CEX.IO

• Maintain and update payment records in accordance with established schedules and internal policies. • Monitor payment timelines, ensuring all payments are processed accurately and on time. • Track and manage payment schedules, flagging discrepancies or delays for prompt resolution. • Coordinate with relevant departments to confirm payment approvals and authorizations. • Сommunication with banks regarding payments, obtaining confirmations from them for audit. • Сommunication with vendors regarding payments or replacement of invoices. • Maintain complete and accurate accounting records in compliance with financial standards and group procedures. • Perform regular control and verification of ending balances across accounts. • Identify and investigate any discrepancies in account balances, escalating issues as needed. • Support month-end and year-end closing activities related to payments and account balances. • Download and process Prime files within the Business Central (BC) system. • Maintain an organized archive of Prime files for audit and reporting purposes. • Conduct regular reconciliation of payment records, accounting entries, and system data. • Document reconciliation results and prepare exception reports for unresolved items. • Prepare subaccount files in accordance with established templates and requirements. • Verify the accuracy and completeness of subaccount data before submission or archiving.

• Act as the designated MLRO for the Spanish MiCA‑authorised entity, with full accountability for AML/CFT/PF compliance. • Serve as the primary point of contact with Spanish competent authorities (including AML and prudential supervisors) on all compliance & financial crime matters. • Ensure compliance with MiCAR AML‑related obligations applicable to CASPs, including governance, risk management, and internal control expectations and MiCAR reporting. • Prepare and submit all required AML‑related regulatory filings, suspicious activity reports, and periodic reports in accordance with Spanish law and SEPBLAC guidance. • Prepare and present the annual AML/CTF/PF report to the Board of Directors, including risk assessments, control effectiveness, incidents, and remediation plans. • Monitor regulatory developments under MiCAR, ESMA, and EBA’s guidance, AMLA guidance, and Spanish AML updates, ensuring timely implementation. • Advise senior management and the Board on Compliance & AML/CFT/PF risks, regulatory developments, and supervisory expectations. • Design, implement, and maintain a robust AML/CFT/PF framework. • Develop and maintain the enterprise‑wide and Spain‑specific AML/CFT/PF risk assessment, ensuring alignment with risk‑based requirements. • Ensure appropriate Compliance & AML/CFT/PF risk classification of the business, customers, products, delivery channels, and geographies. • Identify emerging financial crime risks related to crypto‑assets, DeFi exposure, cross‑border activity, and new product launches. • Oversee and advise on day‑to‑day Compliance & AML operations, including quality assurance of onboarding, alerts, investigations, and reporting. • Ensure timely and accurate filing of suspicious transaction/activity reports with CNMV/SEPBLAC in Spain. • Coordinate with group‑level compliance, risk, and product teams to ensure consistency while maintaining local regulatory ownership. • Draft, maintain, and continuously update AML/CFT/PF policies, procedures, and controls in line with MiCAR, Spanish AML law, and EU guidance. • Ensure policies are embedded operationally and reflect actual business practices. • Ensure AML/CTF/PF training is aligned and contains local-specific requirements, including tailored training for senior management and high‑risk functions. • Identify control gaps, weaknesses, or regulatory findings and design remediation plans. • Track remediation actions to completion and report progress to senior management and the Board. • Protect and enhance the reputation of CEX.IO Europe through a strong compliance culture and proactive regulatory engagement. • Provide regular updates to the Board of Directors regarding Compliance & AML/CFT/PF risks, regulatory developments, and supervisory expectations.

• Identify potential customers across crypto, FinTech, payments, wallets, exchanges, brokers, PSPs, custody, stablecoin, and Web3 infrastructure markets. • Search for prospects on LinkedIn, Reddit, X/Twitter, Telegram, Discord, industry directories, job posts, company websites, and other relevant platforms. • Start conversations with potential customers through LinkedIn and other channels. • Qualify leads based on company type, use case, infrastructure needs, timing, and potential fit. • Maintain a structured lead pipeline and update lead status regularly. • Prepare short outreach messages, follow-ups, and basic product explanations. • Collect market feedback, customer objections, competitor mentions, and common customer needs. • Work closely with Product and Account Management teams to hand over qualified leads. • Support early funnel activities before customer onboarding starts. • Prepare and publish relevant product, market, and infrastructure-focused LinkedIn content.

