AML/CFT Policy

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

Article 1 Purposes and Basis. In view of the fact that money laundering will undermine the development of digital asset trading, facilitate and breed corruption, pollute social morality, damage the legitimate rights and interests of users, destroy the foundation for the sound operation of digital assets trading Platforms, increase the legal and operational risks of digital assets trading Platforms, Solus formulates these Rules in accordance with the User Agreement of the Solus Website, the users Agreement of Solus APP and other relevant documentation, so as to prevent money laundering and terrorist financing and fully comply with relevant regulations against money laundering and terrorist financing. By the very nature of its businesses, Solus will have a portfolio of clients across the globe. This international presence may trigger queries or requests for information from other law enforcement authorities. Solus shall therefore abide by the different laws and legal requirements imposed by the authorities in Seychelles.

These rules outline the procedures to be followed in order to prevent money laundering, terrorist financing and corruption. Solus does not wish to be manipulated by money launderers or terrorists or to become associated with money laundering or terrorism in general. Its aim is not merely to comply with its legal obligations, but to effectively minimize the risk of exploitation by criminals. Thus, the anti-money laundering, terrorist financing and corruption policies are based on the requisite highest standards.

Article 2 Scope of Application. These Rules shall apply to all users trading on the website of Solus and the APP thereof (hereinafter referred to as "the Platform"). The users shall implement the provisions of these Rules in accordance with the anti-money laundering and anti-terrorist financing laws and regulations of the country or region where they are located and within the scope prescribed by the laws and regulations of the region or country where they are located. Where there are stricter requirements in the country or region where the users are located, such requirements shall prevail.

These rules are governed by and shall be construed in accordance with the laws of Seychelles.

Article 3 Fight Against Money Laundering and Terrorist Financing. This refers to activities with respect to which measures have been adopted pursuant to relevant laws, relevant rules and regulations, for the purpose of preventing money laundering activities that are carried out by o enders through the Platform for the purpose of covering up and concealing the source and nature of the proceeds and profits that such offenders obtain through such crimes as those relating to narcotics, organized crimes, terrorism, smuggling, graft, bribery, financial fraud, breach of financial regulation and order, inter alia.

Article 5 Basic Principles of the Platform against Money Laundering.

The Platform monitors users risks according to the following principles:

  1. The principle of comprehensiveness. The Platform will take into account all kinds of risk factors on the basis of which users may be suspected of money laundering, and monitor risks of all users in an appropriate manner.

  2. The principle of prudence. On the basis of fully understanding the users, the Platform will improve its ability to authenticate users identities, and monitor users risks in a prudent way.

  3. The principle of sustainability. The Platform will pay appropriate attention to users risks and respond to risks on the basis of actual and specific circumstances of each risk.

  4. The principle of confidentiality. users identity information, transaction information and risk level held by the Platform shall be kept strictly confidential and shall not be provided to any entity or individual unless it is required by law or regulatory authorities.

  5. The principle of hierarchical management. The Platform will regularly review the basic information of the users according to the risk level of each user. And the review of users with a higher risk level shall be stricter than that of users with a lower risk level.

Article 6 Responsible Organ. The Platform carries out operations against money laundering via a guidance group for money laundering a airs and a team for advancing the fight against money laundering, each of which shall consist of members from the Platform’s risk control and compliance Adertpicalretm7 eFnutnsc. tions of the Responsible Organ. The guidance group for money laundering affairs is responsible for planning, guiding and coordinating the money laundering a airs of the Platform. Its specific responsibilities include the following:

  1. to review and approve the Platform’s money laundering policies, work plans and work reports;

  2. to promulgate and update the guiding principles and rules of the Platform against money laundering;

  3. to review the Platform’s and its sub-websites’ organizational structure and designation of responsibilities against money laundering;

  4. to design and complete procedures for internal inspection and control of transactions;

  5. to study major and di cult problems relating to money laundering and to form solutions.

