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Anti-Money Laundering/Counter the Financing of Terrorism (AML/CFT) Policy

The Platform will verify and record the relevant information submitted by the Users in accordance with the User identification system under the Platform’s relevant regulations against money laundering. If the Platform has any doubt about the information submitted by any User, it has the right to ask the User to provide other documents or consult with relevant competent authorities or departments for verification.

Classification of User Risk Levels

The Platform classifies Users into three categories, i.e., low-risk Users, medium-risk Users and high-risk Users according to the materials submitted by the Users, and on the basis of such factors as the geographical location of the Users, the industries they are involved in, background of the shareholders of Users, if any, and whether Users are prominent public figures, inter alia. The Platform reserves the right to adjust the grading of Users.

Identification of High-risk Users

High-risk Users refers to Users who comprise any of the following high-risk factors and are identified as high-risk Users after a comprehensive evaluation by the Platform. High-risk Users include:

1. Users who have been subject to or are currently under criminal or administrative investigation, excluding Users who are investigated in connection with any civil proceeding or emergency dispute;
2. Users who are prominent public figures, or whose controlling shareholders, actual controllers and/or actual beneficiaries are prominent public figures;
3. Users who are from high-risk countries or regions, or their controlling shareholders, actual controllers and/or actual beneficiaries are from high-risk countries or regions;
4. Users who are identified as key suspicious Users according to relevant procedures of the Platform;
5. Users who are engaged in business operations in industries subject to a relatively high level of money laundering risks, such as jewelry, precious metals trading, currency exchange, pawn brokerage, money remission, nightclubs and the arms industry, etc;
6. Users who engage in intensive trading within a certain period of time, which is seriously inconsistent with the situation on the digital assets markets; and
7. Users who engage in unusual operations.

Identification of Low-risk Users

Low-risk Users refers to those Users who are identified as low-risk Users after a comprehensive evaluation by the Platform. Low-risk factors include:

1. Users that are financial institutions or well-known companies;
2. Users who are natural person and of whom the Platform has proper understanding through verification and who carry a relatively low risk of money laundering;
3. Users who are reviewed and approved by the Platform’s risk control and compliance departments.

Identification of Medium-risk Users

Medium-risk Users refers to Users that are not in any of above groups.

Monitoring of High-risk Users

For Users in the high-risk category, the Platform will conduct a review every six months to update the basic information on the Users' identity and ascertain their sources of funding, use of funds, financial standing or business status. If the Platform, on the basis of a comprehensive assessment during the regular review of a high-risk User, deems that the User and the transactions in the User’s account with the Platform are normal, it may lower the risk level of such User.

Handling of Suspicious Conduct

When the Platform identifies the identity of an User, it shall have the right to adopt measures such as suspending any suspicious transaction, rejecting transaction applications, reversing transactions, freezing suspicious accounts, and reporting to the competent authorities in illegal activities.