- 1.1 We ensure that we comply with know-your-customer and anti-money-laundering laws and regulations, and will not knowingly violate know-your-customers and anti-money-laundering policies. To the extent of our reasonable control, we will adopt necessary measures and technology to provide you with Services that are safe and secure, so as to protect you against the loss caused by money laundering to the greatest extent possible.
- 1.2 Our know-your-customer and anti-money-laundering policies are a comprehensive system of international policies, including the know-your-customer and anti-money-laundering policies of the jurisdictions to which you are subject to. Our robust compliance framework ensures that we meet regulatory requirements and regulatory standards on both the local and global levels, and ensure the operational sustainability of our app.
2. Content of Our Know-Your-Customer and Anti-Money-Laundering
- 2.1 We promulgate and update know-your-customers (KYC) and anti-money-laundering (AML) policies to meet the standards set by relevant laws and regulations;
- 2.2 We promulgate and update some of the guidelines and rules in connection with the operation of this app, and our staff will provide you whole-process service in accordance with the guidelines and rules;
- 2.3 We design and complete the procedures for internal monitoring and transaction control, such as rigorous identity authentication procedures, and form a professional team responsible for anti-money laundering;
- 2.4 We adopt risk-prevention-based approach to carry out due diligence and continuous supervision in connection with customers;
- 2.5 Review and regularly inspect existing transactions;
- 2.6 To report suspicious transactions to the competent authorities;
- 2.7 Proof documents of identity documents, address certificates and transaction records will be maintained for at least six years; if they are submitted to the regulatory authorities, let it be understood that a separate notice will not be provided to you;
- 2.8 Credit cards are prohibited throughout the course of the transaction;
- 2.9. If you are from any of the high-risk and non-cooperative jurisdictions listed on the app of Financial Action Task Force (FATF) of the United States, you will not be allowed to register as a member of this app or use any service offered by this app;
- 2.10 Regularly participate in the trainings organized by the relevant authorities and provide regular trainings to the staff.
3. Identity Information and the Verification and Confirmation Thereof
- 3.1 Identity Information
- 3.1.1 In accordance with the laws and regulations of relevant jurisdictions and in light of the nature of entities concerned, the content of your information as is collected by us may vary, and in principle, we will collect the following information of yours if you register as an individual: Basic personal information: your name, address (and permanent address, if the two are different), date of birth and nationality, and other information available. Identity authentication shall be based on documents issued by the official or other similar authorities, such as passports, identity cards or other identity documents as are required and issued by relevant jurisdictions. The address you provide will be validated in an appropriate manner, such as checking the fare ticket of means of transportation you use, your interest rate bills, or voter register. Contact information: Mobile phone number and valid email address. We may request you to provide further information under circumstances to meet our KYC and AML obligations under relevant laws and regulations.
- 3.1.2 If you are a company or any other type of legal entity, we will collect the following information of yours to determine the final beneficiary of your account or your trust account. Your corporation enrollment and registration certificates of the company; a copy of the articles of association and memorandum of the company; the detailed certification materials of the ownership structure and ownership description of the company, and the decision of the board of directors on designating the authorized agent of the company responsible for the opening and execution of the account of the company with the app; the identity documents of the directors, major shareholders of the company as well as the authorized signatory for the company’s account with the app, as are required to be provided in accordance with relevant rules; the company's main business address, and the company's mailing address if it is different from the main business address of the company. If the local address of the company is different from its main business address, the company shall be deemed to be a high-risk customer, and consequently the company will be required to provide additional documentation. Other certification documents, documents issued by competent authorities and other documents we may deem necessary in light of the laws and regulations of relevant jurisdictions and in light of the specific nature of your entity. We may request you to provide further information under circumstances to meet our KYC and AML obligations under relevant laws and regulations.
- 3.1.3 We only accept English versions of your identity information; if your identity information is not in English language, you shall have your identity information translated into English and duly notarized.
- 3.2 Confirmation and Verification
- 3.2.1 You are required to provide both the front and back sides of your identity documents.
- 3.2.2 Copies of certification documents shall be checked against the originals thereof. Nonetheless, if a trusted and suitable certifier person can prove that such copies are accurate and comprehensive duplicates of the originals thereof, such copies shall be deemed as acceptable. Such certifiers include ambassadors, members of the judiciary, magistrates, etc.
- 3.2.3 The identification the ultimate beneficiary and controller of the account shall be based on the determination of which individuals ultimately own or control the direct customer and/or to determining that the ongoing transaction is performed by another person. If you are a business enterprise, the identity of major shareholders thereof (for example, those holding 10 % or more of the voting equity in such business enterprise) shall be verified. Generally, a shareholder holding 25 % of the shares of the company will be deemed as involving an average level of risk, and the identity of the shareholder shall be verified; a shareholder holding 10 % or more of the voting rights or shares is deemed to be involving a high level of risk, and the identity of the shareholder shall be verified.
4. Transaction Supervision
- 4.1 We constantly set and adjust daily trading and cash withdrawal limits based on security requirement and actual state of transactions;
- 4.2 If the transaction occurs frequently in an account registered by you or is beyond reasonable circumstances, our professional team will assess and determine whether such transaction is suspicious;
- 4.3 If we identify a specific transaction as suspicious on the basis of our assessment, we may adopt such restrictive measures as suspending the transaction or denying the transaction, and if it is possible, we may even reverse the transaction as soon as possible, and report to the competent authorities, without, however, notifying you;
- 4.4 We reserve the right to reject registration applications by applicants that do not comply with the international standards against money laundering or who may be regarded as political and public figures; we reserve the right to suspend or terminate a transaction identified as suspicious based on our own assessment, which, however, does not breach any of our obligations and duties to you.
Our AML Program
We have designed our Program to reasonably prevent money laundering and terrorist financing through a risk-based, multi-layer control system.
The first layer includes a stringent customer identification program, including verifying the identity of our customers, whether individuals or entities. In addition to obtaining identification documents, we obtain for non-natural persons their entities beneficial owners/natural persons consistent to international standards such as the Financial Action Task Force (FATF).
The second layer includes a risk-based system to warrant additional customer due diligence. To accomplish this, we screen our customers (including beneficial owners) against the entities/persons on The Government of Singapore, and the Singapore Security Council Sanctions List, among other government-provided lists of sanctioned individuals and entities. We also may screen against other lists on a discretionary basis to protect our reputation and customers.
The third layer includes ongoing monitoring for suspicious activity. If our Program suspects or has reason to suspect suspicious activities have occurred, we will file suspicious activities reports with local regulators. A suspicious transaction is often inconsistent with a customer’s known and legitimate business, or personal activities.
These are the primary components of our compliance program; however, the most important glue or connections to these layers are our leadership team and staff, including AML/Risk personnel that execute training, oversight and a sound compliance culture.
Trading in digital assets is considered high risk. Digital assets are NOT backed by any government or central bank. The risk of loss in trading or holding digital assets can be substantial. You should carefully consider whether interacting, holding, or trading digital assets is suitable for you in light of your financial condition.
If you have questions or require assistance with our customer due diligence controls, please reach out to our 24/7 customer service representatives by email at email@example.com