General Standard on Imposition of Fines Applicable to General Warehouses

Page 1 of 18 CERTIFICATION OF RESOLUTION RUTH ELIZABETH ROJAS MERCADO, Secretary of the Monetary and Financial Board, CERTIFIES: that in Ordinary Session number sixteen of the Monetary and Financial Board, held on Wednesday, April 29, 2026, Resolution No. CDMF-XVI-1-26 was unanimously approved, which literally states:

Monetary and Financial Board Ordinary Session No. 16 Wednesday, April 29, 2026

RESOLUTION CDMF-XVI-1-26 THE MONETARY AND FINANCIAL BOARD

CONSIDERING

I That in accordance with Article 105 of the Complete Text of the "Political Constitution of the Republic of Nicaragua," banks and other financial institutions, private and state-owned, are supervised, regulated, and audited by the Superintendence of Banks and Other Financial Institutions, in accordance with the laws governing this matter.

II That Article 147 of Law No. 1232, "Law on the Administration of the Monetary and Financial System," published in La Gaceta, Official Gazette No. 241, of December 30, 2024, established a new range of fines for "supervised institutions" for violations of the provisions of said Law, related laws, and regulations, committed even by "other financial institutions," which will be applied by the Superintendence. Likewise, Article 148 of the aforementioned Law No. 1232 establishes the fines to be imposed on persons other than those mentioned in the aforementioned Article 147.

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 with the functions of the Central Bank and the Superintendence, the net worth and the penalty unit will be used as a reference. The value of each penalty unit corresponds to the national average 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 law governing this matter."

IV That Articles 9 (numeral 1), 30 (letter "a"), and 36 of Law No. 977, "Law against Money Laundering, Terrorism Financing, and Financing of Proliferation of Weapons of Mass Destruction," whose consolidated text is contained in Law No. 1175, "Law of the Nicaraguan Legal Digest of the Banking and Finance Matter," published in La Gaceta, Official Gazette No. 153, of August 20, 2024, and its subsequent reforms, empower the Superintendence of Banks and Other Financial Institutions to impose corrective measures and/or administrative sanctions when appropriate for the non-compliance with the AML/CFT/CPF prevention obligations applicable to institutions and natural persons under their supervisory scope in the aforementioned matter, expressly established in the aforementioned Law No. 977; without prejudice to what is provided in criminal legislation.

In exercise of its powers, HAS ISSUED The following,

GENERAL STANDARD ON IMPOSITION OF FINES APPLICABLE TO GENERAL WAREHOUSES

CHAPTER I GENERAL PROVISIONS

Article 1. Concepts.- For the purposes of applying the provisions contained in this standard, the terms indicated in this article, both in uppercase and lowercase, singular or plural, shall have the following meanings: a) Warehouse, Warehouses, or General Warehouses: Non-Bank Financial Institutions - Credit Auxiliaries subject to the surveillance and audit of the Superintendence of Banks and Other Financial Institutions. b) Warehouse Law: Law 734, General Warehouse Law, contained in Law No. 1175, "Law of the Nicaraguan Legal Digest of the Banking and Finance Matter," published in La Gaceta, Official Gazette No. 153, of August 20, 2024. c) Law No. 1232: "Law on the Administration of the Monetary and Financial System," published in La Gaceta, Official Gazette No. 241, of December 30, 2024. d) Fine: Administrative sanction of a pecuniary nature applied based on net worth or in penalty units. e) Operational and Financial Standard: Operational and Financial Standard of General Warehouses. f) Net Worth: Amount established in the supervised entity's financial statements, as defined in its applicable accounting framework. g) Superintendence: Superintendence of Banks and Other Financial Institutions. h) Superintendent: Superintendent of Banks and Other Financial Institutions. i) Titles: Deposit Certificates and Pledge Bonds. j) Penalty Units: Sanction of a pecuniary nature applied in accordance with what is established in Article 146 of Law No. 1232. The value of each penalty unit corresponds to the national average 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 law governing this matter.

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Article 2. Objective.- This Standard aims to establish the amounts of fines applicable to General Warehouses, within the ranges established in Title V, Chapter I of Law No. 1232, determined according to the severity of the offense and the cycle of recurrence.

Article 3. Scope.- The provisions of this Standard are applicable to all Warehouses authorized by the Superintendence to operate in the country.

