Disclosures

1. How to Interpret This Risk Disclosure

All terms used in this notice are defined in the DeepTradeX Terms of Use ("Terms of Use") and have the same meaning and structure as in the Terms of Use.

 

2. DeepTradeX Services

This statement provides you with information about the risks associated with DeepTradeX services. Each DeepTradeX service has its unique risks. This statement provides an overview of the risks you may encounter when using DeepTradeX services.

 

This statement does not explain all risks, nor does it explain how these risks relate to your personal circumstances. Before deciding to use DeepTradeX services, please ensure you fully understand the risks involved.

 

3. No Personal Advice

We do not provide personal advice regarding our products or services. We may sometimes provide factual information, trading process information, and potential risk information. However, any decision to use our products or services is made entirely by you. Any communication or information provided by DeepTradeX to you does not constitute, nor should it be considered or interpreted as, investment advice, financial advice, trading advice, or any other type of advice. You should be solely responsible for determining whether any investment, investment strategy, or related transaction is suitable for you based on your personal investment objectives, financial situation, and risk tolerance.

 

4. No Monitoring

DeepTradeX is not your broker, intermediary, agent, or advisor, and we do not have any fiduciary relationship or obligation with you regarding any transactions or other decisions or activities you make using DeepTradeX services. We do not monitor whether your use of DeepTradeX services aligns with your financial objectives. You should assess whether your financial resources are sufficient to support your financial activities with us and whether you are suitable for the risk profile of the products and services you use.

 

5. No Tax, Regulatory, or Legal Advice

The taxation of digital assets is uncertain, and you are responsible for determining what taxes may be due and how they apply when trading through DeepTradeX services. You are responsible for declaring and paying any taxes that may arise from trading on DeepTradeX services, and you acknowledge that DeepTradeX does not provide legal or tax advice related to these transactions. If you have any questions about your tax status or obligations when using DeepTradeX services or regarding digital assets held in your DeepTradeX account, you may seek independent advice.

 

You acknowledge that DeepTradeX shall, as required by applicable law and at the time, place, and circumstances required by applicable law, report information related to your transactions, transfers, distributions, or payments to tax authorities or other public institutions. Similarly, DeepTradeX shall, as required by applicable law and at the time, place, and circumstances required by applicable law, withhold taxes related to your transactions, transfers, distributions, or payments. Applicable law may also require DeepTradeX to request additional tax information, status, certifications, or documents from you. You acknowledge that if you fail to respond to these requests within the specified time, DeepTradeX may withhold taxes and remit them to tax authorities in accordance with relevant legal provisions. We recommend that you seek professional personal tax advice on the above matters before engaging in any digital asset transactions.

 

6. Market Risk

Digital asset trading faces high market risk and price volatility. Value changes can be very dramatic and may occur rapidly without any warning. Past performance is not a reliable indicator of future performance. Investment value and any returns may rise or fall, and you may not be able to recover the principal you have invested.

 

7. Liquidity Risk

Digital assets may have limited liquidity, which may make it difficult or even impossible for you to sell or close positions when needed. This situation may occur at any time, including during periods of rapid price fluctuations.

 

8. Fees and Charges

Our fees and charges are listed here. DeepTradeX may update fees and charges from time to time at its discretion. Please note all applicable costs and charges, as these costs and charges will affect the returns you receive from using DeepTradeX services.

 

9. Availability Risk

We do not guarantee that DeepTradeX services will be available at any specific time, nor do we guarantee that DeepTradeX services will not experience unplanned service interruptions or network congestion. You may not be able to buy, sell, store, transfer, send, or receive digital assets as you wish.

 

10. Third-Party Risk

The provision of DeepTradeX services may involve third parties, such as payment providers, custodians, and banking partners. You may need to comply with the terms and conditions of these third parties, and DeepTradeX is not responsible for any losses that these third parties may cause you.

 

11. Security Risk

DeepTradeX cannot eliminate all security risks. You are responsible for properly safeguarding your DeepTradeX account password and may be responsible for all transactions under your DeepTradeX account, whether or not you authorize them. Digital asset transactions may be irreversible, and losses from fraudulent or unauthorized transactions may be unrecoverable.

 

12. Risks Related to Digital Assets

Given the nature of digital assets and their underlying technology, there are many inherent risks, including but not limited to:

 

Failures, defects, hacks, vulnerabilities, errors, protocol failures, or unforeseen circumstances occurring in digital assets or the technological or economic systems on which digital assets rely;

 

Digital asset transactions are irreversible. Therefore, losses from fraudulent or accidental transactions may be unrecoverable;

 

Technological developments causing digital assets to become obsolete;

 

Delays causing transactions to fail to settle on the intended delivery date; and

 

Attacks on the protocols or technology on which digital assets rely, including but not limited to: i. distributed denial of service; ii. Sybil attacks; iii. phishing; iv. social engineering; v. hacking; vi. smurfing; vii. malware; viii. double spending; ix. majority mining, consensus-based, or other mining attacks; x. misinformation campaigns; xi. forks; and xii. spoofing.

 

13. Monitoring Risk

Digital asset markets are open 24 hours a day, 7 days a week. Prices may fluctuate dramatically at any time, including outside normal business hours.

 

14. Communication Risk

When you communicate with us through electronic communications, you should be aware that electronic communications may fail, may be delayed, may not be secure, and/or may not reach their intended destination.

 

15. Currency

Currency exchange rate fluctuations will affect your gains and losses.

