Attachment B: El Dorado Funds Movement Levels

Introduction to KYC and KYB

KYC, known by its English acronym "Know Your Customer", is a process through which financial institutions and other entities verify the identity of their customers, ensuring they are who they claim to be. This verification is essential to prevent fraud, money laundering, and other illicit activities.

KYB, or "Know Your Business", is a similar process but aimed at business entities. Through this process, the identity and legitimacy of a business are verified to ensure it operates according to legal and regulatory standards.

KYC Levels in El Dorado

a. No Level: It is the initial state of a user upon registration.

   - Allowance: 0 stable cryptocurrency/month.

b. Level 0: Basic access to the application.

   - Requirements: Report country and city of residence.

   - Allowance: 0 stable cryptocurrency/month.

c. Level 1: Permission to move funds based on the country.

At the time of registration, and according to the country of residence declared by the user and the documentation provided, the application will indicate whether Level 1 or Level 2 verification must be completed in order to perform transactions.

The applicability of the levels is detailed below:

User Country
Level 1 Applicable
Access / Transactions
Requirements
Allowance:
Argentina
No
Basic access to the application; cannot perform transactions until completing Level 2
Phone verification
0 stablecoin units/month
Rest of the countries where the El Dorado operates
Yes
Can perform transactions within the application
First name, last name, age, phone, and identity document
Up to 250 stablecoin units/month

d. Level 2: Standard KYC.

   - Requirements: Complete the verification process through the third-party verification system (SumSub) (phone verification is not required again as it was done in Level 1).

   - Allowance: 10,000 stable cryptocurrency/month.

e. Level 3: Intensified KYC.

   - Requirements: As indicated by the El Dorado platform and/or the customer service team, complete a document called intensified KYC in which the user must provide more information about their economic activity and the origin of their funds. Completing these documents, and any other requested by El Dorado, will be an essential requirement to be able to move more than 10,000 stable cryptocurrency/month up to the amount of 250,000 stable cryptocurrency/month.

 - Allowance: 250,000 stable cryptocurrency/month, taking USDT as a reference.

If the request is not approved from the compliance area, the user will be banned and therefore the funds will be returned, as indicated in these terms.

f. Level 4: Complete KYC.

   - Requirements: As indicated by the El Dorado platform and/or the customer service team, complete a document called Complete KYC. Completing these documents, and any other requested by El Dorado, is a mandatory requirement to move more than 50,000 stable cryptocurrency/month up to an amount of 1,000,000 stable cryptocurrency/month.

   - Allowance: Estimated at 1,000,000 stable cryptocurrency/month, referencing USDT.

Allowance and its Implications

The "allowance" refers to the maximum amount a user can move within the application in a calendar month. Any operation, whether it's a transfer, deposit, or offer creation, increases the allowance usage by the value of that operation. If a user closes an offer without completing it, the allowance will adjust by reducing the corresponding amount.

a. Allowance Limit: If a user reaches their allowance limit, they will not be able to perform additional operations until the following calendar month. If desired, they can advance to the next KYC level to increase their allowance.

b. Current Users: A migration of users with previously verified KYC to Level 2 has been performed. The migration process of users with prior intensified KYC to Level 3 is pending implementation by the IT team. The date for this migration is October 17, 2023.

c. Offer creation: Only users who have completed at least 15 orders as MT will be allowed to create offers on the platform. This requirement seeks to ensure that users have experience in conducting transactions before being able to post advertisements. In addition, they must have accumulated a transaction volume of at least 300 stable cryptocurrency/month, using USDT as a benchmark. This requirement seeks to ensure that users have a minimum transaction volume on our platform before they can post ads.

These levels and allowances are designed to ensure security and transparency in our operations, as well as to comply with current regulations.

Last modification: December 16, 2025

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