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

Purposes and Basis

XchangeOn acknowledges that money laundering undermines the growth of digital asset trading, fosters corruption, erodes social integrity, and infringes on the legitimate rights of users. Therefore, XchangeOn has formulated these Rules to prevent money laundering and terrorist financing, in full compliance with relevant regulations. These rules are based on the User Agreement of the XchangeOn Website, the User Agreement of the XchangeOn APP, and other relevant documentation.

Scope of Application:

These Rules apply to all users trading on the XchangeOn website and the XchangeOn APP ("the Platform"). Users are required to adhere to anti-money laundering and anti-terrorist financing laws and regulations in their respective countries or regions. In cases where the user's location imposes stricter requirements, those will prevail.

Fight Against Money Laundering and Terrorist Financing:

XchangeOn's efforts to prevent money laundering include measures against narcotics-related crimes, organized crimes, terrorism, smuggling, graft, bribery, financial fraud, and breaches of financial regulations.

The Platform's Rules and Regulations against Money Laundering:

Rules against money laundering include these Rules, sections in the User Agreement of the XchangeOn Website and the User Agreement of the XchangeOn APP, Measures for the Management of Large-sum Transactions, and the OTC Platform Guidelines for Users against Money Laundering and Terrorist Financing.

Basic Principles of the Platform against Money Laundering:

The Platform monitors user risks based on principles of comprehensiveness, prudence, sustainability, confidentiality, and hierarchical management.

Responsible Organ:

The Platform manages anti-money laundering operations through a guidance group and a team for advancing the fight against money laundering, consisting of members from the risk control and compliance departments.

Functions of the Responsible Organ:

The guidance group plans, guides, and coordinates money laundering affairs, while the team implements policies and plans, analyzes suspicious transactions, assesses user risk levels, and reports to competent authorities.

Due Diligence:

The Platform conducts due diligence on all users, with enhanced due diligence for high-risk users.

Documents Submitted by Individual Users:

Individual users must provide personal information, including name, address, date of birth, nationality, contact information, a recent photo, and identity documents.

Documents Submitted by Institutional Users:

Institutional users must provide information such as the institution's name, address, contact information, articles of association, equity structure, legal representative's information, business license, and consent to open an account.

Languages of the Submitted Documents:

The Platform accepts documents in Chinese or English. Documents in other languages must be translated by a qualified translator and notarized.

Submission of Document Copies:

Copies of documents must be properly checked against the original, notarized, and certified as true copies.

Photograph-based Verification:

Users must provide a photograph showing themselves holding their identity document and a statement confirming their account opening with XchangeOn.

Identification of the Beneficiary and the Controller:

The Platform identifies the actual or beneficial owner or controller of user accounts.

Identity Authentication by an Entrusted Third Party:

If a third-party institution authenticates a user's identity, it must meet certain requirements, including measures for user identification and data storage.

Review of User Documents:

The Platform diligently verifies user information submitted during registration and transaction activities. This process involves carefully examining documents provided by users, such as identification cards, passports, and utility bills. If additional documentation or clarification is required, users are promptly notified to ensure compliance with anti-money laundering (AML) and counter the financing of terrorism (CFT) regulations.

Classification of User Risk Levels:

To effectively manage risk, users are categorized into different risk levels based on their transaction behavior, geographical location, and other relevant factors. This classification helps the Platform apply appropriate measures to mitigate potential risks associated with money laundering and terrorist financing activities.

Identification of High-risk Users:

High-risk users are identified based on specific criteria, including being under criminal investigation, holding prominent public positions, residing in high-risk jurisdictions, operating in high-risk industries, or exhibiting unusual transaction patterns. These users require enhanced due diligence measures to ensure compliance with AML/CFT regulations.

Identification of Low-risk Users:

Low-risk users are typically entities such as established financial institutions, reputable companies, and individuals with a demonstrated history of compliant behavior. These users are subject to standard due diligence procedures but are considered to pose a lower risk of involvement in money laundering or terrorist financing activities.

Identification of Medium-risk Users:

Medium-risk users fall between low-risk and high-risk categories. They may not exhibit the same level of risk factors as high-risk users but may still require additional scrutiny due to certain characteristics or transaction patterns.

Adjustment of Risk Level Grading:

User risk levels are regularly reviewed and adjusted based on changes in user behavior or circumstances. This dynamic approach ensures that risk management measures are responsive to evolving threats and regulatory requirements.

Monitoring of High-risk Users:

High-risk users undergo continuous monitoring to detect and prevent potential illicit activities. This proactive approach enables the Platform to identify suspicious behavior and take appropriate action to mitigate associated risks.

Continuous User Identification:

To maintain the integrity of its user base, the Platform conducts ongoing user identity verification. This process helps ensure that users are who they claim to be and that their activities comply with AML/CFT regulations.

Re-identification of Users:

Users may be required to undergo re-identification under certain circumstances, such as changes in personal information or suspected involvement in illicit activities. This measure helps the Platform maintain a secure and compliant environment for all users.

Trading Limits:

The Platform sets trading limits, including maximum withdrawal amounts, to prevent money laundering and terrorist financing activities. These limits are based on security and operational considerations, ensuring the safety and integrity of the Platform's services.

Identification of Suspicious Transactions:

The Platform actively monitors transactions for signs of suspicious activity, such as large or frequent transactions, unusual transaction patterns, or transactions involving high-risk jurisdictions. Any suspicious transactions are promptly investigated and reported as required by law.

Identification of Terrorist Financing:

The Platform implements robust measures to detect and prevent transactions related to terrorist financing. This includes monitoring transactions for indicators of terrorist financing and reporting any suspicious activities to relevant authorities.

Handling of Suspicious Conduct:

In cases where users refuse to provide valid information or engage in suspicious behavior, the Platform may suspend transactions, freeze accounts, or report such conduct to authorities. These measures are essential for maintaining the integrity of the Platform and preventing illicit activities.

User Data Storage System:

The Platform maintains a secure system for storing user identity information and transaction records. This system ensures the confidentiality and integrity of user data, complying with relevant regulatory requirements.

Scope of the Storage of User Data and Transaction Records:

User identity information and transaction records are stored securely by the Platform. This includes information such as user profiles, transaction histories, and other data relevant to AML/CFT compliance.

Term for the Storage of User Identity Information and Transaction Records:

User identity information and transaction records are retained by the Platform for a minimum period of five years. This ensures that records are available for audit and regulatory purposes as required by law.

Assistance to Judicial Investigation:

The Platform cooperates fully with judicial, law enforcement, and competent authorities, providing information and materials for investigations upon request. This cooperation is essential for combating money laundering and terrorist financing activities effectively.

Confidentiality in Anti-money Laundering:

All staff members are required to adhere strictly to confidentiality requirements regarding user identity information, suspicious transactions, and other related information. This ensures that sensitive information is protected and used only for legitimate purposes.

Cautions to the Users:

Users are reminded not to share their accounts, identity certificates, or personal information with others. They are also encouraged to cooperate fully with the Platform in user identification processes to ensure compliance with AML/CFT regulations.

Reports of Suspicious Conducts:

Users are encouraged to report any suspicious activities they encounter during trading. This helps the Platform maintain a secure environment and prevent illicit activities.


These Rules are interpreted and enforced by the Platform to ensure compliance with AML/CFT regulations and maintain the integrity of its services.

Effective Date:

These Rules are effective immediately upon promulgation, ensuring that all users are subject to the same standards and requirements for AML/CFT compliance.