Article 4. Parameters.- The Superintendent will apply and grade sanctions taking into account the following: a) Mitigating factors: These are the reasons that allow reducing the corresponding sanction, established as such the following:

1. If before the sanctioning procedure begins or before the Superintendent issues a resolution regarding it, the offender had remedied the infringing conduct on their own initiative or had presented an action plan consisting of the aspects that need to be remedied, indicating a proposal for a reasonable maximum date at the Superintendent's discretion for its completion and the persons responsible for executing it.
2. The historical behavior of the offender. b) Aggravating factors: The circumstances that make the committed offense or infringement more serious, established as such the following:
3. When the infringement causes damage to the public interest and/or the protected legal good, including the impact on public confidence in the area in which the offender conducts its activities.
4. When the offender has committed the infringement with the object of executing or concealing another infringement.
5. When the offender has obtained benefits for themselves or for third parties as a consequence of the infringement.
6. When the offender prevents or hinders the Superintendence from exercising its powers, either by preventing knowledge of the infringement, hiding information, delaying its delivery, or making control actions difficult, or in any other way that generates the same effect.
7. When due to the nature of the position and functions of the offender, they have specific responsibility regarding the fact that constitutes the infringement.
8. When the offender involves or uses one or more institutions operating in the supervised systems to commit the infringement. Likewise, when they involve or use one or more institutions operating in the financial systems of other countries.

Page 3 of 18 7) When the offender reoffends in the commission of any infringement according to the terms provided in Article 151 of the Warehouse Law. The payment of the fine does not exempt the offender from correcting the infringement or fault that generated it.

CHAPTER II INFRINGEMENTS AND FINES IN GENERAL

Article 5. Imposition of fine for infringements of law or lack of authorization.- It will be a serious infringement for any natural or legal person who, without being authorized, carries out General Warehouse operations, for which the Warehouse Law requires prior authorization. The Superintendent will impose a fine, from zero point two hundred fifty-one thousandths of a percent (0.251%) to zero point five tenths of a percent (0.5%) of the net worth.

Article 6. Imposition of fine for infringements of laws, resolutions, and instructions of the Superintendence.- When the Superintendent observes any infringement of the laws that the Superintendence is responsible for applying, including this standard and resolutions of the Monetary and Financial Board, as well as orders, resolutions, or instructions issued by the Superintendent, or irregularities are detected in the operation of the Warehouse, or documents or reports are received from them that do not correspond to their true situation, the Superintendent may impose fines in accordance with the following: a) Minor infringements: Minor infringements are those that do not affect the financial situation of the Warehouse, nor affect its liquidity, solvency, merchandise deposits, or the adequate fulfillment of its corporate purpose in accordance with the law governing this matter. The following are considered included in this category, among others:

1. Not sending, sending outside the established deadline, or sending incomplete or inaccurate reports, minutes, reports, forms, or other information, whether physical, electronic, or by any other means, that Warehouses must present to the Superintendence, occasionally or periodically, in accordance with the law, standards, or instructions of the Superintendent.

2. When provisions are not made for accounts receivable and for the allocation of goods received in the recovery of accounts receivable, in accordance with what is established in the standard on the evaluation of balances in accounts receivable and goods acquired in recovery by Warehouses.

3. The lack of placement of signs with the Warehouse's distinctive mark in visible places within the authorized premises.

4. When monthly inspections are not carried out selectively and with the minimum scope established in the applicable operational and financial standard.

5. The lack of updated documentation in insurance files.

Page 4 of 18 6) When the auction process is not carried out in accordance with the provisions established in the operational and financial standard.

7. That valid and/or uncancelled Pledge Bonds taken by the Warehouse, and/or blank forms, are not kept in secure places under the control of officials appointed by the Board of Directors or by the General Management of the Warehouse.
8. That the originals of the Deposit Certificates and Pledge Bonds that are returned by their holders for substitution, or because the merchandise has been released and/or withdrawn and/or all obligations derived from these documents have been cancelled, are not invalidated with a date and stamp of cancelled and/or that the titles that are invalidated are not invalidated with the stamp of voided and their originals and copies are not archived chronologically.
9. That the Unique Control Archive corresponding to each Deposit Certificate with or without Pledge Bond issued is not updated and/or available to the Superintendence personnel.
10. When complete and permanently updated records of merchandise inventory in deposit, as well as of the Deposit Certificates and Pledge Bonds issued, including cancelled, uncancelled, and voided ones, are not maintained.
11. When the lease contract for premises used by the Warehouse is not kept valid, while titles issued and uncancelled, backed by merchandise deposited in said premises, exist.
12. The lack of annotation and/or countersigning of merchandise deliveries in the control copies of the Deposit Certificate, as well as of releases in the copy of the Pledge Bond, archived in the unique file of said titles.
13. Any other infringements of equal or similar gravity that are committed against the legal, regulatory, and other provisions applicable to them, as well as instructions of the Superintendent. In these cases, a fine from zero point zero zero one percent (0.001%) to zero point one hundred twenty-five thousandths of a percent (0.125%) of the net worth will be applied.

