Resolution SBS No. 1695-2016: Standard for the Prevention of Money Laundering and Terrorist Financing Applicable to Legal Entities Operating Casino Games and/or Slot Machines

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239

Lima, March 23, 2016

Resolution S.B.S.
No. 1695-2016

The Superintendent of Banks, Insurance, and Private Pension Fund Administrators

CONSIDERING:

That, through Law No. 27693 and its modifying regulations, the list of obligated subjects to report to those responsible for implementing a system for the prevention of money laundering and terrorist financing is established, which involves, among other aspects, reporting on suspicious operations and designating a compliance officer duly accredited before the Financial Intelligence Unit of Peru (UIF-Peru), responsible for receiving, analyzing, processing, evaluating, and transmitting information for the detection of money laundering and terrorist financing;

That, through Article 8 of Law No. 27693 and its modifying regulations, as well as Article 3 of the Law incorporating the UIF-Peru into the Superintendence of Banks, Insurance, and Private Pension Fund Administrators (SBS) - Law No. 29038, it is provided that casinos, game houses, slot machines, and others similar are obligated subjects to report, among others;

That, in accordance with Law No. 27153, Law regulating the exploitation of casino games and slot machines, and its modifying regulations, the Ministry of Foreign Trade and Tourism - MINCETUR, through the General Directorate of Casino Games and Slot Machines of the Vice Ministry of Tourism, is the competent authority to authorize, inspect, supervise, evaluate, and sanction the activity of exploiting casino games and/or slot machines;

That, through Ministerial Resolution No. 063-2009-MINCETUR/DM, Directive No. 001-2009-MINCETUR/DM, "Standards for the prevention of money laundering and terrorist financing, applicable to companies that exploit casino games and slot machines," was approved, currently in force;

That, in accordance with what is provided by Article 3 of Law No. 27693, modified by the first complementary modifying provision of Legislative Decree No. 1106, Legislative Decree for effective struggle against money laundering and other crimes related to illegal mining and organized crime, it is the function and faculty of the SBS, through the UIF-Peru, to regulate - in coordination with the supervisory bodies of the obligated subjects - the general and specific guidelines, requirements, clarifications, sanctions, and other aspects related to the prevention systems of the obligated subjects to report and of the reports of suspicious operations and operation records, as well as to issue models of codes of conduct, manual for the prevention of the crime of money laundering and terrorist financing, format for operation records, among others, in accordance with the scope of what is provided in said law and its regulations;

That, in this context, it is necessary to approve a new standard for the prevention of money laundering and terrorist financing applicable to legal entities that exploit casino games and/or slot machines, which in addition to complying with the obligations established in Law No. 27693, its modifying and regulatory norms, adapts to the new Forty Recommendations of the Financial Action Task Force – FATF, which establish international standards and promote the effective implementation of legal, regulatory, and operational measures to combat money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction;

Having the approval of the Financial Intelligence Unit of Peru and the Adjunct Superintendence of Legal Advice, in coordination with MINCETUR, and having complied with the dissemination period of draft legal norms of a general nature referred to in Article 14 of the Regulation that establishes provisions relative to the publicity, publication of normative projects, and dissemination of legal norms of a general nature, approved by Supreme Decree No. 001-2009-JUS and its modifying regulations;

In exercise of the powers conferred by Law No. 26702, Law No. 27693, as well as Law No. 29038, and their modifying regulations;

RESOLVES:

Article 1.- Approve the Standard for the Prevention of Money Laundering and Terrorist Financing Applicable to Legal Entities Operating Casino Games and/or Slot Machines, which is transcribed below:

STANDARD FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING APPLICABLE TO LEGAL ENTITIES OPERATING CASINO GAMES AND/OR SLOT MACHINES

TITLE I
GENERAL PROVISIONS

Article 1.- Scope
This standard is applicable to legal entities that exploit casino games and/or slot machines, authorized by MINCETUR for the exercise of said activity.
It corresponds to MINCETUR, through the General Directorate of Casino Games and Slot Machines of the Vice Ministry of Tourism of MINCETUR, as the supervisory body in matters of ML/FT prevention, to verify compliance with the Law, the Regulation, this standard, and other provisions on ML/FT prevention and detection, as well as to sanction non-compliance according to the corresponding Regulation of Infractions and Sanctions.

Article 2.- Definitions and Abbreviations
For the application of this standard, the obligated subject must consider the following definitions and abbreviations:

a) Beneficial owner: natural person in whose name a transaction is carried out and/or who possesses or exercises final effective control over a client, legal entity, or any other type of legal structure. b) Code: code of conduct for the prevention of ML/FT. c) Days: calendar days. d) DGJCMT: General Directorate of Casino Games and Slot Machines of the Vice Ministry of Tourism of MINCETUR. e) Identity document: national identity document for Peruvians, and the foreigner's ID card, passport, or legally established document for the identification of foreigners, as applicable. f) Terrorist financing: crime typified in Article 4-A of Legislative Decree No. 25475 and its modifying regulations. g) Economic group: set of two or more legal entities, national or foreign, in which one of them exercises control over the others, or when control over the legal entities corresponds to one or more natural persons acting as a decision-making unit. h) Casino games: any table game in which cards, dice, chips, or roulette are used, which admits public bets, the result of which depends on chance; as well as other games to which current regulations grant such qualification. i) ML/FT: money laundering and terrorist financing. j) Money laundering: crime typified in Legislative Decree No. 1106, Legislative Decree for Effective Struggle against Money Laundering and Other Crimes Related to Illegal Mining and Organized Crime, and its modifying regulations. k) Law: Law that Creates the Financial Intelligence Unit of Peru, UIF-Peru, Law No. 27693 and its modifying regulations. l) Manual: manual for the prevention and management of ML/FT risks. m) Slot machines: all electronic, electromechanical, or analogous gaming machines, that receive bets in money from the player and therefore allow them a time of use in exchange for the payment of the play based on chance and, eventually, the obtaining of a prize according to the game program, in accordance with current regulations. n) MINCETUR: Ministry of Foreign Trade and Tourism. o) Unusual operations: operations carried out or attempted to be carried out, whose amount, characteristics, and frequency do not relate to the client's economic activity, fall outside the parameters of normality current in the market, or have no evident legal basis. p) Suspicious operations: operations carried out or attempted to be carried out, whose amount or characteristics do not relate to the client's economic activity, or that do not have an economic basis; or that by their number, amounts transacted, or particular characteristics of these, could reasonably lead to suspect that the obligated subject is being used to transfer, manage, take advantage of, or invest resources coming from criminal activities or intended for their financing. q) Supervisory body: MINCETUR, through the DGJCMT. r) Politically Exposed Persons (PEP): natural persons, national or foreign, who hold or have held in the last five (5) years prominent public functions or prominent
functions in an international organization, either in national or foreign territory, and whose financial circumstances may be subject to public interest. The direct collaborator of the highest authority of the institution is considered a PEP. s) Commercial promotion: mechanism or system adopted by the obligated subject through the offer of prize or prizes under the modality of raffles, sale - exchange, free exchange, contests, combinations of the above, or any other modality, with the purpose of incentivizing the products or services of the obligated subject. t) REGAP: Winners Registry in which the obligated subject registers information regarding persons who turn out to be winners of the prizes granted as a consequence of a raffle, lottery, or other commercial promotion carried out in its game rooms. u) Regulation: Regulation of the Law that creates the UIF-Peru, approved by Supreme Decree No. 018-2006-JUS. v) ML/FT Risks: possibility that the obligated subject is used for ML/FT purposes. w) ROSEL: Online Suspicious Operations Report System. Technological tool developed by the SBS to allow, in accordance with current regulations, obligated subjects to send to the UIF-Peru the report of suspicious operations (ROS) by electronic means, under standards that ensure that the information is transmitted with an adequate level of security. x) Game room: specified area within an authorized establishment where all the facilities required for the exploitation of casino games and/or slot machines are located. y) SBS: Superintendence of Banks, Insurance, and Private Pension Fund Administrators. z) Obligated subject: legal entity that exploits casino games and/or slot machines, authorized by MINCETUR for the exercise of said activity. aa) Worker: natural person who maintains a labor or contractual link with the obligated subject; includes the general manager, managers, administrators, or those who hold similar positions. bb) UIF-Peru: Financial Intelligence Unit of Peru, a specialized unit of the SBS.

Article 3.- System for the prevention of money laundering and terrorist financing

3.1 The obligated subject must implement a system for the prevention of ML/FT, through the management of ML/FT risks to which it is exposed. The ML/FT prevention system is composed of the policies and procedures established by the obligated subject, in accordance with the Law, the Regulation, this standard, and other provisions on the matter, whose purpose is to prevent and avoid being used for illicit purposes linked to ML/FT.

3.2 The ML/FT prevention system must be applied by the obligated subject, the compliance officer, its workers and directors; and in general, by all its administrative and operational organization, according to the functions assigned to them, applying the code and manual approved for said effect, in accordance with what is established in this standard and other provisions on the matter.

3.3 The application of the ML/FT prevention system must focus on the detection of unusual operations and the prevention, detection, and reporting of suspicious operations, carried out or attempted to be carried out, that are presumably linked to ML/FT, in order to communicate them to the UIF-Peru, within the legal deadline established.

3.4 The obligated subject must prepare a report on the evaluation of ML/FT risks, to identify, evaluate, and categorize the risks to which it is exposed, which must consider, among others, the number and average amount of cash operations in the game rooms, regular clients, risk by geographic zone, service channels and/or type of currencies transacted, with the purpose of establishing appropriate controls to mitigate risks, whenever it is in any of the following situations:

3.4.1 It exploits casino game rooms.

3.4.2 It exploits five hundred (500) or more slot machines in total in its authorized rooms.

3.4.3 It exploits slot machine game rooms in the following Regions:

1. Tacna.
2. Puno.
3. Ucayali.
4. Loreto.
5. Tumbes.
6. Madre de Dios.

The identification and evaluation of ML/FT risks must be reviewed and/or updated every two years, except in the case where it is considered to offer new services, regarding which the obligated subject must carry out an evaluation and issue a report on the level of exposure to ML/FT risks to which the new services would be exposed; or decide to use new technologies associated with the offered services or a change is made in an existing product that modifies its ML/FT risk profile. These ML/FT risk evaluation reports must be available to the supervisory body and the UIF-Peru.

3.5 Market knowledge.- The knowledge of parameters notably applicable to the market that the obligated subject must have complements the knowledge of the client and allows estimating the ranges within which the usual operations carried out by its clients would be located, with the purpose of applying a differentiated ML/FT prevention strategy, having as a minimum level what is stated in this standard. For this, the obligated subject must carry out a segmentation of its clients - according to one or several variables -, in such a way that a profiling of these is carried out that allows estimating the characteristics of the operations they carry out, such as the type of operation, its magnitude, and frequency. For these purposes, the particular characteristics of the socio-economic, commercial, or financial sector to which the service is provided must be taken into account, among others.

