Purpose

The purpose of this policy is to ensure that CoinEx (hereinafter referred to as “The platform”) complies with Anti-Money Laundering (AML) and Know Your Customer (KYC) policies and procedures, and to prevent any illegal activities. According to our policy, the platform is unable to provide trading services to users from China, the United States, and the province of Alberta, Canada. The platform adheres to relevant laws, regulations, and regulatory requirements to ensure the compliance of our business. This policy is for general information purposes only and is not legally binding on CoinEx and/or any other individuals (natural or otherwise).

1. Customer Due Diligence (CDD) Methods

1.1 Identity Verification

 - The platform encourages customers to provide valid identification documents such as passports, identity cards, or driver's licenses to ensure the legitimacy and compliance of transactions.

 - Methods for verifying customer identity include comparing original documents, using identity verification service providers, or verifying through other acceptable channels.

1.2 Purpose and Business Relationship Assessment

- Assessing the customer's business purpose, expected business relationship, and required services to ensure compliance with regulatory requirements. The platform requires clients to complete the identity verification process before participating in certain products or services.

- Collecting and analyzing the customer's business plans, financial status, and relevant information.

1.3 Due Diligence

 - Customer's Personal Information:

• Full Name: The platform requires the customer's full name, including any aliases or pseudonyms.
• Unique Identification Number: The customer's unique identification number, such as ID card number, birth certificate number, or passport number. This helps verify the customer's identity and establish their uniqueness.

 - Customer's Organizational Information (if applicable):

• Registered Address or Business Address: If the customer is a legal entity, the platform requires their registered address or business address. If the registered address and business address are different, the platform considers the primary place of business as a reference.
• Date of Establishment / Registration: Determining the customer organization's date of establishment and registration helps confirm its legal status and operational history.
• Legal Form, Articles, and Powers: Understanding the legal form, articles, norms, and powers that govern the customer organization helps understand its organizational structure and operational mode.

 - Information about Related Parties (if applicable):

• Same Identification Information for Related Parties: If the customer is a legal entity, the platform requires the same identification information to identify its related parties, such as directors, partners, and persons with executive authority.
• Full Name: The platform requires the full name of individuals involved in related parties.
• Unique Identification Number: For identification purposes regarding related parties, the platform requires their unique identification number, such as ID card number, birth certificate number, or passport number.

1.4 High-Risk Customer Assessment

 - Conduct additional due diligence on customers considered to have a high risk, such as politically exposed persons (PEPs), businesses in high-risk industries, high-risk transactions and customers from high-risk countries.

 - Implement stricter reviews, monitoring and potential account restrictions, including regular assessments of their risk level and business activities.

1.5 Monitoring and Updates

 - Establish mechanisms for ongoing monitoring, periodic review, and updating of customer information.

 - Monitor customer transaction activities, fund sources, and risk behaviors to ensure the accuracy and timeliness of customer information.

2. Risk Assessment and Mitigation Measures

2.1 Risk Assessment

The platform conducts a customer risk assessment to evaluate the level of identity fraud risk, money laundering risk, and terrorism financing risk based on factors such as the nature of the customer's business, geographic location, customer type, and transaction patterns. Customers are categorized as low risk, medium risk, or high risk, and corresponding monitoring measures are determined based on their risk levels.

2.2 Risk Mitigation Measures

 - Anti-Money Laundering software (AML software): The platform employs advanced AML software to automatically detect and monitor suspicious transactions and activities. These software systems analyze transactions based on pre-set rules and models to identify potential money laundering behaviors and risk indicators.

 - Transaction monitoring system: The platform establishes a transaction monitoring system to monitor transaction activities and detect any suspicious patterns or abnormal transactions. This helps identify potential money laundering activities promptly and allows necessary actions to be taken.

 - Identity verification service providers: The platform collaborates with reliable identity verification service providers to ensure the authenticity and validity of the identity documents provided by customers. This ensures that the customer's identity is legitimate and trustworthy.

3. Identification of Suspicious Transactions and Follow-up Measures

To ensure the compliance of our business operations, prevent money laundering, terrorism financing, and other illicit activities, the platform is committed to identifying and following up on unusual transactions. The following are the measures:

3.1 Monitoring transaction activities

The platform employ advanced transaction monitoring systems and risk assessment tools to monitor customer transaction activities and closely observe the following:

 - High-value transactions: Transactions involving unusually large amounts may raise our attention.

 - High-frequency transactions: Excessively frequent transactions may also be considered suspicious behavior.

 - Unusual transaction patterns: Transaction patterns that deviate from the customer's regular behavior may be regarded as suspicious.

 - High-risk transactions: Transaction that was identified to be exposed to illicit activities on the blockchain.

3.2 Automated alerts and risk analysis

Our system generates automated alerts, identifying transactions that may pose risks. The platform conducts risk analysis on these alerts to assess their legitimacy and compliance. If the alerts indicate potential signs of illegal activities, the platform conducts further investigation and follow-up.

3.3 Manual review

Our professional team conducts manual reviews of the alerts to ensure accuracy and timeliness. When necessary, the platform may engage in further communication with the customer, requesting additional documents or explanations regarding the purpose and source of the transactions.

3.4 Compliance reporting

If the platform determines that a transaction exhibits signs of suspicious activity, compliance reports will be filed in accordance with applicable laws and regulations. Compliance reporting may involve submitting Suspicious Transaction Reports (STR) or Suspicious Activity Reports (SAR) to the relevant authorities.

4. User Data Storage System

The platform has established a user identity information and transaction record storage system to securely store documents and data related to user identity information and transaction records. This system facilitates anti-money laundering investigations, regulatory compliance, and prevents the loss, damage, or disclosure of information.

5. Retention Period of User Identity Information and Transaction Records

The platform complies with applicable legal and regulatory requirements to determine the retention period for customer data. The retention period may vary based on the region and business requirements and may involve certain time limitations. If a user's identity information and transaction records are involved in any suspicious activities under an ongoing anti-money laundering investigation and the minimum storage period specified in the previous section has not elapsed, the platform retains this information until the completion of the money laundering investigation.

6. Assistance in Judicial Investigations

If requested by national, regional judicial institutions, law enforcement agencies, or other regulatory authorities, the platform has the right to cooperate with the investigation and provide relevant information and materials as requested by the respective agency or institution.

7. Confidentiality in Anti-Money Laundering

Any of our staff members, when performing duties or work related to anti-money laundering, must strictly adhere to confidentiality requirements and keep confidential all user identity information, suspicious transactions, terrorism financing transactions, and any other acquired information. Such staff members are prohibited from disclosing such information to any organization, individual, or unrelated personnel of the platform.

8. User Responsibilities

Users should be aware of the following:

(1) Users are prohibited from lending their account details to anyone else.

(2) Users are prohibited from renting or lending their identification documents.

(3) Users are prohibited from renting, lending, or disclosing important personal asset information, such as account details and passwords.

(4) Users should actively cooperate with the platform for user identity verification.

9. Interpretation of AML / KYC Policy

The platform reserves the right to interpret and modify the content of the AML / KYC policy. Depending on the platform's needs and legal requirements, the platform may modify the AML / KYC policy at any time without prior notice to users. These modifications may involve user identity verification requirements, data retention periods, compliance processes, or any other relevant matters. Users should regularly review the latest version of the AML / KYC policy published by the platform to ensure compliance with the latest requirements and regulations.