1. Objective
This Revolut Anti-Money Laundering and Counter-Terrorist Financing Policy ("Policy") was drafted in accordance with the regulations of the Central Bank of Brazil, with the objective of consolidating the procedures, rules, internal controls, and guidelines that govern the actions of all collaborators in preventing and combating these illicit practices.
2. Scope
This Policy applies, without restrictions, to all individuals (hereinafter referred to as "collaborators"), regardless of the type of relationship they have with Revolut. This includes directors, partners, employees, interns, and any other person who provides services to Revolut, even if on an occasional basis, such as service providers and suppliers.
3. Guidelines
Revolut conducts its business with ethics, integrity, and transparency, recognizing that the prevention of money laundering and terrorist financing is a shared responsibility among clients, collaborators, partners, and society.
Through this Policy, Revolut reaffirms its commitment to adopting best practices and continuous efforts to prevent and combat money laundering and terrorist financing, rejecting any conduct inconsistent with current legislation.
Revolut’s Board of Directors maintains its commitment to ensuring an environment of effective internal controls, aligned with the requirements of regulatory bodies and market best practices.
3.1. Money Laundering
Money laundering is the process used to give the appearance of legality to resources obtained illicitly. This crime seeks to conceal the origin and those responsible for the funds, making them difficult to track.
It generally occurs in three stages: placement, when the money is inserted into the financial system; layering (or concealment), when its origin is disguised; and integration, when the funds return to the economy with a legitimate appearance.
Preventing this type of practice is essential to promoting transparency, ethics, and integrity in the financial environment.
3.2. Terrorism Financing
Terrorism is characterized by the practice of violent or threatening acts with the intention of causing widespread fear or insecurity, endangering people, assets, and public peace. These acts may involve the use of explosives, chemical, biological, or nuclear weapons, sabotage of essential services, cyber-attacks, or attacks against the life and physical integrity of individuals, motivated by discrimination, prejudice, or intolerance.
It is important to highlight that terrorist financing differs from money laundering: in financing, the resources used may be of licit or illicit origin, whereas in money laundering, the funds are always derived from illegal activities.
The prevention of these practices is fundamental to strengthening security, ethics, and compliance in the organization's operations and throughout society.
4. Our Prevention and Compliance Practices
At Revolut, we adopt rigorous policies and controls to ensure integrity and transparency in all our relationships. Among the main practices for preventing money laundering and terrorist financing, the following stand out:
- Know Your Customer (KYC): We maintain structured processes to identify, classify, and monitor the risk of each client, ensuring the collection, verification, and continuous updating of their registration information.
- Know Your Supplier (KYS) and Know Your Partner (KYP): We implement due diligence procedures to evaluate and classify the risk of suppliers and service providers, avoiding partnerships with companies that show signs of irregularities.
- Know Your Employee (KYE): We establish internal controls and verification processes aimed at preventing and detecting irregular conduct by our collaborators, reinforcing the culture of ethics and compliance.
- Risk Assessment and Monitoring: We conduct periodic risk analyses and monitor suspicious transactions and activities, adopting preventive measures to mitigate possible threats and strengthen our internal controls.
- Training and Communication: We promote continuous training and awareness programs, ensuring that all collaborators are informed about best practices and the risks related to money laundering and terrorist financing.
5. Whistleblowing Channel
At Revolut, we cultivate a culture of ethics, transparency, and responsibility. Therefore, we encourage all our collaborators to report, in good faith, any concern related to potential, suspected, or proven misconduct, including legal, regulatory infringements, or violations of internal policies.
These communications may involve past, ongoing, or future situations. Every collaborator has the duty to contribute to the detection, prevention, and reporting of practices that are inconsistent with our values and this Policy.
Reports must be made through the Whistleblowing Channel (Speak Up Portal), which guarantees confidentiality, impartiality, and, if desired, total anonymity for the whistleblower. All investigations are conducted fairly, confidentially, and independently, ensuring the protection of the whistleblower's identity and the integrity of the process.
Revolut adopts a zero-tolerance policy for retaliation. Any form of reprisal, discrimination, or attempt to identify the whistleblower is strictly prohibited and constitutes a serious violation of internal policies.