Legal notice

The entity responsible for this provisional website is not a banking institution nor a regulated financial entity, and does not provide services reserved for authorised institutions, except where expressly permitted by law and always in coordination with duly licensed entities. Accordingly, certain services, solutions or structures described herein may not be authorised, regulated or available in specific jurisdictions, including — but not limited to — activities subject to licensing regimes, financial supervision or prior authorisation by local or international regulatory authorities.

No information contained in this provisional website shall be interpreted as being directed at persons or entities resident in jurisdictions where the provision of such services is prohibited, restricted or conditioned by law. Prospective clients, partners or investors are responsible for seeking independent legal, regulatory and tax advice prior to any interaction or decision.

Access to, use of, and reliance upon the information provided in this provisional website are undertaken entirely at the user’s own risk. The user is responsible for obtaining independent professional advice — legal, financial, tax or otherwise — whenever appropriate, before making any decision based on the contents presented herein.

Prospective clients, partners, investors or readers acknowledge that the provision of certain services may be subject to legal or regulatory limitations depending on the applicable jurisdiction. The execution of any activity under this instrument is conditional upon full compliance with all laws, regulations and authorisations required by competent authorities, and no provision shall be construed as obliging the performance of acts that are legally prohibited.

Hare Capital Ltd. – Holding is a nonbanking entity operating under a boutiqueholding company model. It does not accept deposits, does not grant credit directly — only through regulated and authorised institutions — and does not conduct operations typical of regulated financial institutions.

The company positions itself as a development and investment boutiqueholding, dedicated to providing strategic support to companies of various sizes, as well as to public entities, municipalities and governments, in the design, structuring and monitoring of development and investment projects across multiple international jurisdictions.

Its intervention does not replace nor interfere with the functions of banking institutions or regulatory authorities. Instead, it is grounded in strategic advisory, opportunity identification, partner coordination and risk mitigation, in accordance with applicable legislation and recognised best practices in governance, transparency and institutional responsibility.

Hare Capital Ltd. – Holding, together with all boutique companies within the conglomerate, does not engage in transactions with entities associated with criminal activity or under criminal investigation, nor does it establish relationships with entities that are not legally constituted or authorised to conduct their activities.

The group of boutique companies owned, controlled or managed by Hare Capital Ltd. – Holding only establishes, maintains and develops legal relationships — including collaboration, cooperation or strategic partnership — with institutions that demonstrate the implementation of formalised, adequate, effective and systematised internal systems, policies and procedures.

Such procedures must ensure, clearly, audibly and consistently, the identification of operations offered to the market, the description of their execution mechanisms, and the definition of applicable validation, approval and internal control processes, guaranteeing full and effective compliance with legal, regulatory and prudential standards governing the marketing of corporate, banking and financial products and services.

In particular, these institutions must ensure strict compliance with legal and regulatory provisions relating to pricing, minimum banking services, advertising and client information rules, as well as national and international standards on antimoney laundering and counterterrorist financing (AML/CFT), including the adoption and application of security measures, enhanced due diligence, control and continuous monitoring, in accordance with legal obligations and sector best practices.

Hare Capital Ltd. – Holding, together with all boutique companies within the conglomerate, maintains a firm institutional commitment to cooperating with competent authorities, both nationally and internationally, in the fight against transnational financial crime and corruption — phenomena that have grown significantly and pose a structural threat to global financial systems, economic stability and the legal security of markets.

Increasing globalisation and accelerated digital transformation have been exploited by criminal organisations to enhance the sophistication, scale and effectiveness of their illicit activities. Recent experience, particularly during the COVID19 pandemic, demonstrated the adaptability of such groups through financial fraud schemes, phishing, investment scams, paymentrelated crime, money laundering, unlawful asset recovery and corruption, including cases of grand corruption.

In this context, Hare Capital Ltd. – Holding is committed to supporting authorities in the prevention, detection and effective suppression of financial crime and corruption, contributing to strengthened integrity, transparency and confidence in financial markets.

Financial crime and corruption are global phenomena with direct impact on individuals, companies, economies and States. Their effects are particularly severe in developing countries but affect all regions and levels of society. These crimes may undermine political, social and economic stability and ultimately endanger collective security, creating favourable conditions for organised crime and, in extreme cases, terrorism — often sustained by the complicity of corrupt public officials.

As financial crime becomes increasingly crossborder, investigations become more complex and prolonged due to the multiplicity of jurisdictions involved. In this context, Hare Capital Ltd. – Holding will reinforce and optimise existing initiatives and cooperate with public entities and strategic partners in combating illicit financial flows and asset recovery, promoting a coordinated, technically robust response aligned with international best practices.

