1. THE COMPLIANCE PROGRAM

Over Global Trust has an effective Policy on the Prevention of Money Laundering and the Financing of Illicit and Terrorism (PLD/FIT). Over Global Trust's activities are guided by the content of its PLD/FIT Policy, always evolving and in line with the characteristics of its market, as well as by legal, normative and ethical imperatives applicable to its activity. In this way, Over Global Trust assures its customers and regulatory bodies and other members of the market the smoothness of its operations. The PLD/FIT Policy is structured to combat the commission of illicit acts, divided into different components that converge for this purpose. Like the other entities of the financial system, Over Global Trust values ​​the identification of its customers - an identification that must be kept up to date, in line with the recommendations of the Financial Action Task Force (FATF) and the Bank for International Settlement (BIS). Indeed, people identified as politically exposed will be treated differently by the Over Global Trust team. Another pillar of the PLD/FIT Policy is the registration and identification of transactions. In the case of a market where transactions take place at significant amounts and speed, the potential for illegal practices cannot be ignored. In this way, Over Global Trust remains attentive to the financial transactions carried out under its supervision - being they between crypto, whether in fiat currencies or among other businesses, the group will always be willing to collaborate with competent authorities in case of suspected violation of the law. It is also noteworthy that Over Global Trust does not receive cash, thus ensuring transparency and documentation of transactions. Equally important is the preparation of the team. In addition to those directly involved with the compliance sector, everyone must be aware of evidence of illegal acts and be willing to identify and report such behavior to the competent sector. The compliance culture is reinforced by everyone on the Over team; from their CEO to the newest employee, everyone understands the relevance of the PLD/FIT Policy. Still in this field, the transactions to be carried out at the Over Global Trust will respect limits corresponding to the degree of documentation of the client. That is: in order to move higher amounts, Over clients must undergo greater scrutiny, and their request for limit expansion may be denied. New documents can be ordered at any time, and collaboration with demands is essential. These grounds presented herein in no way enclose the PLD/FIT Policy of the Over Global Trust; it shows here only the degree of commitment of the Over Global Trust to compliance with the law and its appreciation for good faith and transparency.

2. CRYPTACTIVE MARKET RISK

Crypto assets are not fiat money. This means that they are not regulated by any central bank or other governmental entity and, depending on their characteristics, may not have any intrinsic value. The risk of financial losses is a factor to be considered during any transaction.

3. APPLICABLE STANDARDS

The legal norms that regulate the crypto market are still scarce. However, Over Global Trust remains in harmony with the legal dictates that regulate the traditional financial market.

Seeking to mitigate the risks of illegal acts - financial or not - Over Global Trust developed its PLD/FIT program in compliance with recommendations and laws of different bodies and jurisdictions. It is worth noting that Over is not a traditional financial institution, which is why, in principle, the rules dedicated to companies in this segment are not fully applicable to Over Global Trust. However, because it understands that combating illicit acts is a common objective for all, Over Global Trust is in constant search and implementation of the dictates that best lead to this end.

Any and all requests for cooperation from authorities, when reasonable and legitimate, will be granted by Over Global Trust. Likewise, the committing of illicit acts will not be tolerated, with the corresponding denunciation to Organs competent bodies. Over Global Trust reserves the right to refuse or terminate relationships with any person or entity that is not in line with its ethical principles, with its Terms of Use, with its Data Policy, with its Money Laundering Prevention Policy and Financing of Illicit and Terrorism, or with any other document that indicates the parameters of Over Global Trust's performance.

4. COUNTRIES NOT SERVED

Due to the inherent risk of operations with these States, Over will not serve individuals or legal entities resident, headquartered or dependent in the following jurisdictions: Afghanistan, Saudi Arabia, Bahamas, Botswana, Cambodia, North Korea, Ethiopia, Ghana, Guam, Guinea-Bissau, Yemen, US Virgin Islands, Iran, Iraq, Lebanon, Libya, Mali, Nigeria, Panama, Pakistan, Puerto Rico, Central African Republic, Democratic Republic of the Congo, Samoa, American Samoa, Serbia, Syria, Somalia, Sri Lanka, Sudan, South Sudan, Trinidad and Tobago, and Tunisia. In turn, people with connections to Balkan states (Albania, Bosnia and Herzegovina, Bulgaria, Greece, North Macedonia, Montenegro, Serbia, Kosovo, Croatia, Romania and Slovenia), Belarus, Burundi, Cuba, Nicaragua, Ukraine, Venezuela and Zimbabwe must undergo a differentiated registration procedure. Finally, regardless of the exclusion of the aforementioned jurisdictions, Over Global Trust's operations are not available to residents of the United States of America or China.

5. COOPERATION WITH PUBLIC AUTHORITIES

The Over Global Trust values ​​cooperation with public agencies in combating corruption, money laundering and terrorist financing. Any authority can contact Over Global Trust in order to comply with legal, judicial or regulatory determinations through the following channel: [email protected] .

6. COMPLAINTS

Anyone who becomes aware of illegal practices that, in any way, involve the Over Global Trust, must immediately communicate to Over Global Trust through internal communication channels, in particular, the following e-mail address: [email protected]

Anonymous complaints are accepted, provided they are corroborated with evidence or evidence that allows the internal team to elucidate the facts.

7. FINAL DECLARATIONS

The Policy for the Prevention of Money Laundering and the Financing of Illicit and Terrorism, in its entirety, is only available to those who maintain an extremely close relationship with the Over Global Trust, due to the need for confidentiality of the compliance measures adopted.

The refusal to provide any documents or information requested by the Over Global Trust may lead to the termination of the relationship, without any reason being given for this. If there is the same document with translations in different languages, the Portuguese version will prevail.

Updated January 8th, 2021.