Norm Reforming Articles 1, 38, 41 and Adding Article 38 Bis to the Standard for the Authorization and Operation of Insurance Intermediaries

Page 1 of 5 CERTIFICATION OF RESOLUTION RUTH ELIZABETH ROJAS MERCADO, Secretary of the Monetary and Financial Board, CERTIFIES: that in Ordinary Session number twelve of the Monetary and Financial Board, held on Wednesday, March 25, 2026, Resolution No. CDMF-XII-5-26 was unanimously approved, which literally states: Monetary and Financial Board Ordinary Session No. 12 Wednesday, March 25, 2026 RESOLUTION CDMF-XII-5-26 THE MONETARY AND FINANCIAL BOARD CONSIDERING I That in accordance with Article 105 of the "Political Constitution of the Republic of Nicaragua," banks and other financial institutions, both private and state-owned, are supervised, regulated, and audited by the Superintendence of Banks and Other Financial Institutions, in accordance with the relevant laws. II That Article 148 of Law No. 1232, "Law on the Administration of the Monetary and Financial System," published in La Gaceta, Official Journal No. 241, of December 30, 2024, established a new range of fines to be imposed on persons other than those mentioned in Article 147 of the same Law. III That Article 146 of Law No. 1232, "Law on the Administration of the Monetary and Financial System," establishes that "For the application of the fines contemplated in this Law and related laws concerning the functions of the Central Bank and the Superintendence, the net worth and the fine unit will be used as reference. The value of each fine unit will correspond to the average national minimum wage on the date of imposition of the fine, which is the simple average calculated based on the Minimum Wage Table by Activity Sector determined by the relevant law." IV That in accordance with the above consideration and based on the power granted by Article 17, letter A, numbers 1), 3) and 10), and letter C, number 1), of Law No. 1232, "Law on the Administration of the Monetary and Financial System." In exercise of its powers, HAS ISSUED

Page 2 of 5 The following: STANDARD REFORMING ARTICLES 1, 38, 41 AND ADDING ARTICLE 38 BIS TO THE STANDARD FOR THE AUTHORIZATION AND OPERATION OF INSURANCE INTERMEDIARIES FIRST: Amend letter l) of Article 1 and Article 41 of the "Standard for the Authorization and Operation of Insurance Intermediaries," contained in Resolution No. CD-SIBOIF-719-2-MAR14-2012, of March 14, 2012, published in La Gaceta, Official Journal No. 79, of May 1, 2012, which shall read as follows: "Article 1. Concepts.- For the purposes of this Standard, the concepts indicated in this article, whether in uppercase or lowercase, singular or plural, shall have the following meanings: (...) l) Fine Unit: As established in Article 146 of Law No. 1232, Law on the Administration of the Monetary and Financial System, published in La Gaceta, Official Journal No. 241, of December 30, 2024, the value of each fine unit will correspond to the average national minimum wage on the date of imposition of the fine, which is the simple average calculated based on the Minimum Wage Table by Activity Sector determined by the relevant law." "Article 41. Sanctions applicable to insurance intermediaries.- In accordance with what is established in Article 148 of Law No. 1232, "Law on the Administration of the Monetary and Financial System," published in La Gaceta, Official Journal No. 241, of December 30, 2024, for infractions committed by insurance intermediaries, the Superintendent may impose the following sanctions: a) Reprimand; b) Monetary sanctions:

1. For minor infractions: Between zero point zero one (0.01) and ten (10) fine units;
2. For moderate infractions: Between ten point zero one (10.01) and fifty (50) fine units; and
3. For grave infractions: Between fifty point zero one (50.01) and one hundred (100) fine units. c) Suspension of the authorization for a period of between one (1) to six (6) months; and d) Revocation of the authorization. The decision to suspend or revoke the authorization of an insurance intermediary will be taken by the Superintendent following the procedure established in the final part of Article 167 of the General Insurance Law."

Page 3 of 5 SECOND: Add Article 38 bis to the "Standard for the Authorization and Operation of Insurance Intermediaries," contained in Resolution No. CD-SIBOIF-719-2-MAR14-2012, of March 14, 2012, published in La Gaceta, Official Journal No. 79, of May 1, 2012, which shall read as follows: "Article 38 bis. Infractions of insurance intermediaries in matters of AML/CFT/CPF.- As indicated in Article 148 of Law No. 1232, Law on the Administration of the Monetary and Financial System, with respect to the prevention of money laundering, asset or property laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction, insurance intermediaries shall be sanctioned by the Superintendent for each of the infractions they commit against the legal and regulatory obligations in this matter, in accordance with the following: Minor Infractions:

