Aboout Anti-Money Laundering and Anti- Terrorist Financing

Article 1: The purpose and basis of the formulation
In view of the fact that money-laundering activities seriously endanger the development of digital asset transactions, promote and breed corruption, corrupt the social atmosphere, and harm the legitimate rights and interests of users, Breaking the foundation of the operation of the digital asset transaction platform and increasing the legal and operational risks of the digital asset trading platform, the Newdex Group, in order to prevent money laundering and terrorist financing activities and fully implement the relevant provisions of anti-money laundering and counter-terrorism financing laws, provides for the development of these guidelines according to the (Newdex Anti-Money Laundering Rules), (Customer Agreements), (Measures for the administration of Large Transactions), etc.

Article 2: Scope of application
This Guideline applies to all users who trade on Newdex OTC Platform (hereinafter referred to as "OTC Platform". Users shall comply with the provisions of the anti-money laundering and counter-terrorism financing in the country or region where they are located and to the extent prescribed by the laws of the user's region, implement the provisions of these guidelines. If the user's country or region has more stringent requirements, he shall comply with its regulations.

Article 3: Anti-money laundering and anti-terrorist financing 
Refer to the money laundering activities with the purpose of preventing illegal persons from carrying out transactions through the OTC platform so as to conceal the sources and nature of illegal income, such as drug crimes, organized crimes of the underworld nature, terrorist activity, smuggling, bribery and corruption, financial fraud, crimes of Disrupting Financial management order, etc., in accordance with relevant regulations ,the act of taking relevant measures in accordance with laws and relevant provisions of Newdex on anti-money laundering.

Article 4: Newdex relevant provisions on anti-money laundering
Relevant provisions on anti-money laundering (including anti-terrorist financing, the same below) of the Newdex group include anti money laundering provisions of Newdex group, anti-money laundering part of (user agreement), large amount transaction management measures and this guideline. In case of any conflict between the provisions of this guideline and other rules, this guideline shall prevail.

Article 5: basic principles of OTC platform anti money laundering OTC platform shall carry out customer risk monitoring in accordance with the following principles:

• Comprehensiveness. The OTC platform will comprehensively consider various risk factors that may be suspected of money laundering by customers, and take a reasonable way to monitor the risk of all customers.
• Prudence. On the basis of fully understanding customers, the OTC platform will improve the identification ability of customers and cautiously monitor customer risk.
• Sustainability. OTC platform will continue to pay attention to customer risk and make appropriate responses according to the situation at hand.
• Confidentiality. The client identity information, transaction information and risk level information held by the OTC platform shall strictly be confidential and will not be provided to any unit or individual except in accordance with the legal provisions and regulatory requirements.
• Hierarchy management. According to the level of risk of customers, OTC platform shall regularly review customer basic information, and the audit of customers with higher level of risk shall be stricter than that of customers with lower level of risk.

Article 6: the OTC users shall submit the following information and materials in accordance with the Newdex relevant provisions on Anti-Money Laundering:

• personal name;
• Photocopy of ID card or password
• Other information or documents required by OTC.

Article 7: the OTC institutional users shall submit the following information and materials in accordance with the Newdex relevant provisions on Anti-Money Laundering:

• Company name;
• Registered office of company;
• Company’s legal representative;
• Address of legal representative of the company;
• Business license of the company;
• Photocopy of ID card or passport of company’s legal representative;
• Other information or documents required by OTC.

Article 8: the OTC platform will verify and record the relevant information submitted by the customer according to the customer identification system in the Newdex anti-money laundering provisions. If the OTC platform has any questions about the information submitted by the customer, the OTC platform has the right to verify it with the relevant competent authority or department.

Article 9: the OTC platform monitoring for low-risk users will detect low-risk users in accordance with the specific requirements of the Newdex anti-money laundering provisions, and the OTC platform has the right to adjust the level of low-risk users.

Article 10: the monitoring OTC platform for high-risk users will conduct an audit every six months for customers in high-risk categories, update the basic information of customer identity, and understand information such as the source of funds, the purpose of funds, economic conditions or business conditions.

Article 11: the OTC platform will take necessary measures according to law to keep the customer's identity data and transaction information for a certain period of time. According to the international rules, the user's identity data and transaction data shall be kept for at least five years from the end of the business relationship and transaction.

Article 12: OTC users should pay attention to the following matters:

• It is prohibited to lend user's account to others;
• It is prohibited to let or lend out user's identity documents;
• It is prohibited to let, lend out and disclose important personal property information such as the user account, bank card, passbook, password, etc.;
• The user should willingly cooperate with the OTC platform for customer identification;
• When trading on the OTC platform, select and use secure third-party financial institutions for payment activities.

Article 13: Report Suspicious Conduct
OTC Platform users who discover that an account may be engaged in money laundering or terrorist financing when trading on the Platform may be involved in reports to the OTC platform.

Article 14: Explanation of Guidelines; the guidelines are explained by the OTC platform.

Article 15: Effective Period; this Guideline shall be effective from the date of its issuance.