rules, conditions and procedures as specified in the notification of the Capital Market Supervisory Board by failed to implement an adequate system to ensure the accurate and complete management and

procedures as specified in the notification. In this regard, Bitazza insufficiently provided the system to ensure that Bitazza could know and verify the true identity of its customers, including acquiring

securities via his nominee's securities account but failed to prepare and disclose report on changing in his holding (Form 59-2) to the SEC Office within the period specified in the notification of the

COL securities via his nominee's securities account but failed to prepare and disclose report on changing in his holding (Form 59-2) to the SEC Office within the period specified in the

accurate information was in place to ensure the status of qualified customers as high net worth investors. SEC Act S.113 Settlement Committee Meeting No. 2/2025 Settlement Committee Order No. 20/2025

November 25, 2024, Bitazza failed to comply with the rules, conditions and procedures as specified in the notification. In this regard, Bitazza insufficiently provided the KYC/CDD system to ensure that

financial statements of the group of offerors for the CPT shareholders immediately after the submission of the tender offer to the Office of the Securities and Exchange Commission, and by failing to ensure

accurate information was in place to ensure the status of qualified customers as high net worth investors. On May 30, 2025, the Criminal Fining Committee issued special order no. 2/2025 imposing a fine on FL

to the Office of the Securities and Exchange Commission, and by failing to ensure that the group of offerors were made aware of their duties and responsibilities to deliver a complete Form 247-4 to the