• Detect, deter, and prevent misuse of the platform for financial crime

This Policy is risk‑based and proportionate to the nature, scale, and complexity of the services facilitated through the platform.

2. Regulatory Framework
MULTIBANQ maintains AML/CTF controls aligned with internationally recognised standards, including:

• FATF Recommendations

• Swiss AML principles and self‑regulatory standards (where applicable)

• EU AML Directives and MiCA‑related expectations (where relevant)

• Applicable local AML/CTF laws in jurisdictions where partners operate

AML/CTF obligations are applied through a combination of internal controls and reliance on regulated third‑party service providers operating under their own licensing and supervisory regimes.

3. Risk‑Based Approach
MULTIBANQ applies a risk‑based approach to AML/CTF compliance. Risk assessments consider, among other factors:

• Client type and business activity

• Jurisdiction and geographic exposure

• Product and service configuration

• Transaction volumes and patterns

• Delivery channels and operational complexity

Enhanced measures are applied where higher‑risk factors are identified.

4. Customer Due Diligence (CDD & KYB)
MULTIBANQ supports customer due diligence processes for business clients through structured onboarding and verification workflows.
CDD/KYB measures may include:

• Identification and verification of legal entities

• Verification of beneficial owners and control persons

• Assessment of business activities and source of funds

• Ongoing review of client risk profiles

CDD and KYB processes are conducted using internal procedures and specialised third‑party verification and screening providers.

5. Ongoing Monitoring & Transaction Oversight
MULTIBANQ supports ongoing monitoring of platform activity to identify unusual or potentially suspicious behaviour. Monitoring measures may include:

• Review of transaction patterns and volumes

• Detection of anomalies or high‑risk indicators

• Use of blockchain analytics and monitoring tools where applicable

• Escalation of alerts for compliance review

Transaction monitoring is proportionate to the service configuration and may involve both automated tools and human review.

6. Sanctions & Screening
MULTIBANQ applies screening measures designed to identify exposure to:

• International sanctions lists

• Politically Exposed Persons (PEPs)

• Adverse media and high‑risk indicators

Screening is conducted at onboarding and, where appropriate, on an ongoing basis using recognised third‑party screening solutions.

7. Third‑Party Reliance & Partner Oversight
Services accessible through the MULTIBANQ platform are delivered in coordination with regulated third‑party providers, including payment institutions, banks, exchanges, custodians, and compliance technology vendors.
MULTIBANQ conducts risk‑based due diligence on partners and relies on their regulatory status, licensing, and internal AML/CTF controls for execution‑level compliance.

8. Suspicious Activity & Reporting
Where suspicious activity is identified, MULTIBANQ applies internal escalation and review procedures.
Where required by applicable law or self‑regulatory obligations, suspicious activity may be reported to competent authorities by the relevant regulated entity or partner.
MULTIBANQ cooperates with lawful requests from regulators and authorities.

9. Record Keeping
Records relating to onboarding, verification, monitoring, and compliance reviews are maintained in accordance with applicable legal and regulatory retention requirements.
Records are stored securely and access is restricted to authorised personnel.

10. Governance & Responsibilities
AML/CTF oversight within MULTIBANQ is supported by:

• Designated compliance and risk management functions

• Senior management oversight

• Defined escalation and decision‑making processes

Employees and contractors receive appropriate AML/CTF awareness and training relevant to their roles.

11. Data Protection
Personal data processed for AML/CTF purposes is handled in accordance with applicable data protection laws and the MULTIBANQ Privacy Policy.

12. Review & Updates
This AML/CTF Policy is reviewed periodically and updated to reflect changes in regulations, risk assessments, or business operations.
The latest version of this Policy is made available on the MULTIBANQ website.

13. Contact
Questions regarding this AML/CTF Policy may be directed to MULTIBANQ via the contact form available on the website.