3.6 Geographic zone.- The obligated subject must manage ML/FT risks associated with geographic zones, both at the local and international level, taking into account their security, economic-financial, and socio-demographic characteristics, as well as the calls made by authorities regarding certain jurisdictions, among others. The analysis associated with this ML/FT risk factor comprises the zones in which the obligated subject operates, as well as those linked to the operation process.

3.7 Economic group.- Economic groups must develop corporate policies and procedures regarding the ML/FT prevention system, including:
a) Policies and procedures at the group level in matters of risk management and ML/FT prevention. b) Policies and procedures to exchange information within the group for ML/FT prevention purposes, establishing adequate safeguards on the confidentiality and use of the exchanged information. c) Criteria necessary to be adopted by members of the economic group to ensure high standards when hiring workers and appointing directors and managers. d) Training programs in matters of ML/FT prevention.

Article 4.- Responsibilities of the obligated subject
The obligated subject is responsible for implementing the ML/FT prevention system. For this, it is the responsibility of the board of directors or the body that acts in its place:
a) Establish and periodically review the functioning of the ML/FT prevention system. b) Approve and periodically review the policies and procedures for ML/FT risk management, in accordance with what is established in numeral 3.4 of Article 3. c) Approve the Manual and the Code. d) Designate a compliance officer with the characteristics, responsibilities, and powers established by current regulations. e) Provide the resources and infrastructure that allow the fulfillment of the compliance officer's functions. f) Establish measures to maintain the confidentiality of the compliance officer, so that their identity is not known to persons outside the obligated subject.

Article 5.- General aspects of training and information on the regulations of the ML/FT prevention system

5.1. Within thirty (30) days following the date of entry of the workers, the obligated subject must inform them, through the compliance officer, about the scope of the ML/FT prevention system, leaving a record of it.

5.2. In addition to what is indicated in the previous numeral, the directors and workers of the obligated subject, as well as the compliance officer, must have at least one annual training in matters of ML/FT prevention and/or detection, with the purpose of being instructed - according to their specialty and function performed - on the current regulations in the matter; the policies and procedures established for the fulfillment of their functions; ML/FT typologies, in particular, those that could be detected in the activities of the obligated subject; as well as alert signals to detect unusual operations; among other aspects that the compliance officer considers relevant.

5.3. Training is the obligation of the obligated subject and may be taught by third parties, specialized entities, or by the compliance officer, under any modality. Obligated subjects must maintain a record of the training received, which must be available to the supervisory body, in the information corresponding to each director or worker, in physical and/or electronic medium. In the case that the training has been carried out by the compliance officer, this must issue a record with the character of a sworn declaration indicating the day, place, duration time, and topics of the training, as well as the names and surnames and positions of the trained persons.

5.4. The compliance officer is responsible for communicating to the obligated subject and all workers about the changes made in the regulations of the ML/FT prevention system.

Article 6.- Minimum training requirements
The obligated subject must train, according to their functions, the directors and workers, as well as the compliance officer, on at least the following:
a) Definition of the crimes of money laundering and terrorist financing. b) Policies of the obligated subject on the prevention and management model of ML/FT risks. c) ML/FT risks to which the obligated subject is exposed. d) Current regulations. e) ML/FT typologies, as well as those detected by the obligated subject or other obligated subjects. f) Internal norms of the obligated subject. g) Alert signals to detect unusual and suspicious operations. h) Procedure for communicating unusual operations. i) Responsibility of each director and worker, as applicable, regarding this matter.

TITLE II
SYSTEM FOR THE PREVENTION OF MONEY LAUNDERING
AND TERRORIST FINANCING

Chapter I
Knowledge of the client, directors, and workers

Article 7.- Determination of clients

7.1 For the purposes of this standard, client is any natural person, national or foreign, who requests and receives from the obligated subject, habitually or occasionally, the provision of the service of casino games and/or slot machines regarding operations that are subject to the RO.
The Law, the Regulation, and this standard are applicable to all clients of the obligated subject.

7.2 Regular client is the one who requests and receives the provision of the service of casino games and/or slot machines from the obligated subject, frequently, regardless of the amount involved in the operation. Occasional client is the one who requests and receives the provision of the service of casino games and/or slot machines, sporadically.

Article 8.- Knowledge of the client, beneficial owner, and due diligence

8.1. The obligated subject must verify the identity of the clients, adequately and reliably, whether it is a regular or occasional client, when the operation they carry out is subject to the RO. The minimum information that must be requested and provided by the client is the following:
a) Names and surnames. b) Type and number of identity document. c) Nationality, in the case of foreigners. d) If PEP, indicating if applicable, the position and name of the institution. In that case, the reinforced regime established in the following numerals applies. e) The origin of the funds involved in the transaction. To carry out the client due diligence, the obligated subject may use the Sworn Declaration Form for client knowledge, referred to in Annex No. 1.

8.2. The obligated subject must identify the beneficial owner in whose name the service of casino games and/or slot machines is carried out and adopt reasonable measures to verify their identity, so that they are convinced that they know who the beneficial owner is.

8.3. The minimum control and due diligence actions regarding the client imply, on the part of the obligated subject, those provided for in numeral 8.1 and 8.2, unless it is in the situations of numeral 3.4 of Article 3, in which case it must establish additional controls based on the ML/FT risks identified according to what is provided in said numeral and others determined by the UIF-Peru.

8.4. The due diligence in the knowledge of the client consists of the stages of identification, verification, and monitoring. The partial or total realization of each of these stages is based on the risks that have been detected. The identification stage must allow obtaining the main information for the purpose of establishing the identity of a client and beneficial owner, if applicable; the verification process consists of ensuring that its clients were duly identified, leaving documentary evidence of it; and the monitoring process

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 8/42 ensure that the operations executed by its clients are compatible with what is established in the client profile.
8.5. Enhanced Regime.- The application of this regime implies for the obligated subject the development and implementation of enhanced due diligence procedures in the knowledge of its clients. The obligated subject must identify and register under this regime clients who demonstrate a pattern that does not correspond to their AML/CFT risk profile, as well as those clients who could be highly affected by AML/CFT risks. This regime must be applied obligatorily to the following clients:
a) Nationals or foreigners, non-residents. b) PEPs and identified as: i) relatives of PEPs up to the second degree of consanguinity and second degree of affinity; and, ii) spouse or cohabitant of PEP. c) Clients regarding whom there is knowledge that they are being investigated for money laundering, predicate crimes, and/or terrorist financing by the competent authorities. d) Others determined by the obligated subject or UIF-Peru. For clients registered in this regime, the obligated subject must implement the following due diligence measures:

1. Regarding PEPs, the names of their relatives up to the second degree of consanguinity and second degree of affinity and of the spouse or cohabitant must be requested, as well as the list of legal entities or legal entities where they hold a participation equal to or greater than 25% of their share capital, contribution, or participation.
2. Increase the frequency of review of the client's transactional activity.
   8.6. The obligated subject may use third parties or intermediaries to comply with services related to the identification and/or verification of information of clients, directors, workers. The obligated subject must adopt the corresponding measures to obtain the information, copies of identification data and other pertinent documentation; as well as a sworn statement by which the third party or intermediary states that it has taken necessary measures to comply with the provisions on client, director, or worker due diligence.
   The obligated subject maintains responsibility for the due diligence processes in the knowledge of its clients, directors, or workers, even when these have been entrusted to a third party or intermediary, linked or not, and must supervise compliance with what is provided by current regulations.
   8.7. The obligated subject must conserve, for a period of five years, the documentation and information obtained in the application of due diligence in the knowledge of the client and ensure that it remains updated through the review of existing records.
   8.8. When the obligated subject is not in a position to comply with the due diligence measures in the knowledge of the client, it must proceed as follows: (i) not initiate commercial relations, not carry out the operation and/or terminate the initiated commercial relationship; and (ii) evaluate the possibility of filing a STR regarding the client.
   8.9. In case the obligated subject has suspicions of AML/CFT activities and considers that carrying out due diligence actions would alert the client, it must report the suspicious operation to UIF-Peru without carrying out said actions. These cases must be adequately justified and documented.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 9/42
Article 9.- Knowledge of directors and workers
9.1 The obligated subject must implement a due diligence policy in the knowledge of its directors and workers. This policy must be part of the recruitment and selection program for new, permanent, and temporary staff, in order to ensure their integrity, regardless of their position.
9.2 The purpose of due diligence in the knowledge of directors and workers is for the obligated subject to be able to establish their profiles; for this, the obligated subject must request and evaluate personal, labor, and asset background information, through a sworn statement that includes at least the following information:

1. Full names
2. Type and number of identity document (including a copy).
3. Marital status, specifying the names and surnames of the spouse or cohabitant, if applicable.
4. Profession or trade.
5. Occupation and/or position in the obligated subject.
6. Home address and telephone number of their habitual residence.
7. Professional studies and specialized training received.
8. Certificate or other documents presenting information on their police and criminal records.
9. Labor and asset background, including the declaration of other income generated outside the obligated subject.
   This minimum information must be part of the personal documentation of each of the directors, if such a governing body exists, and of the workers of the obligated subject; for this, the form referred to in Annex No. 2 – Sworn Statement Form for Knowledge of Directors and Workers must be used.
   9.3 The minimum information indicated above, regarding each worker and director, must be kept updated and be available to the supervisory body during supervision visits of the AML/CFT prevention system, as well as to UIF-Peru.
   9.4 The obligated subject must require as an obligation of each worker to communicate, in writing -with the character of a sworn statement- any change regarding the information provided, within a period of fifteen (15) days from the occurrence of the change, for its update.
   The obligated subject must establish internal sanction mechanisms for non-compliance with this standard, as well as with the manual or code.
   Chapter II
   Records
   Article 10.- Operation Record (OR)
   10.1. The obligated subject must keep and maintain updated an operation record (OR) in which it registers the individual operations carried out by its clients in the cages of the game rooms, as well as the identification of its clients. The mere inclusion of an operation in the OR does not necessarily imply that the client has carried out an unusual or suspicious operation.
   The information supporting the OR must be available to the supervisory body, UIF-Peru, and the jurisdictional bodies and competent authorities in accordance with the Law.
   10.2. The operations subject to the OR are the chip, ticket, or other game medium exchange operations in the cages of the game rooms, regardless of the type of funds used for this purpose, according to the threshold established in numeral 10.3.
   10.3. Threshold for the OR
   10.3.1. The obligated subject must register the individual operations of its clients, for amounts equal to or greater than US$ 2,500.00 (two thousand five hundred and 00/100 US dollars) or its equivalent in national currency or other currencies, if applicable.
   10.3.2. For the registration of the operation, the applicable exchange rate to fix the equivalent in national currency is the selling exchange rate published by the SBS, corresponding to the day the operation was carried out.
   10.3.3. Without prejudice to the threshold indicated in 10.3.1, the obligated subject may establish lower thresholds internally for the OR, which can be fixed based on the risk analysis of the operations it carries out, the economic sector, the client profile, or any other criterion it determines.
   Article 11.- Conservation and availability of the OR
   11.1 The obligated subject must register the operations on the day they occurred. The OR is kept chronologically, precisely, and completely. The OR has the character of confidentiality.
   11.2 The OR is kept through computer systems, such as microfilming, microforms, or others of easy recovery.
   11.3 The obligated subject must conserve the OR for a period of five (5) years, counted from the date the operation is carried out, and must maintain a backup copy of the OR, which must be available to UIF-Peru and the Public Ministry within the timeframes established in the Law.
   11.4 The obligated subject sends the OR to UIF-Peru, in the electronic medium, periodicity, structure, and instructions that the SBS establishes.
   Article 12.- Non-exclusion from the OR
   The obligated subject must not exclude any client from the OR, regardless of their habitual nature and the knowledge it has of them.
   Article 13.- Prize Winners Register (REGAP)
   13.1. The obligated subject must register, in the REGAP, the persons who result as winners of the prizes granted as a consequence of a raffle, lottery, or other commercial promotion that it carries out in its game rooms, on the day they occurred and kept chronologically, precisely, and completely.
   13.2. The obligated subject must keep the REGAP in electronic medium, keep it updated, and conserve it for a period of five (5) years, counted from the date the raffle, lottery, or other commercial promotion was carried out, using for this purpose computer, microfilming, or similar means that are of easy recovery.
   13.3. The REGAP contains, as a minimum, the following information:
   a) Full names of the winner. b) Type and number of identity document. c) Nationality, in the case of a foreigner. d) Address of the winner's domicile. e) Type of commercial promotion.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 11/42 f) Date, time, and place where the commercial promotion takes place. g) No. and date of the authorizing resolution of the ONAGI or body acting in its place. h) Full names of the representative of the ONAGI or entity acting in its place and of the Notary witnessing the act, if applicable. i) Identification of the prize and its value. j) Currency with which the prize is paid, if applicable. k) Others established by the SBS.
13.4. The obligated subject sends the REGAP to UIF-Peru, through the Portal for the Prevention of Money Laundering and Terrorist Financing in the periodicity, structure, and instructions that the SBS establishes.
13.5. The REGAP must be available to the supervisory body, which will analyze it during supervision visits to the obligated subject or on the occasion that it requires it.
Chapter III
Report of suspicious operations and their communication
Article 14.- Suspicious Operation Report (SOR)
14.1 The obligated subject has the obligation to communicate to UIF-Peru, through its compliance officer, the operations carried out or attempted to be carried out, that are considered suspicious, regardless of the amounts involved, in accordance with what is provided in the Law, the Regulation, this standard, and other provisions on the matter.
The communication must be immediate and sufficient, that is, within a period that -according to the nature and complexity of the suspicious operation- allows for the elaboration, documentation, and submission of the SOR to UIF-Peru, which in no case must exceed fifteen (15) business days from detection.
14.2 The compliance officer, on behalf of the obligated subject, must qualify the operation as suspicious and proceed with its communication to UIF-Peru, leaving documentary evidence of the analysis and evaluations carried out, for the qualification of an operation as unusual or suspicious, as well as the reason why an unusual operation was not qualified as suspicious and reported to UIF-Peru, if applicable. The operations qualified as unusual and the documentary support of the analysis and evaluations are conserved for a period of five (5) years, according to the design provided in Annex No. 3 - Design for identification of unusual operations.
14.3 The obligated subject, through the compliance officer, must send the SOR and attached or complementary documentation to UIF-Peru through the ROSEL system, using for this the ROSEL template of the portal for the prevention of money laundering and terrorist financing enabled by the SBS for such effect. In no case must the identity of the compliance officer or the obligated subject, nor any other element that could contribute to identifying them, be recorded in the SOR, except for the secret codes assigned by UIF-Peru.
14.4 The compliance officer of the obligated subject is responsible for the correct use of the ROSEL system and all the information contained in the respective template and its annexes and must adopt the necessary measures to ensure the accuracy and veracity of the information, its reserve, and confidentiality.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 12/42
14.5 Annex No. 4 - Alert Signals contains a list of the types of signals that each obligated subject must take into account in order to detect unusual or suspicious operations. The foregoing does not exempt the obligated subject from communicating other operations it considers suspicious, according to its AML/CFT prevention system and with the alert signals identified by the obligated subject itself, related to the activities it carries out. Without prejudice to this, UIF-Peru may provide the obligated subject with additional information or criteria that contribute to the detection of unusual or suspicious operations.
The mere existence of elements constituting alert signals does not generate the obligation to file the SOR.
14.6 The communication of suspicious operations to UIF-Peru, by the obligated subject, through the compliance officer, has a confidential and reserved character. For all legal purposes, the SOR does not constitute a criminal complaint.
Chapter IV
Manual and Code of Conduct for the Prevention and Management of AML/CFT Risks

Article 15.- Manual for the Prevention and Management of AML/CFT Risks
15.1 The obligated subject must elaborate and apply a manual with the policies, mechanisms, and procedures related to compliance with the system for the prevention and detection of AML/CFT, as provided by the Law, its Regulation, this standard, and other provisions issued on the matter. The manual must contain as a minimum the information indicated in Annex No. 5 – Basic Content of the Manual for the Prevention and Management of Money Laundering and Terrorist Financing Risks, adjusting its content, if applicable, based on the risks identified by the obligated subject.
15.2 The manual must be approved by the board of directors or equivalent body of the obligated subject or, in its absence, by the general manager, manager, managing partner, or administrator as applicable, provided that the legal entity, according to its statutes, is not obliged to have a board of directors.
This manual must be available to the supervisory body and UIF-Peru, when required.
15.3 The manual must be updated in concordance with national regulation and international standards, incorporating in addition to the alert signals of Annex No. 4, those identified by the obligated subject or its compliance officer in the development of its activity.
15.4 The manual and its modifications must be brought to the knowledge of the workers of the obligated subject, the compliance officer, and there must be a record of this. Annex No. 6 contains a model of Sworn Statement of Receipt and Knowledge of the Manual and/or Code, which may be used by the obligated subject.
Article 16.- Code of Conduct for the Prevention of AML/CFT
16.1 The obligated subject must approve and put into practice for its workers, directors, and compliance officer, a code of conduct intended to ensure the adequate functioning of the AML/CFT prevention system, and must contain among other aspects, the guiding principles, values, and policies that must be applied to administer the risk of exposure to AML/CFT, as well as the measures to guarantee the duty of indefinite reserve of information related to the AML/CFT prevention system.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 13/42
16.2 The code must highlight the mandatory character of the procedures that integrate the AML/CFT prevention system, in accordance with current regulations on the matter and specifying, if applicable, those particular details to which the obligated subject, the compliance officer, and its workers must adhere.
16.3 The code must be approved by the board of directors or equivalent body of the obligated subject or in its absence by the general manager, manager, managing partner, or administrator, as applicable, provided that the legal entity, according to its statutes, is not obliged to have a board of directors.
16.4 The code must be brought to the knowledge of the workers of the obligated subject, the compliance officer, and its shareholders, partners, associates, directors, attorneys, or legal representatives, if applicable. This code must be available to the supervisory body and UIF-Peru, when so required.
16.5 The obligated subject may use the Model Code of Conduct for the Prevention of Money Laundering and Terrorist Financing referred to in Annex No. 7.
16.6 The obligated subject must leave a record of the knowledge it has taken, its workers, and the compliance officer, directors, if applicable, regarding the Code and of their commitment to comply with it in the exercise of their functions; as well as, conserve such record. For this effect, the obligated subject may use Annex No. 6 which contains a model of Sworn Statement of Receipt and Knowledge of the Manual and/or Code.
Chapter V
Supervision of the AML/CFT prevention system
Article 17.- Supervision of the obligated subject to inform
17.1 It corresponds to the supervisory body to ensure compliance with the Law, the Regulation, this standard, and other provisions on prevention and detection of AML/CFT, in coordination with UIF-Peru, using not only its own supervision mechanisms, but it may also count on the support of the compliance officer, internal audit whenever the Social Statute or the policy of the obligated subject so provides, and external audit firms, if applicable.
The AML/CFT prevention system must be evaluated by internal audit, if the obligated subject has it, or by a Manager different from the compliance officer of the obligated subject.
The AML/CFT prevention system must be evaluated by an external audit firm, in those cases where there is a legal obligation to have one, different from the one that issues the annual financial statements report, or by a completely distinct team from this.
17.2 The supervisory body carries out supervision visits on AML/CFT prevention, according to the planning it determines, and exercises the sanctioning power for non-compliance with the obligations derived from this standard and according to the Regulation of Infractions and Sanctions corresponding.
Article 18.- Compliance Officer
18.1 The compliance officer is the natural person designated by the obligated subject, responsible for monitoring the adequate implementation and functioning of the AML/CFT prevention system.
It is the contact person between the obligated subject and UIF-Peru and an agent on which the supervisory body relies in the exercise of the control and supervision labor of the mentioned system.
18.2 The person designated as compliance officer can only be so for one obligated subject at a time, unless it is a corporate compliance officer.
18.3 In cases where, due to the size of its organization, complexity, or volume of operations, it is not justified that the obligated subject has a compliance officer on an exclusive dedication basis, obligated subjects may request from the supervisory body and UIF-Peru, authorization to have a compliance officer on a non-exclusive dedication basis, who must comply with articles 19 and 20 of this standard. The request must be duly justified and contain the following minimum information:
a) Composition of the compliance office; b) Description of the distribution of the workload of the non-exclusive dedication compliance officer; c) Description and justification of the reasons that justify its request for the designation of a non-exclusive dedication compliance officer; d) Information describing the level of exposure to AML/CFT risks that the obligated subject faces; and, e) Description of other characteristics of the obligated subject. If in the exercise of supervision powers, the supervisory body or UIF-Peru determine that the management of the non-exclusive dedication compliance officer does not allow adequate management of the AML/CFT risks faced by the obligated subject, they may leave without effect the authorization to have a non-exclusive dedication compliance officer.
Article 19.- Requirements of the compliance officer
19.1 The compliance officer of the obligated subject must meet the following requirements:
a) Have experience in the activities proper to the obligated subject, or experience as a compliance officer or as a worker in the area in charge of a compliance officer. b) Not have been convicted for the commission of an intentional crime. c) Not have been dismissed from public office or have been dismissed from it for serious fault. d) Not have overdue debts for more than one hundred twenty (120) days in the financial system or in judicial collection, nor protests of documents in the last five (5) years, not clarified to the satisfaction of the SBS. e) Not have been declared bankrupt. f) Not be nor have been the internal auditor of the obligated subject, if applicable, during the six (6) months prior to its designation. g) Not be subject to any of the impediments indicated in article 365 of Law No. 26702, excepting paragraph 2 of the mentioned article. h) Have a direct labor or contractual link with the obligated subject and enjoy autonomy and independence in the exercise of its responsibilities and functions. i) Others established by the SBS, in coordination with the supervisory body. The requirements can be accredited through sworn statements.
19.2 The compliance officer who ceases to meet any of the requirements established in this article, cannot continue acting as such, and must communicate it to the obligated subject in writing -with the character of a sworn statement- within a maximum period of five (5) business days

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of the occurrence of the fact. In the event that the obligated subject becomes aware of the non-compliance with requirements, even if the compliance officer has not communicated it to them, they must inform the supervisory body and UIF-Perú within a maximum period of five (5) business days; without prejudice to complying with paragraphs 20.2 and 20.5 of Article 20, for the designation of a new compliance officer and the justification referred to in Article 22.