b) Moderate infringements: Moderate infringements are those that affect the financial situation of the Warehouse without significantly impacting its liquidity, solvency, or merchandise deposits. Likewise, the following practices are considered as such those that weaken its corporate governance and generate an increase in its operational, legal, reputational, or other similar risks, provided that they are not included within the infringements classified as serious in the next paragraph. The following are considered included in this category, among others:

1. Recidivism of any of the minor infringements already sanctioned.

Page 5 of 18 2) When there is no written approval from the General Management of the Warehouse, or another instance duly authorized for this purpose, regarding the deposit of merchandise. 3) Granting documented credits (commercial credits without Pledge Bonds) failing to comply with any of the conditions established in the standard on financing granted by Warehouses and goods they acquire in recovery, regarding this matter. 4) Not provisioning documented credits (commercial credits without Pledge Bonds), which have not been converted into credits backed by Deposit Certificates and Pledge Bonds, as established in the standard on financing granted by Warehouses and goods they acquire in recovery. 5) Granting commercial credits with deposit certificates and pledge bonds failing to comply with any of the conditions established in the standard on financing granted by Warehouses and goods they acquire in recovery. 6) When commercial credits backed by Deposit Certificates and/or Pledge Bonds that have not been cancelled at maturity are not reclassified as overdue commercial credits upon sixty-one (61) calendar days from the maturity date; and/or when, after said reclassification, a provision of one hundred percent (100%) of the outstanding balance is not made. 7) That, in the case of allocation of goods received in the recovery of credits, provisions are not implemented in accordance with what is established in the regulations governing the matter on financing granted by Warehouses and goods they acquire in recovery. 8) That there is no or is not valid fidelity insurance for warehouse keepers and inspectors that responds to eventual failures of the same in the fulfillment of their responsibilities, or that the insured amount is less than fifty thousand United States dollars (US$50,000.00) or its equivalent in córdobas. 9) When the control of merchandise inventory is not carried out individually and by product, by physical or electronic means, and/or under the perpetual inventory system. 10) When the storage of merchandise does not maintain its ordering that facilitates location, counting, and verification of the same and/or when applicable, does not use a uniform system of pallets, units of measurement (boxes and/or sacks and/or bales etc., of the same characteristics and content) and/or equal weights, and in its case, labels and/or control cards. 11) Issuing deposit certificates and pledge bonds with empty spaces, smudges, stains, amendments, or alterations of any type and/or not indicating if the merchandise is subject to the payment of taxes, as well as, that any other special condition or observation regarding the merchandise and/or that the general terms and conditions specifying the rights and obligations of the parties do not appear on the reverse of these documents and are not printed in easily legible letters.

Page 6 of 18 12) When there is no updated analysis of the characteristics of the merchandise and/or an updated and acceptable valuation of the goods or merchandise backing the corresponding Deposit Certificate and Pledge Bond, in accordance with what is established in the operational and financial standard. 13) When goods that are not destined for the offices or activities proper to its corporate purpose are acquired, excepting those resulting from recoveries. 14) Any other infringements of equal or similar gravity that are committed against the legal, regulatory, and other provisions applicable to them, as well as instructions of the Superintendent. In these cases, a fine from zero point one hundred twenty-five one thousandths of a percent (0.1251%) to zero point twenty-five hundredths of a percent (0.25%) of the net worth will be applied.

c) Serious infringements: Serious infringements are those that affect the financial situation of the Warehouse and significantly impact its liquidity, solvency, or merchandise deposits. Likewise, the following practices are considered as such those that weaken its corporate governance and generate an increase in its operational, legal, reputational, or other similar risks. Non-compliance with provisions that prohibit or limit the carrying out of operations, transactions, or records also constitutes serious infringements, as well as acts carried out without observing the conditions established in the applicable laws or regulations. The following are considered included in this category, among others:

1. Recidivism of any of the moderate infringements already sanctioned.
2. Carrying out or exercising activities unrelated to its legally established corporate purpose.
3. Carrying out acts or operations prohibited by laws, regulations, and other applicable regulations.
4. Lacking the legally required accounting, keeping it without complying with accounting standards and other applicable regulations issued, recognized, or authorized by the Superintendence, or with irregularities that prevent knowing the patrimonial, economic, and financial situation of the Warehouse.
5. Refusing to present to the Superintendence accounting books, as well as any other information required of it in accordance with the law, regulations, and other regulations.
6. When it does not deliver in time and form the information requests that the Superintendent or its delegates make to the Warehouse, either for the realization of its on-site, remote, or off-site supervision activities or for the monitoring of compliance with periodic obligations or those that are specifically required of them, for the fulfillment of their inspection duties.
7. When the value of all Deposit Certificates that a Warehouse issues exceeds 30 times the amount of its capital calculation base.

Page 7 of 18 8) That the value of all deposit certificates that a Warehouse issues for the same client, natural or legal person, in authorized premises, exceeds 15 times its capital calculation base. 9) When the value of all merchandise received in deposit exceeds the limit established in Article 96 of the Warehouse Law. 10) Storing merchandise backing titles in premises not authorized by this Superintendence and/or when the requirements and conditions authorized by the Superintendent for the use of these premises have not been met and maintained. 11) When it is not stated in the Deposit Certificate issued with or without Pledge Bond that the merchandise may be subject to the incorporation of value-added processes and transformation, repair, and assembly, in accordance with letters e) and f) of Art. 57 of the Warehouse Law. 12) That the sale of merchandise is carried out when pledge bonds have been issued on them, without the written authorization of the holders of the Deposit Certificate and the Pledge Bond; prior to the delivery of these titles to the Warehouse. 13) Non-existence or unjustified absence of the warehouse keeper or inspector as the case may be and/or of permanent surveillance by the Warehouse 24 hours a day, in accordance with what is established in the regulations governing the matter on control, surveillance, and audit of general warehouses. 14) When pallets are not used to stack merchandise that may suffer damage from humidity or when, in this regard, what is established in the corresponding insurance policy is not complied with and if the policy indicates special particularities, these and their effects are not stated in the respective Deposit Certificate and Pledge Bond, or on a sheet attached to both titles. 15) When merchandise that may suffer damage from being exposed to the elements is stored, in lots and yards or in warehouses that are only roofed, unless its nature and process allow it. 16) When the corresponding contract of authorization and appointment of warehouse keeper is not signed in authorized warehouses. 17) When there are shortages of merchandise, the Warehouse: 1) does not take, at minimum and immediately, the necessary provisions to guarantee its interests and those of third parties and/or does not notify the Superintendent of said shortage immediately and/or, 2) does not carry out the relevant investigation to know the final detail of the shortage in physical units and values within 15 days following its discovery and does not notify the Superintendent within the following 3 days subsequent the actions taken before the corresponding authorities and the respective insurance company. 18) When the authorization granted by the Superintendence is not kept valid while there are titles issued and uncancelled backed by merchandise deposited in the respective premises.

Page 8 of 18 19) When there is no written and documented pronouncement derived from the review and analysis process of storage requests, evaluating, at least, the substantive aspects established by the operational and financial standard of general warehouses. 20) When there is no system or mechanism for inventory control in the premises where merchandise backing Deposit Certificates, with or without Pledge Bonds, is stored. 21) The non-existence of insurance and/or the non-validity of the same that protects: i. The merchandise in deposit and warehouses or deposits belonging to the Warehouse, ii. Rented real estate belonging to third parties, unless these were insured by their owner, or if this exempts the Warehouse from all responsibility in case of a disaster affecting them. 22) The acceptance of endorsements failing to comply with the required requirements; and/or the acceptance of partial endorsements of insurance policies in which the warehouse operator does not appear as first in the order of payment priority; and/or the lack of supervision and timely follow-up on insurance endorsed in favor of the Warehouse, in accordance with what is established in the operational and financial standard of Warehouses. 23) The direct contracting or endorsement of policies in which indiscriminate location coverage is established. 24) The celebration of agreements, addenda, or clauses of endorsement appointment and/or other instrument or legal document in which, explicitly and/or tacitly, insurance companies, national or international residing in the country, evade or exempt themselves from the direct responsibility of assuming the risks

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