The sta ng structure of the team for advancing the fight against money laundering shall be determined on the basis of regulatory requirements and location-specific conditions. The main r(1e)stpoinmspibleilimti esnthrelrevoafnint crluldese: against money laundering and plans of the guidance group for money laundering a airs;

(2) to implement various assignments;

(3) to analyze and identify the identity and background of any users with a suspicious transaction as well as each such suspicious transaction;

(4) to assess and adjust the risk level of users;

(5) to conduct due diligence and continuous supervision of users;

(6) to review and regularly examine transactions that have occurred;

(7) to report suspicious transactions to the competent authorities;

(8) to assist in the investigation at the request of any competent authority.

UsersArticle 8 Due Diligence. Following the principles of diligence and understanding your users, the Platform conducts due diligence on all users. For high-risk users, the Platform has the right to conduct enhanced due diligence.

Article 9 Documents Submitted by Individual Users.

As is required by the laws and regulations of different jurisdictions, the information that the Platform collects on individual Users from different countries or regions may vary. In principle, an individual User is required to provide the following information and data in accordance with relevant regulations of the Platform against money laundering:

  1. personal name;

  2. home address;

  3. date of birth;

  4. nationality;

  5. telephone number;

  6. e-mail address;

  7. a photo of the User taken within the six months from the date of registration with the Platform;

  8. photocopy of a valid Identity Card or a valid passport of the User; and

  9. other information or documents requested by the Platform.

Article 10 Documents Submitted by Institutional Users. As is required by the laws and regulations of different jurisdictions, the information that the Platform collects on institutional Users from different countries or regions may vary. In principle, an institutional User shall submit the following information and data in accordance with the Platform’s relevant regulations against money laundering:

  1. name of the institution;

  2. registered o ce address of the institution;

  3. contact information of the institution;

  4. articles of association of the institution;

  5. description of the equity structure and ownership of the institution;

  6. legal representative of the institution;

  7. place of residence of the legal representative of the institution;

  8. contact information of the legal representative of the institution;

  9. the institution's business license;

  10. the institution’s consent to open an account with this Platform;

  11. letter of authorization by the institution;

  12. a copy of the valid Identity Card or a valid passport of the legal representative of the institution; and

  13. other information or documents to be provided upon request by the Platform.

Article 11 Languages of the Submitted Documents. The Platform only accepts documents prepared in Chinese or English. Users who submit documents prepared in any language other than Chinese or English shall engage a properly qualified translator to translate such documents into Chinese or English and have the translated version thereof properly notarized.

Article 12 Submission of Document Copies. Where a copy of a document is submitted, the copy shall be properly checked against the original of such document. A copy of a document may be submitted if the copy has been notarized and certified as a true and accurate copy of the original document. The certification mentioned under this Clause includes, but is not limited to, certification by an embassy, judicial certification, certification by local magistrate, or certification by a notary public.

Article 13 Photograph-based Verification. Users shall complete a photograph-based verification procedure as required by the Platform: the User shall have a photograph of himself/herself taken, which shows the User holding his/her identity document and a statement that the User opens his/her account with the Platform according to his/her free will. If the photograph of the User is not clear enough or fails to conform with the requirements of the Platform, the Platform shall have the right to refuse to reject the User’s registration.

Article 14 Identification of the Beneficiary and the Controller. The Platform has the right to identify the actual or beneficial owner or controller of the account of a User. In the case of registration of an institutional User, the shareholder(s) holding more than 10% of the shares of the institution shall provide relevant materials and undergo identity verification according to the requirements of the Platform.

Article 15

Risk Assessment Identification of High-risk users. High-risk users refers to users who comprise any of the following high-risk factors and are identified as such s after a comprehensive evaluation by the Platform.