Article 20.- Designation and exercise of functions of the compliance officer

20.1 The designation of the compliance officer must be carried out by the board of directors or equivalent body; or in its absence, by the general manager, manager, managing partner, or administrator, provided that the legal entity, according to its bylaws, is not obliged to have a board of directors. The designation of the compliance officer does not exempt the obligated subject or its workers from the obligation to apply the policies and procedures of the AML/CFT prevention system.

20.2 The designation of the compliance officer must be communicated by the obligated subject via a letter addressed to the supervisory body and UIF-Perú, in writing or other means determined by them, respectively, in a confidential and reserved manner, within a period not exceeding fifteen (15) business days from the date of designation, attaching the documentation that accredits compliance with the requirements indicated in the previous article, and indicating at minimum the following information about the compliance officer:

a) First and last names. b) Type and number of identity document. c) Nationality. d) Address. e) Address of the office where they work. f) Contact details (phone numbers, email, etc.). g) Indicate whether the position of compliance officer is full-time or not. h) Date of entry and position held. i) Sworn declaration indicating that the designation of the compliance officer has been carried out by the board of directors or equivalent body, in case the legal entity, according to its bylaws, is not obliged to have a board of directors. The minutes of the general shareholders' meeting or the board of directors session, as applicable, will be available to UIF-Perú and the supervisory body. j) Sworn declaration regarding compliance with the requirements indicated in the previous article.

Changes in the aforementioned information must be communicated by the obligated subject to the supervisory body and UIF-Perú, via letter, within a period not exceeding five (5) business days from the occurrence of the change.

20.3 The obligated subject may designate an alternate compliance officer simultaneously with the designation of the principal compliance officer or subsequently, to serve as compliance officer only in the event of temporary absence or vacancy of the principal, including until the designation of the new compliance officer. Any reference to the obligations, functions, and responsibilities of the compliance officer in this standard is understood to apply to the alternate compliance officer.

20.4 In cases where an alternate compliance officer is required to perform the functions established in this standard, the obligated subject must communicate this to the supervisory body and UIF-Perú, within a period not less than five (5) business days prior to the principal's absence, except in cases of duly justified force majeure, indicating the period and reasons supporting the absence. The period of temporary absence cannot last more than four (4) months.

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20.5 The vacancy of the compliance officer cannot last more than thirty (30) days, from the date it occurred, and must be communicated to UIF-Perú, within a period of five (5) business days from its occurrence, without prejudice to compliance with paragraph 20.2 of this article.

20.6 The aforementioned communications, addressed to the supervisory body and UIF-Perú, can be made via written document or other means determined by each entity.

Article 21.- Confidentiality of the compliance officer's identity

21.1 The obligated subject must safeguard the identity of the compliance officer. For the proper confidentiality of their identity, the designation of the compliance officer must not be registered in the records that make up the National System of Public Registries. When the compliance officer is appointed to a managerial, administrative, or directorial position, it corresponds to register in the legal entity's registry entry only the part pertinent to the appointment in the respective position.

21.2 UIF-Perú assigns secret codes, both to the obligated subject and to the compliance officer, the alternate compliance officer, and/or the corporate compliance officer, if applicable, after verifying the documentation and information presented, who must adopt the necessary actions to maintain and guarantee the confidentiality of said secret codes.

21.3 The secret codes assigned by UIF-Perú serve only as identification in all communications sent to UIF-Perú and its supervisory body, thereby guaranteeing the confidentiality of their identity, as well as the confidentiality of the information sent to UIF-Perú. In the case of a corporate compliance officer, the codes are assigned once the respective authorizations from the corresponding supervisory bodies have been obtained.

Article 22.- Removal of the compliance officer

22.1 The removal of the compliance officer position by the obligated subject must have due justification of the reasons justifying such measure and must be approved by the board of directors or the general manager or equivalent body of the obligated subject. The removal, as well as the respective justification, must be communicated to the supervisory body and UIF-Perú, within a period of five (5) business days from the adoption of the decision.

22.2 The communication that must be sent to UIF-Perú, in the case of the corporate compliance officer, must be signed by the representatives of each of the obligated subjects that make up the economic group.

Article 23.- Corporate compliance officer

23.1 Obligated subjects that are part of the same economic group may designate, with prior authorization from the respective supervisory bodies and UIF-Perú, according to the following paragraphs, a single corporate compliance officer, who must have a managerial level in one of the legal entities forming the economic group and have a sufficient number of personnel.

23.2 In the event that the economic group is composed solely of obligated subjects under the supervision of the supervisory body, the obligated subjects must request express authorization from the supervisory body and UIF-Perú, who issues the authorization, if applicable, regarding the entire economic group, once the supervisory body has issued its statement, as follows:

a) They must present a single authorization request to the supervisory body and UIF-Perú, which must be signed by the legal representative of each of the obligated subjects that make up the economic group, and must attach the information indicated in Annex No. 8 – Information to request authorization to have a corporate compliance officer. b) The authorization issued by the supervisory body must be supported by a report that must contain at minimum the analysis of complexity and volume of operations, quality of the IT tools used by the obligated subjects that make up the economic group, the AML/CFT risk level they face, if applicable, among others they consider pertinent. The statement of the supervisory body must be sent to UIF-Perú. c) The statement of UIF-Perú with the respective authorization, regarding the entire economic group, is communicated to the obligated subjects that formulate the request by the economic group and to the supervisory body.

23.3 In the event that the economic group includes obligated subjects under the supervision of various supervisory bodies:

a) The obligated subjects must request express approval from each of the supervisory bodies, as well as from UIF-Perú, who issues the authorization, if applicable, regarding the entire economic group, once the corresponding supervisory bodies have issued their statements. b) For authorization of the corporate compliance officer position, the obligated subjects that make up an economic group must present a single authorization request to the heads of the respective supervisory bodies and to UIF-Perú, which must be signed by the legal representative of each of the obligated subjects that make up the economic group, and must attach the information indicated in Annex No. 8 – Information to request authorization to have a corporate compliance officer. c) The supervisory bodies, if applicable, approve the request, regarding the obligated subjects under their supervision. The authorizations issued by the supervisory bodies must be supported by a report that must contain at minimum the analysis of complexity and volume of operations, quality of the IT tools used by the obligated subjects that make up the economic group, the AML/CFT risk level they face, if applicable, among others they consider pertinent. Each of the statements of the supervisory bodies must be sent to UIF-Perú. d) The statement of UIF-Perú is communicated to the obligated subject that formulates the request by the economic group and to the respective supervisory bodies.

23.4 The replacement of the person occupying the position of corporate compliance officer, in the case of economic groups referred to in paragraphs 23.2 and 23.3, respectively, and provided that the economic group has not changed substantially with respect to that maintained at the time of initial approval, is informed via written communication addressed to each of the supervisory bodies, when applicable, and to UIF-Perú, attaching the documentation referred to in Article 20.

23.5 Obligated subjects that make up the same economic group authorized to have a corporate compliance officer, who require incorporating a new obligated subject into the economic group, must present a single authorization request to the heads of the respective supervisory bodies and to UIF-Perú, which must be signed by the representatives of each of the obligated subjects that make up the economic group, for which they must follow the procedure established in paragraph 23.2 or paragraph 23.3, respectively.

23.6 The authorization to have a corporate compliance officer may be revoked by UIF-Perú, when due to the particular characteristics of the companies that make up the economic group, the authorization to have a corporate compliance officer is not justified.

Article 24.- Corporate coordinator in AML/CFT prevention

Members of an economic group that has a corporate compliance officer must designate a corporate coordinator in each member of the economic group, who is responsible for directly coordinating all matters related to AML/CFT prevention with the corporate compliance officer; without prejudice to the fact that the corporate compliance officer maintains responsibility for the AML/CFT prevention system of each of the obligated subjects that are part of the economic group.

Article 25.- Functions of the compliance officer

The functions of the compliance officer are as follows:

a) Propose the strategies of the obligated subject to prevent and manage AML/CFT risks. b) Monitor the adequate implementation and functioning of the AML/CFT prevention system. c) Evaluate and verify the application of the policies and procedures implemented in the AML/CFT prevention system, as indicated in the Regulation of the Law, including the recording of operations and the timely detection and reporting of suspicious operations. d) Evaluate and verify the application of the policies and procedures implemented to identify PEPs. e) Implement policies and procedures to ensure adequate management of AML/CFT risks. f) Verify that the personnel of the obligated subject have the appropriate level of training for the purposes of the AML/CFT prevention system, which includes the adequate management of AML/CFT risks. g) Verify that the AML/CFT prevention system includes the review of the lists indicated in Annex No. 9 – Lists that contribute to the prevention of AML/CFT. h) Propose alert signals to be incorporated into the manual. i) Keep a record of those unusual operations that, after respective analysis, were not determined as suspicious. j) Evaluate operations and, if applicable, qualify them as suspicious and communicate them, maintaining the duty of confidentiality referred to in Article 12 of the Law, through SARs to UIF-Perú, on behalf of the obligated subject. k) Issue annual reports on their management. l) Verify the adequate conservation and custody of documents related to the AML/CFT prevention system. m) Act as the interlocutor of the obligated subject before UIF-Perú, on matters related to their function. n) Attend to information requests or requests for additional and/or complementary information requested by competent authorities. o) Inform regarding modifications and incorporations to the list of high-risk and non-cooperative countries published by the Financial Action Task Force - FATF.

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p) Those others that are necessary or established by the Superintendency to monitor the functioning and level of compliance of the AML/CFT prevention system.

Article 26.- Annual report of the compliance officer

26.1 The compliance officer must prepare and send to the supervisory body and UIF-Perú, the Compliance Officer Annual Report (COAR) on the adequacy and compliance of the policies and procedures that make up the AML/CFT prevention system implemented by the obligated subject, which must contain, at minimum, the following aspects:

a) The address and phone number of the obligated subject, and the email of the compliance officer. b) Indication regarding whether the compliance officer exercises the function as a corporate compliance officer or not. c) Name of partners or shareholders and percentage of participation in the obligated subject, if applicable. d) Name of managers or other workers responsible for business management, if applicable. e) Annual statistics of unusual operations detected by workers, discriminating information monthly, specifying amounts involved or other aspects considered significant. f) Annual statistics of the SAR, indicating the number of registered operations and amounts involved, discriminating information monthly. g) Annual statistics of suspicious operations reported to UIF-Perú, discriminating information monthly, specifying amounts involved or other aspects considered significant. h) Annual statistics of the REGAP, indicating the number of registered operations and amounts involved, discriminating information monthly. i) Description of new alert signals for unusual operations established by the obligated subject and typologies of suspicious operations that have been detected and reported, if any. j) Customer due diligence policies and policies for directors and workers. k) Training on matters related to AML/CFT prevention, including a general description of the training provided and the number of people who have been trained. Likewise, the number of people who were trained more than once a year must be indicated, as well as the detail of differentiated training according to the profile of the recipient and their function, as well as the AML/CFT risks they face. l) Last date of update of the manual and code, and compliance with the manual and code by directors and workers of the obligated subject, indicating those cases where they have been non-compliant, sanctions imposed, and corrective measures adopted. m) Corrective measures adopted by virtue of observations and/or recommendations made by the supervisory body, UIF-Perú, and internal or external auditors, when applicable. n) Method of conservation of the SAR and the REGAP. o) Other important aspects related to their management, at the discretion of the compliance officer. p) Others determined by the SBS, in coordination with the supervisory body.

