SANCTIONS COMPLIANCE POLICY

1. Introduction

SpeedSellX (“SpeedSellX LLC,” headquartered in the United States, and its subsidiaries in Brazil Apex Speedsellx Tecnologia em Pagamentos Ltda and Speedsellx Ltda) is a global platform specialized in the sale and distribution of digital and nutraceutical products, either proprietary or provided by third parties, operating in North America, Latin America, Europe, and other regions, not limited to these locations.

In SpeedSellX’s business model, authorized producers may make their products available for commercialization, with all sales to the end customer conducted by SpeedSellX as the legal seller (Merchant of Record).

SpeedSellX ensures that the end customer has adequate support and service channels, provided directly by the company or through authorized producers, guaranteeing that all demands are handled effectively and in compliance with applicable law.

All payments are processed by payment service providers duly licensed and regulated in their jurisdictions. SpeedSellX maintains strict internal controls to ensure that no transaction conducted through its platform violates economic sanctions laws or trade restrictions.

This Sanctions Compliance Policy establishes clear guidelines to ensure the company operates within the highest international compliance standards, protecting its integrity, reputation, and relationships with customers, affiliates, producers, and partners.

2. Objective

● Ensure full compliance with laws, regulations, and sanctions regimes of multiple jurisdictions, including but not limited to:

○ Office of Foreign Assets Control (OFAC) – United States;

○ United Nations Security Council (UNSC);

○ European Union (EU);

○ Office of Financial Sanctions Implementation (OFSI) – United Kingdom;

○ Conselho de Controle de Atividades Financeiras (COAF) – Brazil;

○ Additional sanctions and regulations from applicable national and international authorities.

● Prevent the platform from being used, directly or indirectly, to circumvent or violate international sanctions;

● Preserve the trust of customers, affiliates, producers, business partners, and payment service providers;

● Ensure all transactions align with international security and compliance standards.

3. Scope

This policy applies to:

● Affiliates and producers registered with SpeedSellX;

● Employees, administrators, and directors of the company;

● All transactions and operations conducted by SpeedSellX, regardless of currency, country of origin, or destination;

● Any commercial relationship that, directly or indirectly, could expose the company to sanctions violation risks.

4. Key Guidelines

SpeedSellX adopts a zero-tolerance policy for transactions with persons, entities, or countries listed or identified as subject to economic sanctions.

It is strictly prohibited to:

● Conduct or facilitate transactions with any individual, legal entity, or organization listed on:

○ OFAC – Specially Designated Nationals (SDN List);

○ ONU – Sanctions List;

○ UE – Consolidated Sanctions List;

○ UK – Consolidated List of Financial Sanctions Targets;

○ National sanctions lists (including COAF and Federal Revenue Service in Brazil);

○ Other applicable international lists, not limited to those mentioned.

● Structure or disguise transactions to circumvent sanctions;

● Use third parties, shell companies, or triangulated operations with sanctioned countries to conceal the true beneficiary;

● Provide products or services to customers or affiliates operating in high-risk sectors prohibited by this policy, as well as any direct or indirect attempt to circumvent, facilitate, or collaborate with operations involving sanctioned individuals, entities, or countries.

5. Verification and Monitoring Processes

SpeedSellX maintains ongoing systems and procedures to identify and prevent sanctions violations, including:

● Automated screening of affiliates and producers against international and national sanctions lists;

● Maintaining relationships only with payment providers duly licensed and regulated in their jurisdictions;

● Verification during onboarding and periodic monitoring of affiliates and producers;

● Tiered review according to risk identified in the affiliate or producer profile;

● Constant updating of sanctions and PEP (Politically Exposed Persons) databases.

All operations suspected or inconsistent with this policy are blocked preventively until compliance analysis is concluded.

6. Reporting and Cooperation Procedures

SpeedSellX operates under the Merchant of Record (MoR) model, assuming the legal seller position in all transactions made through the platform. Thus, before customers, payment service providers, and competent authorities, SpeedSellX is formally responsible for commercial operations, even if the marketed product was made available by a registered producer.

When any activity is identified that may constitute legal infractions, regulatory violations, or breaches of the company’s internal policies involving affiliates or producers, the following protocol will be adopted:

1. Immediate action and internal measures

● Immediate suspension of the suspicious offer or product, with preventive blocking of financial disbursements to the affiliate or producer;

● Preservation and recording of all relevant evidence, including promotional materials, product content, communications, transaction records, access history, and any associated

technical or audit reports;

● Classification of the case according to severity and risk, prioritizing incidents with potential regulatory, financial, or reputational impact.

2. Communication to payment service provider

● Secure and timely forwarding of all information and evidence to the payment processor (e.g., Stripe, Dlocal, etc.);

● Considering such providers are licensed and regulated entities, they will be responsible for formally filing Suspicious Activity Reports (SARs) or equivalents with competent authorities such as FinCEN (USA), COAF (Brazil), or corresponding entities in other jurisdictions.

3. Direct communication to authorities (when applicable)

● In situations with clear evidence of criminal offense, SpeedSellX may, at its discretion or by legal obligation, communicate directly to police, prosecutorial, or judicial authorities regardless of reporting by the payment provider;

● In Brazil, such communications may include but are not limited to Civil Police, Federal Police, and Public Prosecutor’s Office. In foreign jurisdictions, communication will be directed to the relevant local authorities.

4. Assignment of responsibilities

● As Merchant of Record, SpeedSellX assumes initial responsibility before customers, payment partners, and authorities;

● However, the involved affiliate or producer will be held civilly, administratively, and criminally liable for illicit conduct, as provided in Terms of Use, commercial contracts, and other platform policies;

● SpeedSellX reserves the right to take legal actions for damages, freezing of funds, and enforcement of contractual guarantees.

7. Training, Awareness, and Compliance Culture

● Mandatory training includes all employees, covering operational, marketing, support, management, and technology development teams, with content adapted to each area’s responsibilities;

● Specific modules on Compliance, covering international sanctions standards, anti-money laundering, risk identification, and good governance practices;

● Content continuously updated according to global regulatory changes;

● Practical simulations and case studies to reinforce policy application in daily activities;

● Formal recording of participation and assessment of each employee’s understanding and application of the content.

8. Consequences for Non-Compliance

Any violation of this policy may result in:

● Immediate termination of the commercial relationship with the affiliate or producer;

● Freezing of pending payments and benefits;

● Communication to competent authorities, when applicable;

● Adoption of legal and reparative measures.

9. Review and Update

This policy will be reviewed annually or whenever there is a relevant change in regulations, sanctions regimes, or international compliance standards.

10. Final Provisions

This policy must be interpreted and applied together with SpeedSellX’s Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT). Both are mandatory for all internal SpeedSellX employees and must be observed by affiliates and producers as a condition for platform use.

Contact for questions or reports: compliance@speedsellx.com