High-risk users include:

  1. users who have been subject to or are currently under criminal or administrative investigation, excluding users who are investigated in connection with any civil proceeding or emergency dispute;

  2. users who are prominent public figures, or whose controlling shareholders, actual controllers and/or actual beneficiaries are prominent public figures;

  3. users belongingwho are from high- risk countries or regions, or their controlling shareholders, actual controllers and/or actual beneficiaries are from high-risk countries or regions;

  4. users who are identified as key suspicious users according to relevant procedures of the Platform;

  5. users who are engaged in business operations in industries subject to a relatively high level of money laundering risks, such as jewelry, precious metals trading, currency exchange, pawn brokerage, money remission, nightclubs and the arms industry, etc;

  6. users who engage in intensive trading within a certain period of time, which is seriously inconsistent with the situation on the digital assets markets; and

  7. users who engage in unusual operations.

Article 19 Identification of Low-risk users. Low-risk users refers to those users who are identified as such s after a comprehensive evaluation by the Platform.

Low-risk factors include:

  1. users that are financial institutions or well-known companies;

  2. userss who are natural person and of whom the Platform has proper understanding through verification and who carry a relatively low risk of money laundering;

  3. users who are reviewed and approved by the Platform’s risk control and compliance departments.

Article 20 Identification of Medium-risk users. Medium- risk users refers to users other than those specified under Articles 18 and 19 of these Rules.

Article 21 Adjustment of Risk Level Grading. After the establishment of business relations with the users, the Platform will pay sustained attention to their identity and transaction status. Should there be any change or abnormality in such identity or status, or the Platform becomes suspicious about any of the information that it has by then obtained on the users, the Platform will re-identify the user identity and adjust the risk level grading of the user in a timely manner. The Platform has the discretion to adjust the users’s risk level grading and may do so without providing the user with any reason.

Article 22 Monitoring of High- risk users. For users in the high-risk category, the Platform will conduct a review every six months to update the basic information on the user's identity and ascertain their sources of funding, use of funds, financial standing or business status. If the Platform, on the basis of a comprehensive assessment during the regular review of a high-risk users, deems that the user and the transactions in the users’s account with the Platform are normal, it may lower the risk level of such users.

Article 23 Continuous users Identification. Throughout the business relationship with each user, the Platform will adopt continuous user identity verification measures so as to keep following the user's transaction status, and if the Platform finds that the users's identity information or information has expired and the user fails to update such information or data within a reasonable period of time without providing any justifiable reason, the Platform will take measures to suspend the service for the user.

Article 24 Re-identification of userss. Under any of the following circumstances, the Platform has the right to re- identify a users’s identity:

  1. where the users requests to change his/her name or designation, the type of his/her identity certificate(s) or identification documents(s), ID Card number, registered capital, business scope or legal representative;

  2. where there is any abnormality in the users’s conduct or trading;

  3. where the users’s name is the same as that of any criminal suspect, money launderer or terrorist financier;

  4. where the users is suspected of engaging in money-laundering or terrorist financing;

  5. where there is any inconsistency or contradiction between the information on the users that the Platform acquires and relevant information that the Platform already has in its possession;

  6. there is any doubt about the authenticity, validity and/or integrity of the users’s information and materials previously obtained;

  7. other circumstances under which the Platform deems it necessary to re-identify the users's identity.

Article 25 Trading Limits. The Platform has the right to set and adjust at any time the maximum amount of currency that may be withdrawn for scheduled transactions, according to the transaction security and actual conditions.

Article 26 Identification of Suspicious Transactions. The Platform has the right to verify the following suspicious transactions and suspicious accounts:

  1. dispersed transfer-in of digital assets followed by collective transfer-out thereof within a short period of time, or collective transfer-in followed by dispersed transfer- out within a short period of time, which is clearly inconsistent with the users’s identity, financing standing and/or business operation status;

  2. where an account that has been inactive for a long time is suddenly reactivated, or there is a sudden abnormal in-flow of digital assets in an account with usually small amounts of digital asset flow, and a large amount of currency is withdrawn within a short period of time;

  3. where a large number of accounts are opened or cancelled without any justifiable reason, and a large amount of currency is deposited or withdrawn prior to such cancellation of accounts;

  4. there is any suspicious lump-sum deposit or withdrawal in the account of an User who is a natural person;

where the users engages in excessively frequent trading within a certain period of time, which is seriously inconsistent with the situation on the digital assets market;

Unusual or unexplained transactions

Transactions that do not have an apparent lawful purpose

Transactions involving known or suspected terrorists or terrorist organizations

Transactions involving politically exposed persons (PEPs)

Transactions that are inconsistent with the customer's known business or financial activities

Transactions that involve customers from high-risk countries or regions

  1. other suspicious trading situations identified by the Platform.