Hare Capital Ltd. – Holding incorporates the fight against financial crime and corruption as a central pillar of its institutional strategy and responsible governance framework.

In a global environment marked by accelerated digitalisation and increasing market complexity, such illicit practices represent significant systemic risks, directly affecting investor confidence, economic stability and business sustainability.

Our boutiqueholding promotes a proactive approach based on

• Prevention and detection of illicit financial risks
• Cooperation with authorities and strategic partners
• Promotion of transparency, integrity and compliance

Financial crime and corruption affect companies, economies and entire societies, creating market distortions, significant economic losses and elevated reputational risks. Their transnational nature requires coordinated, technically robust responses aligned with international compliance and governance standards.

Hare Capital Ltd. – Holding positions itself as an institutional partner committed to protecting markets, strengthening stakeholder confidence and creating longterm sustainable value, through practices aligned with ESG principles, sound corporate governance and institutional responsibility.

The financial sector faces the ongoing challenge of preventing illicit financial activities while ensuring the efficient and secure processing of legitimate transactions. In this context, SWIFT plays a critical role as the global infrastructure for financial messaging, committed to integrity, security and regulatory compliance. SWIFT operates as a neutral messaging service provider, neither transferring funds nor holding custody of them, with responsibilities relating to KYC (Know Your Customer), AML (AntiMoney Laundering) and CTF (CounterTerrorist Financing) resting entirely with financial institutions and their respective competent authorities.

In alignment with European Union regulations, the guidelines of supervisory authorities and recommendations issued by international regulatory bodies, SWIFT provides secure financial messaging services that promote standardisation, transparency and international interoperability. SWIFT continuously develops standards, products and services that support financial institutions in meeting their legal and regulatory obligations. Any banktobank messages transmitted outside authenticated channels or official banking networks do not constitute valid proof.

Fraudulent SWIFT templates are frequently used by criminals to facilitate money laundering and the transfer of illicit assets. These templates may include messages combining legal terminology, references to notarial offices and mentions of authorities — including Central Banks — in an attempt to make fraudulent documents appear legitimate. Criminals exploit the banking system — and therefore SWIFT — using outdated message formats or external nonbank servers to move illicit funds, concealing their origin by simulating legitimate operations (layering). The complexity of multiple steps across different jurisdictions makes identifying the source of funds significantly more difficult.

As with Hare Capital Ltd. – Holding and all boutique companies within the conglomerate, SWIFT recognises that cooperation with national and international authorities is a fundamental pillar of its mission, reinforcing trust, transparency and resilience across the global financial system.

The rise of cryptocurrencies as means of exchange, stores of value and investment assets has introduced new dimensions to antimoney laundering (AML) efforts. Their decentralised nature, pseudonymity and rapid blockchainbased transactions create opportunities for financial innovation while simultaneously enabling more sophisticated illicit practices.

The growing adoption of cryptocurrencies and digital assets drives financial innovation but also expands the challenges associated with AML. Confidentiality, decentralisation and the ease of global transfer of cryptoassets create a new environment for combating financial crime, requiring a sophisticated and continuously updated legal and regulatory approach.

Money laundering is the process through which illicitly obtained funds (from drug trafficking, corruption, fraud, etc.) are “cleaned” and integrated into the legitimate financial system to conceal their criminal origin. With the advent of cryptocurrencies, criminals have found a new vector for this practice, driven by pseudonymity, decentralisation and the crossborder nature of transactions.

Although blockchain technology is transparent — with all transactions publicly recorded — identifying the individuals behind digital wallet addresses can be highly challenging. This pseudonymity, combined with the speed and low cost of international transfers, makes cryptoassets particularly attractive for those seeking to move large sums of money without raising suspicion.

The obligation to report to the competent authorities any transaction, or series of transactions, which by their nature, value, form or frequency present indicators of money laundering or terrorist financing is a fundamental legal requirement within financial crime prevention frameworks.

Entities in general — and exchange platforms in particular — must identify clients who, immediately after opening an account, make substantial deposits in multiple currencies and rapidly convert them into cryptocurrencies, transferring such assets to unknown external wallet addresses without any apparent economic purpose or legitimate legal justification.

For transactions of this nature, where no lawful economic rationale or regulatory justification exists, Hare Capital Ltd. – Holding will report the activity to the competent authorities, in full compliance with applicable national and international standards, reinforcing its institutional commitment to integrity, compliance and the prevention of illicit financial flows.