26.2 The annual report of the compliance officer must have the approval of the board of directors or equivalent body of the obligated subject or, in its absence, of the general manager, manager, managing partner, or administrator as applicable, provided that the legal entity, according to its bylaws, is not obliged to have a board of directors. The report must be approved within thirty (30) days following the expiration of the respective period.

26.3 The COAR is sent by the compliance officer of the obligated subject no later than February 15 of the following year, to the supervisory body by the means established by it, and to UIF-Perú through the Portal for the Prevention of Money Laundering and Terrorist Financing or other means established by the SBS, in the structure and according to the instructions determined by the same means.

26.4 In the case of the corporate compliance officer, they must present an annual report for each of the obligated subjects that are part of the economic group, within the same deadlines cited above.

Chapter VI
Conservation of documents, attention to information requests, and communications

Article 27.- Conservation of documents

27.1 Obligated subjects must conserve information related to the AML/CFT prevention system and that which allows accrediting compliance with the provisions established by this standard, for a period not less than five (5) years. This information mainly comprises information related to the linkage and operations carried out by clients, including all information obtained and/or generated in the application of due diligence measures. The aforementioned information must be kept updated, considering for such effect the AML/CFT risk analyses and periodicity established by the obligated subject and considered in the Manual, and, as applicable, must be available to the supervisory body and UIF-Perú.

27.2 For this purpose, IT means, microfilming, microforms, or similar means that allow easy recovery of information for consultation and internal or external reporting to competent authorities in accordance with the Law are used.

Article 28.- Attention to information requests from authorities

28.1 Obligated subjects must develop and implement mechanisms for attending to requests made by competent authorities regarding the AML/CFT prevention system, taking into account the deadlines and forms established in the legislation and regulation of the matter.

28.2 The obligated subject must attend, within the period requested of them, information requests or requests for expansion of information made by the supervisory body and UIF-Perú, in accordance with current regulations.

28.3 The obligated subject, through its compliance officer, must send and/or make available to UIF-Perú the reports, operation records (SAR), prize winner registry (REGAP), and suspicious operation reports (SAR), via electronic means or other that is established, as well as all information that allows accrediting compliance with what is provided in this standard.

Article 29.- Communications addressed by the obligated subject

29.1 The communications, reports, records, and reports that, according to the Law, Regulation, and this standard, the obligated subject must send, through its compliance officer, to the

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respective supervisory bodies and to UIF-Perú, which must be signed by the representatives of each of the obligated subjects that make up the economic group, for which they must follow the procedure established in paragraph 23.2 or paragraph 23.3, respectively.

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organismo supervisor and to UIF-Perú, must be identified solely with the secret codes assigned by UIF-Perú to this entity and the obligated subject, adopting measures that allow for the confidentiality of the information and its senders.

29.2 The communications that the obligated subjects must issue in accordance with the provisions of this standard are confidential, and all those involved are prohibited from disclosing to any person the content of the information, as well as whether such information has been requested, made available, or provided to the supervisory body or to UIF-Perú, under the corresponding administrative, civil, and criminal responsibilities.

SUPPLEMENTARY AND FINAL PROVISIONS

First.- Annexes
The following annexes form an integral part of this standard:
Annex No. 1: Sworn declaration of client knowledge form.
Annex No. 2: Sworn declaration of knowledge of directors and employees form.
Annex No. 3: Design for the identification of unusual transactions.
Annex No. 4: Alert signals.
Annex No. 5: Basic content of the manual for the prevention and management of money laundering and terrorist financing risks.
Annex No. 6: Sworn declaration of receipt and knowledge of the Manual and/or Code.
Annex No. 7: Model code of conduct for the prevention of money laundering and terrorist financing.
Annex No. 8: Information to request authorization to have a corporate compliance officer.
Annex No. 9: Lists that contribute to the prevention of ML/FT.

Second.- Exemption from liability
In accordance with Article 13 of the Law, the obligated subject and its employees are exempt from penal, civil, and administrative liability, as applicable, derived from the due compliance with current regulations on the prevention of ML/FT.

Article 2.- The SBS determines the date from which the obligated subject must send the RO and REGAP to UIF-Perú, in the structure, electronic medium, periodicity, and in accordance with the instructions that are established.

Article 3.- The obligated subjects within the framework of the Standard for the prevention of money laundering and terrorist financing applicable to companies that operate casino games and/or slot machines, which on the date of entry into force of this, have authorization to have a corporate compliance officer, must adapt to what is provided in Articles 19, 20, and 23 of the aforementioned standard, within a term of ninety (90) business days, counted from the entry into force of the standard, in order to keep the respective authorization valid. If they meet the requirements established in said standard, a sworn declaration to that effect must be sent to the supervisory bodies and UIF-Perú; otherwise, the documentation indicated in Article 23 or the new designation, with the corresponding documentation, if applicable, must be sent.

Obligated subjects whose requests for authorization to have a compliance officer or a corporate compliance officer, which on the date of entry into force of this standard are pending, must present the

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Article 4.- The annexes referred to in the Standard for the prevention of money laundering and terrorist financing applicable to legal entities that operate casino games and/or slot machines approved by Article 1) of this resolution, are published on the Institutional Portal – www.sbs.gob.pe – in accordance with what is established in Supreme Decree No. 001-2009-JUS and its modifying norms.

Article 5.- This resolution enters into force on June 1, 2016.

Register, communicate, and publish.
JAVIER MARTÍN POGGI CAMPODÓNICO
Superintendent of Banks, Insurance and Private Pension Fund Administrators (e)

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ANNEX No. 1
SWORN DECLARATION OF CLIENT KNOWLEDGE
To be filled out by the client of the legal entity that operates casino games and/or slot machines (For exclusive use of the obligated subject, the supervisory body, and the SBS through UIF-Perú) CLIENT: DATA OF THE PERSON PERFORMING THE OPERATION (EXECUTOR) By this document, I declare under oath, the following:
1 First Names: Last Names:
2 Type and number of identity document (mark with an "X" as applicable):
DNI Passport Alien ID Card No.
3 Nationality (fill only if foreign):
4 Have you been or are you a public official or first-level official of an international organization in the last 5 years? A first-level official is considered a direct collaborator of the highest authority of the institution (mark with an "X" as applicable): I AM ( ) I HAVE BEEN ( ) I AM NOT ( ) I HAVE NOT BEEN ( ) If you marked "I am" or "I have been", indicate:
Position:______ Name of the institution: ______ 5 I perform this operation on behalf of: (mark with an "X" as applicable):

1. Myself ( ) 2. Natural person ( )
   If you marked option 1, complete the information in item 5.1; if you marked option 2, complete the information in item 5.2.
   5.1. If you perform the operation on behalf of yourself, complete the following information:
   a) Origin of the money involved in the operation:
   5.2. If you perform the operation on behalf of another natural person, complete the following information:
   a) First names and last names of the natural person:
   b) Origin of the money involved in the operation:
   c) Specify if you have representation by power of attorney, mandate, notarial document and/or registry:
   I affirm and ratify everything stated in this sworn declaration.
   SIGNATURE
   DATE (dd/mm/yyyy) / /

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1
2
3
S/.
3. BACKGROUND
Phone:
II. WORK BACKGROUND
TOTAL
I declare having police records: Yes No . If positive, indicate the reason:
Mark "X" as applicable. If the answer was "YES", indicate the reason I declare having criminal records: Yes No . If positive, indicate the reason:
Mark "X" as applicable. If the answer was "YES", indicate the reason No.:
St - Av . - Street - Passage
Indicate the professional studies and specialized training received Home Address:
Profession or Trade : Occupation / Position :
If applicable, provide the LAST NAMES and FIRST NAMES of the spouse or partner:
Urban / Complex / Zone / Sector District Prov ince
2. STUDIES
1. Patrimonial information (referring to the number of real estate assets and value)
ANNEX No. 2
I. PERSONAL BACKGROUND
I declare under oath that the data recorded in this document are true and current. In case of change, I obligate myself to my employer to communicate it within a maximum term that will not exceed fifteen (15) calendar days from the occurrence of the change. (To be incorporated into the personal documentation of the directors and employees of the legal entity that operates casino games and/or slot machines
1. PERSONAL DATA
SWORN DECLARATION OF KNOWLEDGE OF DIRECTORS AND EMPLOYEES Paternal Surname Maternal Surname Civil Status a. Single b. Married c. Cohabiting d. Divorced e. Widowed a. DNI b. Alien ID Card c. Country:______ First Names Identity Document:
Name of the Company or Entity
Department
N o ta : To be conserved by the obligated subject and, if applicable, exhibited and/or sent upon request of the supervisory body during supervision visits and to UIF -P erú. It is not required to send to UIF -P erú, unless express request. City SIGNATURE OF DECLARING EMPLOYEE/DIRECTOR
III. PATRIMONIAL BACKGROUND
Date (dd/mm/yyyy)
Prepared and signed in:
2. Other income
1. WORK EXPERIENCE IN THE LAST 2 YEARS (from most recent to oldest)
No. Position Performed Start Date
Month - Year
End Date
Month - Year