1. When the AML/CFT/CPF training program is inadequate or inconsistent with the complexity, size, or risk profile of the Intermediary; or said program is executed deficiently.
2. Sending the Monthly Cash Transaction Reports (CTR) outside the established deadline, which must be submitted in accordance with the regulatory provisions established by the SIBOIF and the UIF.
3. Sending outside the established deadline or not sending the monthly communication of no cash transactions to report to the SIBOIF and/or Report of Absence of Information of Interest (RAII) to the UIF, in accordance with the regulatory provisions issued by these authorities. Moderate Infractions:
4. The AML/CFT Program presents material or significant deficiencies, both in its content, as well as in its execution or management and/or its implementation is deficient or increases the risk profile of the Intermediary.
5. When the Internal Policies and Procedures Manual for the prevention of AML/CFT/CPF risks exists, it: i. Is not updated in accordance with the latest changes made to the laws and regulations in this matter and duly approved by the board of directors of the brokerage company or, in its case, by the Individual Broker. ii. Is inadequate or inconsistent with the complexity of its financial products and services, service technology and business or its risk profile. iii. Does not contain a Customer Due Diligence (CDD) Policy that is consistent with those applied by the Insurance and/or Reinsurance companies with which it is linked. iv. Does not include policies on the filing, backup, safeguarding, custody, maintenance, conservation, and access to records, files, files, transactions, and other data, which, in accordance with the laws and regulations in this matter, are subject to retention, either physically or electronically, or that, if they exist, are inadequate or deficient, or are being applied deficiently. v. Does not include procedures for the monitoring and detection of AML/CFT/CPF alerts, through transactions carried out by the Intermediary, or, if these procedures exist, are inadequate or deficient, or are being applied deficiently. vi. Does not include procedures for the detection, analysis, scrutiny, documentation, escalation, and decision to report or not, of activities and operations or transactions unusual qualified as suspicious of constituting money laundering and/or terrorist financing or financing of the proliferation to the competent authority, or, if these procedures exist, are inadequate or deficient, or are being applied deficiently; or the tools used for the monitoring of the intermediary's transactions are not appropriate to the complexity and volume of its insurance operations.
6. The physical or electronic documentation regarding the identification, verification measures, and customer and/or beneficial owner due diligence is incomplete or inappropriate in accordance with the minimum requirements of the laws and regulations in this matter and/or its "Know Your Customer" policies denote an inadequate or deficient realization of the Due Diligence of the customer and Beneficial Owner knowledge.
7. Sending incomplete or inaccurate Monthly Cash Transaction Reports (CTR), which must be submitted in accordance with the laws and regulations in this matter, instructions of the Superintendent, and others applicable to it.
8. Notifying late to SIBOIF and the UIF, about the non-realization of reportable cash transactions, which must be informed within the legal deadline and through a negative communication note, in accordance with the laws and regulations in this matter, instructions of the Superintendent, and others applicable to it.
9. That the financial, human, technological, and material resources assigned by the Intermediary for the execution of the AML/CFT Program are not appropriate to the volume, complexity of its financial products and services, service technology and business or its risk profile.
10. That it does not have a formal AML/CFT training program, with its corresponding budget allocation for its execution appropriate to its volume of operations and personnel. Grave Infractions:
11. Not attending the trainings to which they are summoned by the Insurance and/or Reinsurance companies with which they have business links.
12. Not sending the Monthly Cash Transaction Reports (CTR) or not sending to SIBOIF the negative communication of non-existence of reportable cash transactions for the month or, to the UIF the Reports of

Page 4 of 5 Absence of Information of Interest (RAII), which must be submitted in accordance with the laws and regulations applicable in this matter when there are no transactions that meet the threshold. 3) Not having an AML/CFT Program with its respective Internal Policies and Procedures Manual of AML/CFT or not being updated in accordance with the laws and regulations in this matter. 4) When the intermediary does not comply with the obligation to report to the competent authority according to the law in this matter, the unusual operations or transactions that are suspected of constituting the crime of money laundering and/or terrorist financing and/or financing of the proliferation of weapons of mass destruction. The maximum of this sanction will be applied when an ostensibly suspicious operation is not reported. 5) When the director, manager, official, or any other employee of the intermediary discloses or informs the client that their transaction is being analyzed or considered for a possible Suspicious Activity Report (SAR) or informs them that such report has been filed. In the case of grave infractions or their recurrence, the Superintendent may additionally order the definitive removal from office of the offender or the cancellation of the authorization to operate." THIRD: Repeal number 5, of letter a) of Article 38 of the "Standard for the Authorization and Operation of Insurance Intermediaries," contained in Resolution No. CD-SIBOIF-719-2-MAR14-2012, of March 14, 2012, published in La Gaceta, Official Journal No. 79, of May 1, 2012. FOURTH: This standard will enter into force from its notification by the Superintendence of Banks and Other Financial Institutions. Publish it in the media determined by the Superintendence. (f) legible, Ovidio Reyes R. President of the Board; (f) Illegible, Luis Ángel Montenegro Espinoza, Vice President of the Board; (f) Illegible, Nicolás Espinoza Rivera, Deputy Minister of Finance, Substitute Member; (f) Illegible, Roberto Rivas, Executive Member; (f) Illegible, Hugo Ortega, Executive Member. (End of the Resolution text). It conforms with its original which was duly collated, and based on the powers conferred in Article 40 of the Internal Regulations of the Monetary and Financial Board, issues this Certification with reason of rubric, signature and seal, in the city of Managua on March 26, 2026. Ruth Elizabeth Rojas Mercado Secretary of the Board