• Lead the implementation and maintenance of the ICT risk management framework to meet CNMV and ESMA standards • Supervise and control ICT services provided by CEX.IO Ltd (UK), including cloud infrastructure, software development, and security operations • Identify, assess, and mitigate technological risks • Act as the ultimate authority for initiating the Incident Response Plan (IRP) for high and critical levels • Supervise critical ICT third-party service providers • Oversee the security of crypto-asset custody solutions • Supervise the Secure Software Development Life Cycle and validate security testing in pre-production (UAT) environments before deployment • Approve and collaborate on operational resilience testing plans and specific tests regarding Distributed Ledger Technology (DLT) • Maintain a unified and centralized inventory of CEX.IO systems and infrastructure

• Define, drive, and execute the global information security roadmap aligned with business goals. • Build, implement, and optimize robust security processes, frameworks, and policies across the organization. • Oversee the successful acquisition and maintenance of industry-specific licenses and certifications (e.g., SOC 2, PCI-DSS, DORA, MiCA/crypto regulations). • Manage regular internal/external security audits and executive reporting. • Collaborate with external auditors, regulators, and legal teams to ensure compliance with data privacy laws and corporate governance standards. • Lead, mentor, and scale a high-performing, fully remote security team. • Act as the ultimate point of escalation for global security incidents, ensuring proactive threat hunting and rapid mitigation.

• Own the end-to-end creation and operation of a portfolio of niche crypto websites targeted at different regions. • Write prompts that generate sites in AI tools (Claude, Cursor, Lovable, v0, etc.), ship them to live domains, iterate on requested edits, and monitor performance across the fleet. • Write and refine prompts that produce production-ready niche crypto sites (landing pages, info portals, comparison sites, lead-gen funnels) tailored per region and language. • Manage the full publishing pipeline: domain registration (optional), DNS, hosting setup, FTP deployment, SSL etc.. • Apply ongoing edits and requests to existing sites — content updates, layout tweaks, copy changes, bug fixes. • Track performance across many sites in parallel (traffic, indexing, conversions, uptime) and propose scaling ideas: new keyword groups, new geos, new templates, automation opportunities.

• Provide independent oversight to the Executive Management team • Ensure operations maintain high standards of financial integrity and regulatory excellence • Help executive directors identify hidden problems or external factors impacting profitability • Ensure adherence to the Markets in Crypto-Assets Regulation (MiCAR) and local mandates • Advise on developing robust risk management and internal control systems • Participate in Board meetings and specialized committees

• Collaborate with the Board to define the company’s enterprise-wide risk appetite, covering operational, financial, cyber, and strategic risks. • Present and justify the Risk Management Framework to the Board Risk Committee for approval. • Advise the Board on conflicts of interest regarding qualifying shareholders and shared resources. • Provide regular risk reports to the Board Risk Committee, highlighting any key risk indicators (KRIs) and emerging trends in the crypto-asset sector. • Develop, implement, and maintain the comprehensive risk management framework and policies across the organisation. • Act as the primary point of contact for the Banco de España and/or CNMV and external auditors regarding risk management matters and compliance with industry standards.

• Maintain, operationalise, and continuously update the entity’s AML/ATF Policies and Procedures manual in strict accordance with the Proceeds of Crime Act 1997 (POCA) and the AML/ATF Regulations 2008. • Act as the sole designated officer to receive internal disclosures, evaluate them independently, and promptly file Suspicious Activity Reports (SARs) with the Financial Intelligence Agency (FIA) when required. • Oversee global sanctions screening operations (against UN, HM Treasury, and Bermuda-specific lists) and implement strict cross-border compliance protocols, specifically enforcing the FATF Travel Rule for virtual asset transfers. • Establish and manage automated transaction monitoring systems, pairing traditional fiat monitoring with advanced blockchain analytics tools (e.g., Chainalysis, Elliptic, TRM Labs) to detect unusual or high-risk wallet behaviours. • Design and execute risk-based institutional and retail onboarding flows, ensuring precise Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for politically exposed persons (PEPs) or higher-risk jurisdictions. • Act as the primary interface for all BMA prudential on-site visits, information requests, and regulatory filings. • Lead the preparation of data for the annual BMA AML/ATF returns. • Oversee and coordinate the mandatory independent annual AML/ATF audit conducted by qualified third parties, systematically addressing and remediating any identified gaps. • Conduct mandatory, regular AML/ATF and sanctions training for the Board of Directors, local executives, and operations staff, incorporating findings from Bermuda's National Risk Assessment (NRA).