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ANNEX No. 3
DESIGN FOR THE IDENTIFICATION OF UNUSUAL TRANSACTIONS (For use by the legal entity that operates casino games and/or slot machines ITEM DESCRIPTION OF FIELDS / ITEMS DATA OF THE OBLIGATED SUBJECT IDENTIFICATION (Data to be recorded only in the initial part of the record, not regarding each operation) 1 Code of the obligated subject granted by UIF-Perú. 2 Code of the compliance officer granted by UIF-Perú. 3 Registration period. DATA OF THE UNUSUAL TRANSACTION 4 Row number: Record the sequence number corresponding to the lines contained in the file to be registered, starting with the number one (1). 5 Operation registration number: Record the sequence number corresponding to each operation record recorded in the RO, starting with the number one (1), according to the following format: (year - number). 6 Internal operation registration number: Record the number corresponding to the operation identified as unusual. 7 Date of the operation: Record the date the operation was performed (dd/mm/yyyy). 8 Office code where the operation was performed (in case the obligated subject has more than one office). DATA OF THE IDENTIFICATION OF THE PERSONS INVOLVED IN THE UNUSUAL TRANSACTIONS (record the data for each person involved in the unusual transaction) 9 Condition in which they intervene in the unusual transaction (Mark option 1, 2, or 3): (1): Executor; (2) Beneficiary (person on whose behalf the operation is performed); (3) Executor and beneficiary. 10 Paternal surname of the person performing the operation. 11 Maternal surname of the person performing the operation. 12 First names of the person performing the operation. 13 Type of identity document of the person performing the operation. Record the code according to Table No. 1: Type of document. 14 Number of identity document of the person performing the operation. 15 Nationality (fill only if foreign) 16 Occupation, trade, or profession (natural person): Record the codes according to Table No. 2. 17 Description of the occupation, trade, or profession, if in the previous item you marked the option "other". 18 Person is PEP: (1) If yes (2) If has been (3) If no (4) If has not been. If you recorded option (1) or (2), complete the information in items 19 and 20. 19 Position: record the codes according to Table No. 3, if applicable. 20 Name of the institution. 21 Person on whose behalf the operation was performed (Record options 1, 2, or 3 as applicable): (1) On behalf of oneself; (2) Natural person. If you recorded option (1) complete the information in item 22. If you recorded option (2) complete the information in items 23 to 27. 22 Origin of the money involved in the operation. 23 First names and last names of the natural person.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 26/42 24 Origin of the money involved in the operation.
25 Data of the representation (mark with an "X"): Power of Attorney ( ) Mandate ( ) 26 Notarial data of the power of attorney or mandate (Date of the public instrument, name and jurisdiction of the notary) 27 Registry data of the power of attorney or mandate (Registry entry, seat and heading and registry zone) DATA RELATED TO THE DESCRIPTION OF THE OPERATION 28 Type of funds or assets with which the operation was performed: Record the code according to Table No. 4. 29 Type of operation for the obligated subject: Record the code according to Table No. 5. If you recorded the code for "Other", complete the information in item 30. 30 Description of the type of operation 31 Description of the operation (Indicate the arguments that led you to qualify the operation as unusual) 32 The operation has been qualified as suspicious: (1) Yes or (2) No 33 If in item 32 you recorded option (1) indicate the ROS number with which it was sent to UIF-Perú 34 If in item 32 you recorded option (2) describe the arguments by which this operation was not qualified as suspicious ALERT SIGNALS IDENTIFIED (This data must be recorded for each alert signal) 35 Code of the alert signal 36 Description of the alert signal 37 Source of the alert signal: (1) Monitoring System; (2) Commercial Area; (3) Analysis of the CO; (4) Press; (5) Other sources. 38 If in item 37 you recorded option (5) describe the source.
Table No. 1
IDENTITY DOCUMENT
Code Description
001 NATIONAL IDENTITY DOCUMENT
002 ALIEN IDENTITY CARD
003 POLICE FORCES IDENTITY CARD
004 ARMED FORCES IDENTITY CARD
005 PASSPORT
006 CITIZENSHIP CARD
007 DIPLOMATIC IDENTITY CARD
009 OTHER
Table No. 2
OCCUPATION, TRADE OR PROFESSION
Code Description Code Description
001 LAWYER 060 HISTORIAN
002 ACTOR, ACTRESS, ARTIST, SHOW DIRECTOR,
CHOREOGRAPHER, MODEL, MUSICIAN, SET DESIGNER AND DANCERS 061 ENGINEER 003 ACTUARY 062 INTERPRETER, TRANSLATOR 004 ADMINISTRATOR 063 GARDENER 005 CUSTOMS OFFICER/AGENCY AGENT/FRONTIER INSPECTORS 064 JOCKEY 006 FLIGHT ATTENDANT 065 JEWELER AND/OR SILVERSMITH /

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 27/42 GOLDSMITH 007 AGENT / INTERMEDIARY / REAL ESTATE BROKER 066 RETIREE / PENSIONER 008 STOCKBROKER 067 LABORATORY TECHNICIAN 009 IMMIGRATION AGENT 068 ADJUSTER, CLAIMS/INSURANCE 010 TOURISM/TRAVEL AGENT 069 MACHINIST / MACHINERY OPERATOR 011 AGENT/INTERMEDIARY/INSURANCE BROKER 070 AUCTIONEER 012 FARMER, AGRONOMIST, AGRONOMIST, ARBORIST, SURVEYOR, TOPOGRAPHER, GEOGRAPHER 071 WHOLESELLER, RETAIL WHOLESALE 013 MASON, CONSTRUCTION WORKER 072 MECHANIC 014 HOUSEWIFE 073 DOCTOR / SURGEON 015 SYSTEM AND COMPUTING ANALYSTS 074 METALLURGIST 016 ANTHROPOLOGIST, ARCHAEOLOGIST AND ETHNOLOGIST 075 MEMBER OF THE ARMED FORCES 017 ARCHIVIST 076 NUTRITIONIST 018 SHIPBUILDER 077 WORKER / OPERATOR 019 ARCHITECT 078 MIDWIFE 020 ARTISAN 079 EVENT ORGANIZER 021 SOCIAL ASSISTANT 080 BAKER / PASTRY CHEF 022 LITERARY AUTHOR, WRITER AND CRITIC 081 PARAMEDIC 023 POULTRY FARMER 082 JOURNALIST 024 BACTERIOLOGIST, PHARMACOLOGIST, BIOLOGIST, SCIENTIST 083 EXPERT 025 TRASH COLLECTOR / SWEEPER 084 FISHERMAN 026 CASHIER 085 PILOT 027 WAITER / BARMAN / WAITER/ COOK / CHEF 086 PAINTER 028 EXCHANGER, CURRENCY BUY/SELL 087 MUNICIPAL POLICE 029 PEASANT 088 PNP POLICE 030 FOREMAN 089 CINEMA / RADIO / TELEVISION / THEATER PRODUCER 031 LOADER 090 PRODUCER, EXTENSIVE CROPS 032 CARPENTER 091 PROGRAMMER 033 POSTMAN 092 PSYCHOLOGIST/ THERAPIST 034 LOCKSMITH 093 CHIROPRACTOR/ KINESIOTHERAPIST (KINESIOLOGISTS) 035 COLLECTOR 094 PUBLIC AND INDUSTRIAL RELATIONS OFFICER 036 MERCHANT / SELLER 095 WATCHMAKER 037 DRIVER, CHAUFFEUR / TAXI DRIVER 096 CAR REPAIR, PAINTER REFINISHER 038 JANITOR / DOORMAN/ GUARD/ WATCHMAN 097 REPAIRER OF APPLIANCES 039 BUILDER 098 DELIVERY PERSON 040 ACCOUNTANT 099 PRIEST / NUN

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 28/42 041 CONTRACTOR 100 SECRETARY, RECEPTIONIST, TELEPHONE OPERATOR 042 CUTTING AND SEWING OF CLOTHES/ CLOTHING MANUFACTURER 101 SECURITY / BODYGUARD / SECURITY GUARD 043 COSMETOLOGIST, HAIRDRESSER AND BARBER 102 WAREHOUSE SERVICE/WAREHOUSE KEEPER 044 DECORATOR, DRAWER, ADVERTISER, ADVERTISING DESIGNER 103 VEHICLE RENTAL SERVICE 045 DENTIST / DENTIST 104 VIDEO RENTAL SERVICE, SOUND EQUIPMENT 046 PROFESSIONAL ATHLETE, ATHLETE, REFEREE, SPORTS COACH 105 SOCIOLOGIST 047 DISTRIBUTOR 106 APPRAISER 048 TEACHER 107 TECHNICIAN 049 ECONOMIST 108 BULLFIGHTER 050 ELECTRICIAN 109 PROCESSOR 051 HOUSEHOLD EMPLOYEE (O) / NANNY 110 CARGO TRANSPORT AND/OR RELOCATION 052 EXPORTING BUSINESSMAN/ IMPORTING BUSINESSMAN 111 TRANSPORTER 053 NURSE 112 STREET VENDOR 054 ASSEMBLER 113 VETERINARIAN, ZOOLOGIST, ZOOTECNICIAN 055 SCULPTOR 114 MEDICAL VISITOR 056 STUDENT 115 SHOEMAKER 057 PHOTOGRAPHER / CAMERA OPERATORS, CINEMA AND TV, RADIO AND TV ANNOUNCER, SCREENWRITER 116 OTHERS (indicate) 058 LIVESTOCK FARMER 117 DOES NOT DECLARE 059 PLUMBER
Table No. 3
POSITIONS
Code Description Code Description
001 MAYOR 019 PUBLIC NOTARY
002 ANALYST 020 INTERN
003 REPRESENTATIVE 021 PREFECT
004 ADVISOR / CONSULTANT 022 PRESIDENT OF REGIONAL GOVERNMENT 005 ASSISTANT 023 PRESIDENT OF THE SUPREME COURT 006 AUDITOR 024 PRESIDENT OF THE REPUBLIC 007 AUXILIARY / HELPER 025 PRESIDENT, TRIBUNAL OF JUSTICE 008 CONGRESSMAN 026 MINISTER / VICE MINISTER 009 COMPTROLLER GENERAL 027 PROSECUTOR 010 DEAN 028 ATTORNEY GENERAL 011 DIPLOMAT 029 RECTOR 012 SPORTS ASSOCIATION EXECUTIVE 030 COUNCIL MEMBERS OF MUNICIPALITIES 013 DIRECTOR, SUBDIRECTOR, MANAGER, HEAD OF THE PRIVATE SECTOR 031 SUB-PREFECT

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 29/42 014 TEACHER 032 SUPERINTENDENT OF PUBLIC ADMINISTRATION 015 INSPECTOR 033 VICE-PRESIDENT OF THE REPUBLIC 016 INTENDANT, DIRECTOR, MANAGER, HEAD OF PUBLIC ADMINISTRATION 034 JUDGE OF THE SUPERIOR OR SUPREME COURT 017 GENERAL INTERVENTOR OF PUBLIC ADMINISTRATION ECONOMY 035 OTHERS (indicate) 018 JUDGE 036 DOES NOT DECLARE
Table No. 4 Table No. 5
TYPE OF FUNDS TYPE OF OPERATION
Code Description Code Description
001 CASH 001 EXCHANGE OF MONEY FOR CHIPS
002 CHECK 002 EXCHANGE OF CHIPS FOR MONEY
003 WIRE TRANSFER
003
EXCHANGE OF TICKET (SLOT MACHINE
CREDITS) FOR
MONEY
004 BANK TRANSFER 004 EXCHANGE OF LOTTERY TICKET FOR CHIPS 005 ACCOUNT DEPOSIT 005 PRIZE COLLECTION (JACKPOT) 006 CREDIT CARD 006 TABLE GAME 099 OTHER 999 OTHER

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ANNEX No. 4
ALERT SIGNALS
(For use by the legal entity that operates casino games and/or slot machines) Alert signals constitute for the obligated subject, its employees, and the compliance officer, a tool to be taken into account with the purpose of detecting and/or preventing suspicious operations related to ML/FT. If any of the operations or situations indicated below are identified, they must be analyzed and evaluated by the compliance officer to determine if they constitute suspicious operations, and if so, communicate them to UIF-Perú as a Suspicious Operations Report (ROS), through the ROSEL system. Each obligated subject must define particular criteria linked to the alerts depending on the nature of its operations. Likewise, each obligated subject must develop alert evaluation procedures, which must be found in the Manual, available to UIF-Perú. The list of alert signals is not exhaustive, so each obligated subject must consider other situations that escape normality, according to its good judgment.

