AML/KYC Policies

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, FX Live formulates these Rules in
accordance with the User Agreement of the FX Live Website, the User Agreement of FX Live 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, FX Live will have a portfolio of clients across the globe. This international
presence may trigger queries or requests for information from other law enforcement authorities.
FX Live shall therefore abide to the different laws and legal requirements imposed by the
authorities in Seychelles. These rules outline the procedures to be followed to prevent money
laundering, terrorist financing and corruption. FX Live 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.
SCOPE OF APPLICATION
These Rules shall apply to all Users trading on the website of FX Live 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.
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 offenders 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.

THE PLATFORM’S RULES AND REGULATIONS AGAINST MONEY LAUNDERING.
The rules and regulations of the FX Live against money laundering (including terrorist financing; the
same hereafter) include these Rules, sections concerning money laundering in the User Agreement
of FX Live Website and the User Agreement of the FX Live APP, Measures for the Management of
Large- sum Transactions and the OTC Platform Guidelines for Users against Money Laundering and
Terrorist Financing. In the event of any conflict between these Rules and the sections on money
laundering in the User Agreement of FX Live Website and the User Agreement of the FX Live AP
these Rules shall prevail. In the event of any conflict between these Rules and Measures for the
Management of Large-sum Transactions and the OTC Platform Guidelines for Users against Money
Laundering and Terrorist Financing, such measures and guidelines shall prevail.

BASIC PRINCIPLES OF THE PLATFORM AGAINST MONEY LAUNDERING
The Platform monitors User risks according to the following principles:
(1) The principle of comprehensiveness. The Platform will consider all kinds of risk factors
based on which Users may be suspected of money laundering, and monitor risks of all Users in an
appropriate manner.
(2) The principle of prudence. Based on fully understanding the Users, the Platform will
improve its ability to authenticate User identities, and monitor User risks in a prudent way.
(3) The principle of sustainability. The Platform will pay appropriate attention to User risks and
respond to risks based on actual and specific circumstances of each risk.
(4) The principle of confidentiality. User 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.
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.

RESPONSIBLE ORGAN.
The Platform carries out operations against money laundering via a guidance group for money
laundering affairs 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 departments.

FUNCTIONS OF THE RESPONSIBLE ORGAN.
The guidance group for money laundering affairs is responsible for planning, guiding, and
coordinating the money laundering affairs 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 difficult problems relating to money laundering and to form solutions.

The staffing structure of the team for advancing the fight against money laundering shall be
determined based on regulatory requirements and location-specific conditions. The main
responsibilities thereof include:
(1) to implement relevant rules against money laundering and plans of the guidance group
for money laundering affairs.
(2) to implement various assignments.
(3) to analyze and identify the identity and background of any User 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.

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.
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

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 office 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.

LANGUAGES OF THE SUBMITTED DOCUMENTS.
The Platform only accepts documents prepared in English. Users who submit documents prepared in
any language other than English shall engage a properly qualified translator to translate such
documents into English and have the translated version thereof properly notarized.
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.
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.
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.

IDENTITY AUTHENTICATION BY AN ENTRUSTED THIRD PARTY.
Where a sub-website of the Platform entrusts a third-party institution to authenticate a User’s
identity, the third-party institution shall meet the following requirements:

(1) the third-party institution has adopted necessary measures for User identification and
storage of identity information in accordance with laws and regulations on money laundering and
the Platform’s relevant rules and regulations against money laundering.
(2) the third-party institution’s supply of User information to the sub-website is not subject to
any legal or technical obstacles.
(3) when it engages in business operation, the sub-website can promptly obtain the User
information provided by the third-party institution and, if necessary, obtain the User’s valid identity
certificate, as well as the original, photocopy or photographic copies of the identity documents from
the third-party institution.
REVIEW OF USER DOCUMENTS.
The Platform will verify and record the relevant information submitted by the Users in accordance
with the User identification system under the Platform’s relevant regulations against money
laundering. If the Platform has any doubt about the information submitted by any User, it has the
right to ask the User to provide other documents or consult with relevant competent authorities or
departments for verification.
CLASSIFICATION OF USER RISK LEVELS.

