Anti-Money Laundering (AML) and Due Diligence (KYC) Policy

Money laundering involves concealing an illegal source of funds by converting them into cash or seemingly legitimate investments.

General provisions

Our anti-money laundering policy ("AML Policy" hereinafter) is based on the following essential principles:

• Do not establish business relationships with criminals and/or terrorists.
• Do not process transactions arising from criminal and/or terrorist activities.
• Do not facilitate any transactions related to criminal and/or terrorist activities.

Verification procedures

The Store has its own procedures to determine compliance with the standards of the AML Policy and the Know Your Customer (KYC) policy.

Store Customers complete a verification procedure (they must provide a state-issued ID document: Passport or National Identity Document). The Store reserves the right to use Customer identification information for the purpose of adhering to the AML Policy. This information is processed and stored strictly in accordance with the Store's Privacy Policy. The Store will verify the authenticity of the documents and information provided by Customers and reserves the right to request additional information from Customers identified as potentially at risk.

If a Customer's identification information has changed or their activity becomes suspicious, the Store has the right to request updated documents from the Customer, even if they have been authenticated in the past.

AML - KYC Policy Compliance Officer

The Store has an Anti-Money Laundering Policy Compliance Officer responsible for ensuring compliance with the AML Policy and the execution of KYC procedures, such as:

• Collection of Customer identity information.
• Updating and monitoring internal policies and procedures to create, review, submit, and store all necessary reports in accordance with existing laws and regulations.
• Monitoring and tracking transactions to analyze any significant deviations from Customers' normal activities.
• Creation of a records management system to store and retrieve documents, files, forms, and records.
• Regular analysis of risk assessments.

Transaction monitoring

Monitoring Customer transactions and analyzing the data obtained is a tool that allows us to assess their risk level and detect suspicious transactions. If money laundering is suspected, the Store will monitor all of the Customer's transactions and reserves the right to:

• Request the Customer to provide additional information and documents.
• Suspend or close the Customer's Account.

Retention of records and information reports

As part of our AML program, we maintain relevant documentation regarding customer identity and electronic fund transfers. The record retention period is updated in accordance with current regulations.

The current retention period for these records is ten years. The archive must be completed so that it is available to all employees who must have access to the customer in question.

We will respond to written, reasoned, and legally binding requests issued and supported by official authorities within the legal framework regarding accounts and transactions, searching our records to determine whether we hold or have held any information, or have conducted any transactions with each appropriately defined person, entity, or organization named in the request.

If no information is found, we will provide the relevant response, maintain documentation of the search, and record the name of the individual or company in the request for our risk-based procedures.

Customer identification and source of funds

We store certain identifying information for each of our clients before they carry out any transaction:

For individuals

• Name and any other names used.
• National ID, passport or national identity card number, residence card, driver's license number, or other identification number.
• Residency information (address and/or utility company customer number, details, etc.).
• Biometric verification.
• Other additional client information if necessary to meet the requirements of the risk-based approach.

For companies or legal entities

• Company name.
• Principal place of business information.
• Contact information.
• Incorporation details (number on the relevant register, date of incorporation, etc.).
• Payment details and/or bank details.
• Relevant information about the place of residence (address details or utility customer details).
• Details of the persons authorized to operate on behalf of the company and their authorization details.
• Biometric verification of the entity's director(s).
• Other additional customer information if necessary to meet the requirements of our risk-based approach.

We will apply relevant risk-based measures to verify the identity of each customer and maintain the necessary records.

Risk Assessment

 In accordance with international requirements, La Tienda applies a risk-based approach to combating criminal activities. Therefore, measures aimed at preventing money laundering and terrorist financing are proportional to the identified risks, allowing resources to be allocated effectively. Resources are used based on priority; the higher the risk, the greater the attention.