I. Unusual operations or conduct relative to the obligated subject's clients

1. The client, for identification purposes, refuses to provide information, presents inconsistent information or information difficult to verify by the obligated subject.
2. The client declares or registers the same address as other people and/or clients with whom they have no apparent relationship or link.
3. The existence of indications that the executor (who performs the operation) or the beneficiary (who benefits from the operation) is not acting on their own behalf and attempts to hide the identity of the beneficial owner.
4. The client shows unusual indifference to the risks they assume or to the amounts or costs involved in the operation.
5. The client performs operations successively and/or repeatedly, without this adjusting to their occupation and/or economic activity.
6. The client refuses to fill out forms or provide the information required by the obligated subject, or refuses to perform the operation as soon as it is requested.
7. That it is known through public media or otherwise, as the case may be, that a client (executor and/or beneficiary) is being investigated or prosecuted for the crime of money laundering, predicate crimes, the crime of terrorist financing and/or related crimes.
8. The client frequently performs operations for amounts of money that do not relate to their occupation and/or income.
9. The client appears on any of the international lists of the United Nations, OFAC or others that contribute to the prevention of ML/FT (Annex No. 9).
10. The client uses intermediaries to perform operations.
11. Clients domiciled in countries with low or zero tax imposition.
12. The client requests that a document or certificate be issued accrediting the amount won.

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II. Unusual operations or conduct regarding employees of the obligated entity

1. The employee's lifestyle does not correspond to their income, or there is a notable and unexpected change in their economic situation.
2. The employee's address appears in operations carried out by the client, repeatedly and/or for significant amounts, without any apparent link between the employee and the client.
3. An unusual or sudden growth in the number of operations under the employee's responsibility is observed.
4. It is proven that the employee has not communicated or has concealed from the compliance officer of the obligated entity information regarding the change in behavior of any client.
5. The employee refuses to present and/or update all information required in the Sworn Declaration of Knowledge of Directors and Employees or its equivalent, or it is verified that they have submitted false information.
6. It is proven that the employee is involved in non-profit organizations, such as foundations, associations, committees, NGOs, among others, whose objectives have been duly demonstrated to be related to the ideology, claims, or demands of a national and/or foreign terrorist organization.

III. Operations related to the activities of the obligated entity

1. Persons who acquire significant quantities of gaming chips with low-denomination bills.
2. Persons who repeatedly request to exchange instruments proving alleged gaming winnings (chips, tickets, or others) for financial instruments (checks, bank transfers, account deposits, among others) in their favor or in favor of a third party.
3. A person who continuously places the maximum allowed bet at the table, without regard to the information available regarding their economic or financial capacity.
4. Players who place bets of considerable sums that do not correspond to their economic and financial profile.
5. Situations in which the prize winner is linked to the operating and/or administrative company of the game of chance.
6. A player whose bets are disproportionate in relation to the expected prize.
7. A player who wins prizes in more than one draw or game of chance, with a frequency that exceeds the probabilities of the game to obtain them.
8. Persons who show interest in establishing contact with prize winners or winners of games of chance.

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ANNEX No. 5
BASIC CONTENT OF THE MANUAL FOR THE PREVENTION AND MANAGEMENT OF MONEY LAUNDERING AND TERRORISM FINANCING RISKS

The manual for the prevention and management of money laundering and terrorism financing risks, hereinafter referred to as the Manual, aims to ensure that directors, managers, and employees of legal entities operating casino games and/or slot machines, authorized by MINCETUR to carry out such activity, have at their disposal the policies and procedures that must be observed in the exercise of their functions. The Manual must contain, at least, the following information:

1. General aspects:
   1.1. Relevant definitions related to the prevention and management of ML/TF risks.
   1.2. Objective of the Manual.
   1.3. Policies related to the prevention and management of ML/TF risks.
   1.4. Training, considering the minimum content developed in the Standard for the prevention of ML/TF applicable to legal entities operating casino games and/or slot machines.
   1.5. General guidelines established in the code of conduct of the obligated entity with the objective of managing ML/TF risks.
   1.6. Infractions and internal sanctions, contemplated in the Internal Work Regulations of the obligated entity, the code of conduct, the manual, the ML/TF prevention system, or legal provisions on the matter, for non-compliance with established obligations.

2. Functions and responsibilities:
   2.1. General obligations applicable to all employees of the obligated entity regarding ML/TF prevention.
   2.2. Functions and responsibilities associated with the prevention and management of ML/TF risks of the board of directors, management, the compliance officer, and employees, considering for this purpose the role they play in the obligated entity and their powers.
   2.3. Functions and responsibilities of the compliance officer and their staff.

3. General mechanisms for the management of money laundering and terrorism financing risks (if applicable):
   3.1. Description of ML/TF risk factors.
   3.2. Description of the procedure and criteria for customer, market knowledge, indicating the levels of its execution.
   3.3. Procedure to evaluate the personal, professional, and asset background of employees and directors.
   3.4. Alert signals to determine unusual conduct of employees, managers, and directors.
   3.5. Alert signals for the detection of unusual or suspicious operations of its clients.
   3.6. Procedure for the analysis of alerts, unusual operations, and suspicious operations.

4. Registration and communication procedures:
   4.1. The format and periodicity with which the board of directors and general management or similar position, among others, must be informed about the ML/TF risk exposure of the obligated entity.
   4.2. Procedures for the registration, archiving, and conservation of information and documentation required, in accordance with current regulations.

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4.3. Forms for the registration of operations and reporting of unusual operations to the compliance officer.
4.4. Internal procedures for the consultation and communication of unusual and/or suspicious operations.
4.5. Procedures for the reporting of suspicious operations to UIF-Peru within the legal deadline.
4.6. Procedures to attend to information requests or additional information requested by competent authorities.
4.7. Communication channels between the offices of the obligated entity with the different instances within the obligated entity for the purposes of the ML/TF prevention system, if applicable.
4.8. Consultation mechanisms between the compliance officer and other departments of the obligated entity, if applicable. In the event that the compliance officer is corporate, the consultation mechanisms between all companies of the economic group must be indicated.

5. International and regulatory references on the prevention of money laundering and terrorism financing

Mechanisms or means by which the current regulations on the prevention of ML/TF and international standards on the matter, their modifications, and substitutions, will be available to the directors and employees of the obligated entity must be indicated.

The development of each of the minimum aspects contemplated in the Manual may be included in this or in another internal normative document of the obligated entity, provided that such documents have the same approval procedure. In the latter case, it must be specified in the Manual which aspects have been developed in other internal normative documents, which must be available to the supervisory body and to UIF-Peru.

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ANNEX No. 6
MODEL OF SWORN DECLARATION OF RECEIPT AND KNOWLEDGE OF THE MANUAL AND/OR CODE

By this document, I declare under oath the following:

1. That my current legal details as of this date are:
   First Names: Last Names:
   Identify myself with: DNI Passport Foreigner's ID Card No.
   (Mark with an "X" what corresponds)

2. That, upon signing this document, I have received the printed version of the following documents from the obligated entity:

• Manual for the prevention and management of ML/TF risks
• Code of Conduct for the prevention of ML/TF.

3. I know that both documents are mandatory compliance.

4. I know that if I violate their provisions, I am subject to disciplinary sanctions by my employer/contractor.

I affirm and ratify everything stated in this sworn declaration, as a sign of which I sign it, in the place and date indicated below:
DISTRICT PROVINCE DEPARTMENT Date: dd mm yyyy
S I G N A T U R E

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ANNEX No. 7
MODEL OF
CODE OF CONDUCT FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING

CHAPTER I
GENERAL PROVISIONS

Article 1.- OBJECTIVE
The Code of Conduct for the prevention of money laundering and terrorism financing, hereinafter referred to as the Code of Conduct, aims to establish the minimum bases of responsible behavior, as well as the principles, duties, and ethical norms that the obligated entity must know and comply with, in order to promote the proper functioning of the money laundering and terrorism financing prevention system.

Article 2.- SCOPE
This Code of Conduct is applicable to:

---

(Enter the name/trade name of the obligated entity) hereinafter referred to as the obligated entity, who is under the supervision of the Ministry of Foreign Trade and Tourism – MINCETUR, in matters of prevention of money laundering and terrorism financing. Likewise, it is applicable to its employees according to the definition of this Code.

Article 3.- DISSEMINATION
The obligated entity will disseminate laws, norms, internal provisions, manuals, and other information it considers relevant in matters of ML/TF prevention, among its employees and directors, as appropriate to the specific type of labor of each person. Likewise, it will deliver a copy of this Code, approved in compliance with the norms on the matter, to each employee and director, in order to facilitate compliance with these by its employees.

The adequate dissemination of this Code will be accredited by the signing of the sworn declaration of receipt and knowledge or the document that makes it up and that the obligated entity deems pertinent.

Article 4.- GLOSSARY OF TERMS
For the purposes of the application of this Code of Conduct, the following shall be understood:
a) Code: Code of conduct for the prevention of ML/TF. b) Days: calendar days. c) Terrorism financing: crime typified in article 4-A of Legislative Decree No. 25475 and its modifying norms. d) Casino games: Any table game in which cards, dice, chips, or roulette are used, which admits public bets, the result of which depends on chance; as well as other games to which current regulations grant such qualification. e) ML/TF: money laundering and terrorism financing.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 36/42

f) Money laundering: crime typified in Legislative Decree No. 1106, Legislative Decree on Effective Fight against Money Laundering and other crimes related to Illegal Mining and Organized Crime, and its modifying norms. g) Law: Law creating the Financial Intelligence Unit of Peru, UIF-Peru, Law No. 27693 and its modifying norms. h) Manual: Manual for the prevention and management of ML/TF risks. i) Slot machines: all electronic, electromechanical, or analogous gaming machines, which receive bets from the player in money and therefore allow them a time of use in exchange for the payment of the play based on chance and, eventually, the obtaining of a prize according to the game program, in accordance with current regulations. j) Compliance officer: natural person who collaborates in the implementation of the ML/TF prevention system and is responsible for monitoring and verifying its functioning. k) Unusual operations: operations carried out or attempted to be carried out, whose amount, characteristics, and periodicity do not correspond to the client's economic activity, fall outside the parameters of normality currently in force in the market, or do not have an evident legal basis. l) Suspicious operations: operations carried out or attempted to be carried out, whose amount or characteristics do not correspond to the client's economic activity, or that do not have an economic basis; or that by their number, by the amounts transacted, or by their particular characteristics, could reasonably lead to suspect that the obligated entity is being used to transfer, manage, take advantage of, or invest resources originating from criminal activities or intended for their financing. m) Supervisory body: the Ministry of Foreign Trade and Tourism (MINCETUR) through the General Directorate of Casino Games and Slot Machines of the Vice Ministry of Tourism of MINCETUR. (DGJCMT). n) Regulations: Regulations of the Law creating UIF-Peru, approved by Supreme Decree No. 018-2006-JUS. o) RO: Register of operations. p) ROS: Report of suspicious operations. q) SBS: Superintendence of Banks, Insurance and Private Pension Fund Administrators. r) Obligated entity: legal entity that operates casino games and/or slot machines, authorized by MINCETUR to carry out such activity. s) Employee: natural person who maintains a labor or contractual link with the obligated entity; includes the general manager, managers, administrators, or those who hold similar positions. t) UIF-Peru: Financial Intelligence Unit of Peru, a specialized unit of the SBS.