The Platform classifies Users into three categories, i.e., low-risk Users, medium-risk Users, and high-
risk Users according to the materials submitted by the Users and based on such factors as the

geographical location of the Users, the industries they are involved in, background of the
shareholders of Users, if any, and whether Users are prominent public figures, inter alia. The
Platform reserves the right to adjust the grading of Users.
IDENTIFICATION OF HIGH-RISK USERS.
High-risk Users refers to Users who comprise any of the following high-risk factors and are
identified as high-risk Users 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 who 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, which is seriously
inconsistent with the situation on the digital asset’s markets; and
(7) Users who engage in unusual operations.
IDENTIFICATION OF LOW-RISK USERS.
Low-risk Users refers to those Users who are identified as low-risk Users after a

comprehensive evaluation by the Platform. Low-risk factors include:
(1) Users that are financial institutions or well-known companies.
(2) Users 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.
IDENTIFICATION OF MEDIUM-RISK USERS.
Medium-risk Users refers to Users other than those specified under Articles 18 and 19 of these
Rules.
ADJUSTMENT OF RISK LEVEL GRADING.
After the establishment of business relations with a User, 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 User, 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 User’s risk level
grading and may do so without providing the User with any reason.
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 Users’ identity and ascertain their sources of funding, use of funds,
financial standing, or business status. If the Platform, based on a comprehensive assessment
during the regular review of a high-risk User, deems that the User and the transactions in the User’s
account with the Platform are normal, it may lower the risk level of such User.
CONTINUOUS USER IDENTIFICATION.
Throughout the business relationship with each User, the Platform will adopt continuous User
identity verification measures to keep following the User’s transaction status, and if the Platform
finds that the User’s identity information or information has expired and the User fails to update
such information or data within a reasonable period without providing any justifiable reason, the
Platform will take measures to suspend the service for the User.

RE-IDENTIFICATION OF USERS.
Under any of the following circumstances, the Platform has the right to re- identify a User’s identity:
(1) where the User 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 User’s conduct or trading.
(3) where the User’s name is the same as that of any criminal suspect, money launderer or
terrorist financier.
(4) where the User is suspected of engaging in money-laundering or terrorist financing.
(5) where there is any inconsistency or contradiction between the information on the User 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 User’s information
and materials previously obtained.
(7) other circumstances under which the Platform deems it necessary to re-identify the User’s
identity.

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.

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 User’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 many 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 a User who is a
natural person.
(5) where the User engages in excessively frequent trading within a certain period, which is
seriously inconsistent with the situation on the digital assets market; and
(6) other suspicious trading situations identified by the Platform.
IDENTIFICATION OF TERRORIST FINANCING.
If the Platform suspects that a User’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.
HANDLING OF SUSPICIOUS CONDUCT.
When the Platform identifies the identity of a User, 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 User:
(1) the User refuses to provide valid identity certificates or other identification documents.
(2) the User 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 User’s identity information.
(4) the User 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 User refuses to provide a reasonable explanation for the suspicious conduct thereof, or
the User’s explanation is obviously unjustifiable.
USER DATA STORAGE SYSTEM.
The Platform establishes a system for the storage of Users’ identity information and transaction
records, and properly preserves documents and data such as User identity information and
transaction records to facilitate money laundering investigation and supervision and regulation, and
prevent the loss, damage, and disclosure of such information
.
SCOPE OF THE STORAGE OF THE USERS’ DATA AND TRANSACTION RECORDS.
User identity information and transaction data saved by the Platform includes the User identity
information as provided, various data and records reflecting the User’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.
TERM FOR THE STORAGE OF USER IDENTITY INFORMATION AND TRANSACTION RECORDS.
The Platform shall keep User identity information and transaction records for specific terms
depending on the following circumstances:
(1) User’s identity information shall be kept for at least five years, starting from the date when
the business relationship between the User and the Platform ends.
(2) transaction records shall be kept for at least five years, starting from the date when the
transaction is entered into records.
(3) if the User’s identity information and transaction records involve any suspicious activity that
is being investigated for money laundering, and the investigation into money laundering is not
completed at the expiration of the minimum storage term as is specified in the preceding
paragraph, the Platform will keep them until the end of the money laundering investigation.
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.
CONFIDENTIALITY IN ANTI-MONEY LAUNDERING.
Any staff 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 User identity
information, suspicious transactions, terrorist financing transactions and other information that he or
she may obtain. Such staff member may not provide such information to any organization, individual
or any unrelated staff member of the Platform.
CAUTIONS TO THE USERS.
The Users shall pay attention to the following cautions:
(1) the Users are forbidden from lending their account details to any other person.
(2) the Users are forbidden from renting out or lending their identity certificates.

MEASURES TAKEN
In cases of an attempt to execute transactions which FX Live suspects that are related to money
laundering or other criminal activity, it will proceed in accordance with the applicable law and report
suspicious activity to regulating authority.
FX Live reserves the right to suspend any client’s operation, which can be regarded as illegal or may
be related to money laundering in the opinion of the staff. FX Live has complete discretion to
temporarily block the suspicious client account or terminate an existing client relationship.
For more information, please contact support@fx-live.com