POLICY AML

At CREA-THUM, we are firmly committed to operating with integrity and in full compliance within the digital asset environment. Our goal is to promote responsible financial practices and ensure that our platform is never used to conceal, transfer, or legitimize funds from illicit sources.

We fully adhere to Mexican anti-money laundering regulations and align our practices with applicable international standards.

Customer Due Diligence (KYC – Know Your Customer)

All users must complete a thorough identity verification process before conducting any operations on our platform. This process includes:

• Submission of a valid government-issued ID.
• Recent proof of address.
• Assessment of declared economic activity and validation of the legitimacy of funds.

We also apply a risk-based user classification system (low, medium, or high risk), which determines the level of monitoring and oversight based on the user’s profile and transaction behavior.

Transaction Monitoring and Activity Oversight

CREA-THUM has implemented an automated transaction monitoring system designed to identify irregular patterns, including:

• Unusually large or unjustified transactions.
• Abnormal frequency of purchases or exchanges.
• Activities linked to jurisdictions under sanctions.

Any transaction that deviates from expected behavior is reviewed by our compliance team. If deemed necessary, an unusual transaction report will be submitted in accordance with Mexican regulatory requirements.

Information Retention and Documentation

In accordance with current legislation, CREA-THUM will retain the following records for at least five years:

• All personal and financial data collected during user onboarding.
• Full transaction history within the platform.
• Supporting documentation related to internal investigations or submitted reports.

These records are securely stored using encrypted and protected systems, ensuring their availability in the event of audits or regulatory inspections.

Staff Training and Compliance Oversight

All CREA-THUM personnel undergo regular mandatory training on anti-money laundering and counter-terrorist financing practices. Training topics include:

• Identification of suspicious activity.
• Internal escalation and reporting protocols.
• Regulatory updates and emerging criminal typologies.

Our compliance department operates independently, reporting directly to senior management. It is responsible for the design, implementation, and oversight of our AML/CFT policies.

Policy Updates and Risk-Based Adaptation

As the digital asset landscape continues to evolve, CREA-THUM will update this policy as new risks, regulations, or illicit practices emerge. Users will be notified of any significant changes. However, we encourage users to review this policy periodically, as continued use of the platform implies tacit acceptance of its terms.

CREA-THUM firmly believes that user trust and operational transparency can only thrive in a legal and ethical environment. This policy reflects our ongoing commitment to preventing the misuse of our digital infrastructure for unlawful purposes and to ensuring a secure commercial space for all our users.