Article 27 Identification of Terrorist Financing. If the Platform suspects that an users's transaction or attempted transaction is related to terrorism, terrorist crime, any terrorist organization, terrorist or people engaged in terrorist financing activities, it shall adopt appropriate measures, regardless of the amount of fund or value of assets involved.

Article 28 Handling of Suspicious Conduct. When the Platform identifies the identity of an users, it shall have the right to adopt measures such as suspending any suspicious transaction, rejecting transaction applications, reversing transactions, freezing suspicious accounts, and reporting to the competent authorities if the Platform uncovers any of the following conducts on the part of the users:

  1. the users refuses to provide valid identity certificates or other identification documents;

  2. the users refuses to update his/her profile without any justifiable reason;

  3. where, after necessary measures are adopted, the Platform still doubts the authenticity, validity and/or integrity of the users’s identity information;

  4. the users forges or alters his or her identification documents to deceive the Platform to allow it to open an account with the Platform; or

  5. the users refuses to provide a reasonable explanation for the suspicious conduct thereof, or the users’s explanation is obviously unjustifiable.

Article 29 users Data storage system. The Platform establishes a system for the storage of userss’ identity information and transaction records, and properly preserves documents and data such as users identity information and transaction records so as to facilitate money laundering investigation and supervision and regulation, and prevent the loss, damage and disclosure of such information.

Article 30 Scope of the storage of the userss’ Data and Transaction Records.

users identity information and transaction data saved by the Platform includes the users identity information as provided, various data and records reflecting the users’s identity identification carried out by the Platform, as well as the data and information of each transaction and other data reflecting the actual circumstances of the transactions.

Article 31 Term for the storage of users identity information and Transaction Records. The Platform shall keep users identity information and transaction records for specific terms depending on the following circumstances:

  1. users's identity information shall be kept for at least five years, starting from the date when the business relationship between the users and the Platform ends;

transaction records shall be kept for at least five years, beginningstarting from the date when the transaction is entered into records;

If the user's identity information and transaction records are associated with any suspicious activity under investigation for money laundering, and the money laundering inquiry is not concluded upon the expiration of the minimum storage term specified in the preceding paragraph, the Platform will retain such information until the conclusion of the money laundering investigation.

Article 32 Assistance to Judicial Investigation. If a judicial organ, law enforcement organ or other competent authority of a country or region submits a request to the Platform for assistance in connection with any investigation, the Platform shall have the right to cooperate with such investigation and provide relevant information and materials as is requested by such organ or authority, as the case may be.

Article 33 Confidentiality in Anti-money Laundering. Any sta member of the Platform that comes across any information relating to anti- money laundering through his or her performance of duties relating to money laundering or his or her work shall strictly comply with confidentiality requirements and keep confidential all the users identity information, suspicious transactions, terrorist financing transactions and other information that he or she may obtain. Such sta member may not provide such information to any organization, individual or any unrelated sta member of the Platform.

Article 34 Cautions to the userss. The userss shall pay attention to the following cautions:

  1. the userss are forbidden from lending their account details to any other person;

  2. the userss are forbidden from renting out or lending their identity certificates;

  3. the userss are forbidden from renting out, lending or disclosing important personal assets information, such as the users's account details and password;

  4. userss shall actively cooperate with the Platform in users identification.

Article 35 Reports of Suspicious Conducts. userss of the Platform may report to the Platform if they find that any account may be engaged in money laundering or terrorist financing activities during trading on the Platform.

Article 36 Interpretation. These Rules shall be interpreted by the Platform.

Article 37 E ective Date. These Rules shall come into e ect on the date of promulgation thereof.

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