Bello, Gallardo, Bonequi y García, S.C.

Incorporated in 2001, BGBG is currently a ninety-member Mexican law firm comprised of fourteen partners, forty-six associates, and several law clerks and paralegals, including the main office in Mexico City, as well as representative offices in Querétaro, Merida, and Madrid, Spain.

BGBG has an extensive practice, rendering legal services in the fintech, compliance, AML, anticorruption, finance, corporate, banking, securities, consumer rights, insurance, reinsurance, energy, infrastructure, intellectual property, privacy, real estate, telecommunications, and litigation practice areas. BGBG renders legal advice to domestic and international clients regarding complex transactions, including corporate and regulatory advice on the fintech, compliance, banking, finance, insurance, and anti-money laundering practice areas.

Several of our members are certified by the National Banking and Securities Commission as AML and Compliance experts.

BGBG strives to offer high-quality services with a different approach. The main goal of all the members of BGBG is to team up with its clients and assist them in accomplishing their goals.

Legal services provided by BGBG, include the authorization and registration of Fintech entities in Mexico, such as crowdfunding and wallets, as well as analysis and implementation of crypto assets structures applicable to commercial entities.

Representative clientes (Fintech): Mercado Libre, Satoshi Portal, Citibanamex, CoinMetro, Juntos Financiera, Ictineo, Interlinked, Nubank Tan-Tan, Agro Mich, Soluciones Moviles, Mexicrowd, Oro Verde -San Tadeo, Cori Capital, KLU, ALA Bool, Pagsmile, Nelo, Oplay, SuperDigital, Elektra, Uber, Cobee, Coda Payments, Mountx, Fairplay, Get Cometa, Conekta, Insurex, and Fintech Association Mexico.

a.Fintech regulatory framework: a summary of the most relevant laws and regulations concerning fintech and financial innovation.

In Mexico, over the past few years, we have seen the evolution of financial systems, mainly how transactions and their functions have changed or targeted specific sectors.

As a result, financial systems have adopted increasingly automated or digital transactions, securities, and systems to facilitate financial relationships between their subjects – whether users, clients, financial intermediaries, or government regulators.

Mexico has issued laws to regulate fintech entities. On 9 March 2018, the Law to Regulate Financial Technology Institutions (the Fintech Law) was published in the Official Federal Gazette. These institutions are legal entities authorised by the National Banking and Securities Commission (the "Commission") to carry out activities. The Fintech Law describes two types of financial technology institutions:

• collective financing institutions (crowdfunding), which carry out activities intended to connect the general public to provide financing through debt, capital, co-ownership, or royalty financing transactions, carried out through computer applications, interfaces, web pages, or through any

other means of electronic or digital communication; and

• electronic payment fund institutions providing services on a regular and professional basis, consisting of issuing, administration, redemption, and transmission of electronic payment funds (wallets).

b.Payment service providers and digital wallets: a summary of regulations applying to payment service providers and/or digital wallets.

In Mexico, companies that provide these services are those in charge of the issuance, management, and redemption of balances registered electronically, known as electronic payment institutions or digital wallets. These balances can be used to make payments or electronic transfers through interfaces, internet pages, or any other means of electronic or digital communication.

Digital wallets must maintain one or more accounts of electronic payment funds for each client, as well as make the transfers of said funds among their clients through the respective installments and charges in the corresponding accounts. Digital wallets may act as transmitters of money in accordance with the provisions of the General Law of Auxiliary Credit Organizations and Activities; may grant credit or loans in the form of an overdraft, subject to the conditions established in the Fintech Law; and may provide services related to payment instrument networks, issue securities on their account and transmit virtual assets on their account or on behalf of their clients.

It is important to mention that electronic payment institutions are prohibited from paying their clients interest or any other monetary benefit or profit for their accumulated balance. Likewise, an obligation is established so that the clients of these institutions designate beneficiaries, who will be given the corresponding funds in case of death.