AML & KYC Policy.

Last updated · 10 July 2026

A lending platform is only as trustworthy as the money that flows through it. This policy sets out how Fundaro prevents money laundering and terrorist financing - and what we will ask of you before you can lend.

1. Our commitment

Fundaro Ltd. ("Fundaro") is committed to full compliance with applicable anti-money-laundering (AML) and counter-terrorist-financing (CTF) rules, including Spanish Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing, its implementing regulation, and the EU Anti-Money-Laundering Directives. We apply a risk-based approach: the higher the risk, the deeper the checks.

2. Know Your Customer (KYC)

Before anyone can lend through Fundaro, we verify who they are. Depending on whether you participate as an individual or through a company, this includes:

• a valid government-issued identity document (passport or national ID card);
• proof of residential address;
• for legal entities: registry extracts, ownership structure and identification of ultimate beneficial owners (UBOs);
• where the risk profile warrants it, evidence of the source of funds and source of wealth.

Verification is completed before the first transaction. If we cannot complete it, we will not open the account, and we may have to end an existing relationship.

3. Enhanced due diligence

We apply enhanced due diligence to higher-risk situations, including politically exposed persons (PEPs) and their close associates, participants connected to high-risk jurisdictions identified by the EU or FATF, complex ownership structures, and activity that does not match a participant's known profile.

4. Sanctions screening

All participants are screened against applicable sanctions lists - including those of the European Union, the United Nations and, where relevant, OFAC - at onboarding and on an ongoing basis. We do not do business with sanctioned persons or entities.

5. Ongoing monitoring

Due diligence is not a one-off event. We keep participant information up to date, review it periodically and monitor transactions for patterns that are unusual for the participant or for the platform.

6. Reporting obligations

Where we know, suspect or have reasonable grounds to suspect that funds are connected to money laundering or terrorist financing, we report to SEPBLAC, Spain's financial intelligence unit, as the law requires. The law prohibits us from telling the person concerned that a report has been made ("tipping off").

7. Payments and cash

Fundaro accepts no cash under any circumstances. Funds must arrive by bank transfer from an account held in the participant's own name at a supervised credit institution. Third-party payments are not accepted, and repayments are made only to the verified account of record.

8. Record keeping

We retain identification documents, due diligence records and transaction records for ten years from the end of the business relationship, as required by Law 10/2010. These records are stored securely and processed in line with our Privacy Policy.

9. Governance and training

Responsibility for this policy sits with Fundaro's management, which designates a compliance officer responsible for AML/CTF matters. Everyone at Fundaro who touches onboarding or transactions receives regular AML training. This policy is reviewed at least annually and whenever the legal framework changes.

10. What this means for you

Expect us to ask for documents before you can lend, to ask follow-up questions when something needs clarifying, and occasionally to refresh your file. It is friction with a purpose: it keeps the courtyard clean for everyone.

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