CHAPTER II
ETHICAL PRINCIPLES AND DUTIES

Article 5.- ETHICAL PRINCIPLES
5.1 The obligated entity and its employees must act in the exercise of their activities, under the following principles:
5.1.1 Respect and adequacy to norms.
Complying with the norms that regulate the exercise of their activities, adapting their conduct towards respect for the Political Constitution of Peru, the Laws, and the current legislation in matters of fighting ML/TF, as well as the Standard for the prevention of money laundering and terrorism financing applicable to legal entities operating casino games and slot machines, this code, and the manual.

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5.1.2 Probity
Exercising their functions with responsibility, acting with rectitude, honesty, and integrity, and ensuring that the obligated entity is not used in ML/TF activities.

5.1.3 Confidentiality
Guaranteeing the strict confidentiality of information and the anonymity of the compliance officer, both with respect to the responsibilities assigned to them by Law, and regarding the ROS that they communicate to the SBS through UIF-Peru and the investigation and judicial processes that may take place based on them.

5.1.4 Equity
Acting with justice and mutual respect in their internal relations and with their clients, with public bodies and private entities, with the supervisory body, as well as with the SBS through UIF-Peru.

5.1.5 Competence
Guaranteeing technical and moral aptitude in the development of their activities, taking advantage of training opportunities for the proper fulfillment of their functions and, especially, in matters of ML/TF prevention.

5.1.6 Impartiality
Evaluating objectively the information at their disposal or under their charge for the detection of unusual and suspicious operations and, if applicable, issuing the corresponding reports, demonstrating independence in their links with people and institutions.

5.1.7 Veracity
Expressing themselves with the truth, in the exercise of their activities and fulfillment of their functions, as well as with clients and third parties.

Article 6.- ESSENTIAL DUTIES
6.1 The obligated entity, its directors, and employees must comply with the duties established in the Law, its regulations, and other applicable norms, putting special diligence in:

6.1.1 Duty to Inform
Pay special attention to the detection of unusual operations and in the prevention or detection of suspicious operations, informing UIF-Peru through the ROS when appropriate, in accordance with what is established in the Law, its Regulations, and other applicable provisions on the matter.

6.1.2 Duty of registration and conservation
Register all operations carried out by its clients, without any exclusion, in a precise, complete, and chronological manner, in accordance with the amounts established in the Standards for the prevention of ML/TF applicable to legal entities operating casino games and/or slot machines, conserving them for the legal period, and making them available to UIF-Peru in the form and deadline that it determines.

Conservation of the identification of unusual operations, their documentary support, respective analysis and evaluations, as well as the reason why such operation was not qualified as suspicious and reported to UIF-Peru, if applicable.

6.1.3 Duty of Reserve
Under responsibility, the obligated entity and its employees are prohibited from informing any person, entity, or body, under any means or modality, of the fact that any information has been requested by UIF-Peru or has been provided in accordance with the Law, except by requirement of the judicial body or competent authority, in accordance with current regulations.

The obligated entity must adopt measures intended to support its employees in the development of the activities they carry out, for the effective compliance with current norms. In no case may this or its employees adopt reprisals or exercise any coercion against other employees, their clients, or other persons members of the National System for the Prevention and Detection of ML/TF.

6.2 For the fulfillment of the duties emanating from current norms, it corresponds to the obligated entity to adopt measures regarding the following aspects:

6.2.1 Regarding due diligence of customer knowledge:
a. Identify adequately and reliably the clients who request the provision of casino games and/or slot machine services, whether they are a habitual or occasional client and the operation they carry out is subject to the RO, requiring the exhibition of the identity document and additional information when appropriate. b. Establish the requirements for additional documentation for the identification of the client, verifying it.
c. Be attentive to changes in the usual behavior of clients, which allow detecting significant departures from normal operations, in order to carry out the analysis and evaluation in accordance with current legal regulations.
d. If as a result of the aforementioned, the operation is identified as suspicious, the corresponding ROS must be sent.

6.2.2 Regarding the knowledge of directors, managers, and employees
a. Ensure that its employees and directors have a high level of integrity. b. Gather information on the personal, professional, and asset background of the employee, which will be in their personnel file, guaranteeing the transparency of the information provided. The information must be updated and will be available to the supervisory body and to the SBS when UIF-Peru requests it.

6.2.3 Regarding ML/TF preventive policies
a. Designate a compliance officer who meets the requirements provided in current regulations, and, if applicable, designate the new compliance officer in a timely manner. b. Identify alert signals and ML/TF typologies and disseminate them among employees, keeping them informed and aware of the risks that permissive conduct may bring to the obligated entity.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 39/42

c. Comply with at least one training session in matters of prevention and detection of ML/TF for directors, managers, and employees, according to their functions, on the topics provided in the Standard for the prevention of ML/TF applicable to legal entities operating casino games and/or slot machines.
d. Know the current legal framework in matters of ML/TF prevention, disseminating the respective updates among its employees.

CHAPTER III
NON-COMPLIANCE WITH THE PROVISIONS OF THE CODE OF CONDUCT AND DISCIPLINARY MEASURES

Article 7.- NON-COMPLIANCE WITH THE PROVISIONS OF THE CODE OF CONDUCT
Non-compliance with the provisions of this Code is sanctionable by the supervisory body in the administrative route, in accordance with what is established in the Regulations on Infractions and Sanctions issued for this purpose.

Without prejudice to this, the following constitute infractions sanctionable by the obligated entity, those committed by its employees as indicated below:
a) Not signing the Sworn Declaration of receipt and knowledge of both the Manual and the Code, or the document that makes it up and that the obligated entity deems pertinent. b) Revealing the identity of the compliance officer and/or the alternate compliance officer and, if applicable, the corporate compliance officer. c) Non-compliance with the procedures of the internal manuals established by the obligated entity, in matters of ML/TF prevention, if applicable. d) Non-compliance or violation of the procedures, guides, and internal guidelines established by the obligated entity for customer identification. e) Not preparing or preparing outside the corresponding deadline, the annual report of the compliance officer, the RO, the REGAP, or other register(s) or reports that are among their functions. f) Unjustified absence from scheduled training sessions in matters of prevention and detection of ML/TF. g) Obstructing or attempting to prevent the work of the supervisory body in supervision visits. h) Excluding any client from the RO. i) Violating the duty of reserve, informing any person, entity, or body, under any means or modality, even of the supervisory body, of the fact that any information has been requested by UIF-Peru or has been provided. j) Not communicating to the compliance officer about a certain suspicious operation of a client.

The obligated entity will qualify these infractions in its internal regulations, if applicable, according to their severity, whether they are minor, serious, or very serious infractions, for the purpose of imposing the corresponding sanction. Non-compliance generated by fortuitous event or force majeure duly proven, does not constitute an infraction.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 40/42

ANNEX N° 8
INFORMATION TO REQUEST AUTHORIZATION TO HAVE A CORPORATE COMPLIANCE OFFICER

The application for authorization to have a corporate compliance officer must be signed by the legal representative of each of the obligated subjects that make up the economic group, attaching the following information:

1. A technical report that supports the viability of having a corporate compliance officer. The aforementioned report must contain the following information and/or documentation:

a) List of members that make up the economic group, indicating for each of them: RUC number, name of the legal representative, and main economic activity. b) The linkage that exists between the obligated subjects to be considered as an economic group. c) Amount of current social capital of each member of the economic group. d) Full names and/or corporate name or trade name of the shareholders and their respective percentages and amount of participation regarding social capital, of each member of the economic group as of the month prior to the date of the application. e) Number of employees of each member of the economic group as of the month prior to the date of the application. f) Geographical location (department, province, and district) of the main establishment and of the annex establishments of each member of the economic group as of the month prior to the date of the application, including those that may be administrative establishments. g) Number of operations in the year prior to the application (cash transactions), discriminating the information monthly, performed by room (indicating the total number of operations and the number of operations that exceed the threshold) by each member of the economic group. h) Total income received in the year prior to the application and income projections for the year in which the application is presented. i) Statistics on the number of clients, (detailing how many are regular or occasional). j) Medium and method of collection and/or payment for the goods and/or services offered by the members of the economic group (transfers, cash, others). k) Medium through which they register operations. l) Reasons for requesting the designation of a corporate compliance officer. m) Reasons why it is considered viable to have a corporate compliance officer and description of the manner in which compliance with current provisions in the matter of prevention of ML/FT will be given, for each of the members of the economic group under the charge of the corporate compliance officer. n) List of personnel that will be under the charge of the corporate compliance officer, as well as the list of corporate coordinators designated by each member of the economic group, indicating which are the additional obligations they fulfill

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 41/42 in the companies of the economic group. o) Description of the level of exposure to ML/FT risks of the obligated subjects that make up the economic group, taking into account what is stated in article 3° of the Standard for the prevention of money laundering and terrorist financing applicable to companies that operate casino games and slot machines.

2. Sworn statement indicating that the appointment of the corporate compliance officer has the approval of the highest authority of each of the obligated subjects that make up the economic group, which must be signed by each of the legal representatives of the obligated subjects that make up the economic group.

3. Sworn statement by the corporate compliance officer specifying that, in their personal documentation presented to the obligated subjects, there is sufficient information regarding their personal background, work history, credit history, and asset history.

4. Sworn statement regarding that, if the authorization is granted, the corporate compliance officer will have sufficient personnel to fulfill their obligations.

5. Curriculum vitae of the corporate compliance officer.

6. In the event that there are members of the economic group that are under the jurisdiction of other supervisory bodies, the receipt of such applications must also be attached to the aforementioned application to prove that they are in process.

7. Others that the supervisory body and UIF-Perú consider pertinent to request.

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511) 6309000 Fax: (511) 6309239 42/42

ANNEX N° 9
LISTS THAT CONTRIBUTE TO THE PREVENTION OF ML/FT

In accordance with what is stated in the Standard for the prevention of money laundering and terrorist financing applicable to legal entities that operate casino games and/or slot machines, authorized by MINCETUR for the exercise of said activity, the following documents must be reviewed:

a) OFAC List: list issued by the Office of Foreign Assets Control of the Department of the Treasury of the United States of America (OFAC), which includes countries, persons and/or entities, that collaborate with terrorism and the illicit drug trade. b) Lists of terrorists of the United Nations Security Council, in particular the Lists on persons involved in terrorist activities (Resolution N°1267). c) List of terrorists of the European Union. d) Lists related to the Financing of the Proliferation of Weapons of Mass Destruction: Lists issued by the UN Security Council. Includes at least, the Consolidated List UN Resolution 1718, on the Democratic People's Republic of Korea (North Korea) and the Consolidated List UN Resolution 1737, on Iran. e) List of Non-Cooperative Countries and Territories. f) Lists of Resolutions of the United Nations Security Council. g) Others indicated by the Superintendence, through Circular.