Anti-Money Laundering Agreement

Introduction

This Agreement is jointly prepared and signed by the parties (the “Agreement Parties”) to enhance understanding of the virtual currency trading platform and implement effective Anti-Money Laundering (AML) supervision and enforcement across relevant participants.

1. Definitions

2. Goals and Principles

2.1 Objectives. The Agreement Parties cooperate to implement effective AML measures to ensure that transactions and funds on the platform comply with applicable laws and regulations and are not used for money laundering, terrorist financing, or other unlawful activities.

3. Customer Due Diligence (CDD)

• 3.1 Identity verification. Conduct strict KYC for registered users, including verification of legal name, ID documents, and contact information.
• 3.2 Risk assessment. Apply risk-based measures according to customer risk characteristics to align with the AML strategy.
• 3.3 Suspicious activity reporting. Establish mechanisms to detect and report suspicious activity and cooperate with competent regulators.

4. Transaction Monitoring

• 4.1 Monitoring system. Implement an effective system to monitor and analyze transactions in real time to detect unusual patterns.
• 4.2 Suspicious transaction reports. When suspicious transactions are identified, promptly submit STRs to relevant authorities and cooperate with investigations.

5. Internal Control

• 5.1 AML policies and procedures. Establish and maintain AML policies and procedures that meet applicable legal and regulatory requirements.
• 5.2 Internal audit and supervision. Set up internal oversight to assess AML measures regularly and take timely corrective actions when issues are found.

6. Training and Awareness

• 6.1 Training plan. Provide regular AML training covering laws, regulations, red flags, and suspicious transaction identification.
• 6.2 Awareness raising. Promote AML awareness and encourage employees to report suspicious activities via defined channels.

7. Compliance Audit

• 7.1 External audit. Engage independent third parties periodically to audit AML measures for compliance.
• 7.2 Internal audit. Maintain an internal audit function to perform routine reviews and implement corrective actions.

8. Information Sharing and Cooperation

• 8.1 Information sharing. Cooperate with regulators in lawful information sharing, including STRs and relevant account information.
• 8.2 Coordination. Maintain mechanisms for cooperation with competent authorities to combat money laundering, terrorist financing, and related offenses.

9. Entry into Force and Amendment

• 9.1 Effectiveness. This Agreement takes effect on the date of signing and applies to all subsequent transactions and activities of the parties.
• 9.2 Amendment. The Agreement may be amended to reflect legal or regulatory changes, with revised terms jointly negotiated and signed by the parties.

10. Dispute Resolution

• The interpretation and implementation of this Agreement are governed by applicable laws and regulations.
• Disputes should be resolved through friendly negotiation; failing which, they may be submitted to the competent judicial authority.