# Anti-money-laundering and anti-terrorist financing policies

Introduction

This Anti-Money Laundering and Anti-Terrorist Financing Policy (hereinafter referred to as “the Policy”) should read as follows:

User Protocol

Privacy statements

Risk tip

Read together.

Unless otherwise defined in this policy, the terms used in this document should be consistent with those defined in the above-mentioned document.

This policy is intended to provide a general description and does not constitute a legal constraint on any individual or entity.

II. Policy objectives

EXBIT  is committed to establishing a compliance system that is consistent with applicable laws and regulations and industry best practices.

The Platform maintains a zero-tolerance policy\*\* for:

Money-laundering

Financing of terrorism

Transactions of sanctioned entities

High-risk illicit funds activities

These acts may:

Platform security

User rights

Global financial system

This has serious implications.

EXBIT does business globally and in accordance with international standards, including:

&#x20;FATF recommendations

If the legal and regulatory requirements of the user ' s location are stricter, local law prevails.

&#x20;Core principles

(a) Risk-based multilevel approach

EXBIT .

i. Customer Due Diligence (CDD)

Identification and background assessment of all clients.

ii. Strengthening due diligence (EDD)

Additional review of high-risk clients.

iii. Ongoing monitoring

Continuous monitoring of clients and transactions.

(b) High ethical standards

EX upholds high standards of business ethics and avoids creating anything that might involve:

Money-laundering

Business relations in terrorist financing.

(c) Regulatory cooperation

To the extent permitted by law, EXBIT  will cooperate with the investigative and regulatory requirements of regulatory and enforcement agencies.

1\. Risk-based approach

EX Conducts ongoing risk assessments to identify potential risks and update internal control mechanisms.

The scope of the risk evaluation includes:

Client type

Products and services

Geographical location

&#x20;Main measures

Risk identification: analysis of customer identity, transaction behaviour and area risk

Risk classification: classified as low, medium and high

Ongoing assessment: adjusted to changing business and regulatory dynamics

2\. Customer Due Diligence (CDD)

EXBIT Pertify all customers and do not accept:

Anonymous accounts

False identity accounts

If it is discovered that the customer's funds may be involved in illegal activities, téRM 0  will:

Refusal to establish a relationship

Submission of Suspicious Transaction Reports (STR)

Reporting to relevant bodies

CDD startup scenario

When establishing a business relationship

When trading takes place

When receiving transfer of assets

In case of suspicious acts

When information is in doubt

&#x20;Client information collection

Natural persons:

Name

Date of birth

Home address

Nationality

Contact information

Legal entities:

Company name

Registration Information

Directors and management information

Actual beneficiaries (UBO)

Nature of operations and source of funds

Authentication file

This includes, but is not limited to:

Passport/ ID card

Address certificate

Company registration documents

Digital authentication technology

Bioidentification

Document authenticity testing

3\. Strengthening due diligence (EDD)

Applicable to high-risk clients, including:

Political public figures (PEP)

Users in high-risk areas

Complex corporate structures

Unusual trading behaviour

EXBIT  will take:

Depth information verification

Continuous monitoring

Risk assessment

4\. Ongoing monitoring

EXBIT  continuously monitors transactions, including:

Unusual mode

High transactions

Frequent transactions

Cross-border transactions

Adopt:

Automatic monitoring system

Manual clearance

5\. Sanctions screening

EXBIT  Screening based on international sanctions lists, including:

United Nations

EU

UK (HMT)

Singapore (MAS)

Australia (DFAT)

Limited area (example)

Korea, Iran, Syria, Cuba

Sanctions-related accounts will:

Suspension of transactions

Assets freeze

Report to the police.

VIII. Travel rules

EXBIT Compliance with FATF Recommendation 16:

The collection of information includes:

Sender Information

Receiver Information

Amount and time of transaction

Data saved for at least 5 years

Transaction reports

EXBIT    will fulfil its regulatory reporting obligations, including:

Suspicious activity reports (SAR)

Record-keeping

Records kept for not less than 5 years

6\. Staff training

EXBIT  regularly conducts AML/CTF training, including:

Risk identification

Reporting process

Compliance,

Audit and evaluation

Review at least once a year

Update policy in response to regulatory changes

Virtual asset risk assessment

EX will assess:

Anonymous

Compliance

Historical risks

High-risk assets may:

Delay going online

Deny access

Regulatory cooperation

EXBIT  will cooperate with:

Audit

Investigations

Information request

Policy updates

The policy will be updated regularly to comply with:

Legal requirements

Industry standards

User security responsibilities

User needs:

Protect Account Information

Timely reporting anomalies

7\. Language description

If there is a discrepancy in the multilingual version: based on the English version

Contact us.

If you have any questions, please contact:

Client service support

Data protection mailbox (recommended to use enterprise mailbox)


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