 

16. Legal Risk

Changes in legislation and regulation may have a significant impact on the value of digital assets. This risk is unpredictable and may vary by market.

 

 

 

Anti-Money Laundering (AML)

 

This policy relates to DeepTradeX's anti-money laundering and counter-terrorism financing ("AML/KYC") policies and procedures. This policy is provided for general information purposes only and is not legally binding on DeepTradeX and/or any other person (natural or non-natural).

 

1. DeepTradeX's AML/KYC Working Principles and Approach

DeepTradeX is committed to supporting AML/KYC efforts. In principle, we commit to:

 

Exercising due diligence when dealing with our customers and natural persons designated to act on behalf of our customers;

 

Conducting business according to high ethical standards and avoiding, to the extent possible, establishing any business relationships that are related to or may be related to or may facilitate money laundering or terrorism financing;

 

We will make every effort to assist and cooperate with relevant law enforcement agencies to prevent the threat of money laundering and terrorism financing.

 

2. DeepTradeX's Risk Assessment and Risk Mitigation Approach

The first layer includes strict customer identification (KYC) procedures, including verifying the identity of customers, whether individuals or entities. In addition to obtaining identity documents, we also obtain the beneficial owners/natural person identities of non-natural person entities in accordance with international standards such as the Financial Action Task Force (FATF).

 

The second layer includes a risk-based system to ensure additional customer due diligence (CDD) is conducted. For this purpose, we screen customers (including actual beneficial owners) against any lists of sanctioned individuals and entities provided by governments. We may also screen against other lists at our discretion to protect our reputation and customers.

 

The third layer includes ongoing monitoring of suspicious activities. If our procedures suspect or have reason to suspect that suspicious activity has occurred, we will submit suspicious activity reports to local regulatory authorities. Suspicious transactions are typically inconsistent with the customer's known legitimate business or personal activities.

 

These are the main components of our compliance program; however, the most important adhesive or connection point of these layers is our leadership team and staff, including anti-money laundering/risk personnel who implement training, supervision, and a sound compliance culture.

 

 

Risk Assessment

We anticipate that, as of the date of this policy, most of our customers are retail customers. In this regard, we will:

 

a. Document and/or collect documents related to:

1. The identity of our customers;
2. The countries or jurisdictions from which our customers come or are located; and

b. Ensure that, to the best of our knowledge, skill, and ability, with the assistance of designated individual and entity lists, we assess and screen our customers, customer affiliates, natural persons designated to act on behalf of customers, and beneficial owners of customers. Designated individual and entity lists include (but are not limited to) the following categories:

 

Hong Kong Special Administrative Region Government Gazette, U.S. Office of Foreign Assets Control (OFAC) sanctions lists, United Nations Security Council sanctions lists, etc.

 

 

Risk Mitigation

Once identified, we will not deal with any person listed on designated individual and entity lists.

 

3.Our Attitude Toward New Products, Practices, and New Technologies

We will obtain appropriate advice on identifying and assessing money laundering and terrorism financing risks that may arise in connection with:

 

Developing new products and new business practices, including new delivery mechanisms;

 

Using new or developing technologies to meet new and existing needs.

 

We will pay particular attention to any new products and new business practices, including new delivery mechanisms and new or developing technologies that facilitate anonymity, such as digital tokens that facilitate anonymity (whether security, payment, and/or utility tokens).

 

4.Our Customer Due Diligence (CDD) Approach

We do not open, maintain, or accept anonymous accounts or pseudonymous accounts.

 

If we have any reasonable grounds to suspect that a customer's assets or funds come from drug trafficking or criminal activities, we will not establish business relationships or conduct any transactions with them. We will submit suspicious transaction reports and provide copies to relevant financial intelligence units.

 

We perform customer due diligence:

 

When we establish business relationships with any customer;

 

When we conduct any transaction for any customer who has not established a business relationship with us;

 

When we facilitate or receive cryptocurrency through transfers for any customer who has not established a business relationship with us;

 

When we suspect money laundering or terrorism financing;

 

When we have doubts about the authenticity or adequacy of any information.

 

When we suspect that two or more transactions are or may be related, connected, or are deliberately restructuring one transaction into several smaller transactions to evade anti-money laundering and counter-terrorism financing measures, we will treat these transactions as one transaction and combine their values to comply with anti-money laundering and counter-terrorism financing principles.

 

 

Identifying Our Customers

 

We will identify each customer.

 

To identify our customers, we shall obtain at least the following information:

 

• Their full name, including aliases;
• Their unique identification number (such as identity card number, birth certificate number, or passport number, or if the customer is not a natural person, their business registration number);
• Their residential address, or if applicable, their registered business address, and (if different) their principal place of business;
• Their date of birth, incorporation, merger, or registration; and their nationality, place of incorporation, or registration.
• If the customer is a legal person or legal arrangement, in addition to obtaining the above relevant information, we will also determine its legal form, articles of association, and the powers that govern and bind the legal person or legal arrangement;
• We will also identify its affiliates (for example, its directors, partners, and/or persons with executive authority) by obtaining at least the following information for each affiliate:
• Full name, including aliases; and unique identification number (for example, the affiliate's identity card number, birth certificate number, or passport number).

 

 

Verifying Customer Identity

 

We will verify customer identity using reliable, independent source data, documents, or information. If the customer is a legal person or legal arrangement, we will verify its legal form, proof of existence, articles of association, and the powers that govern and bind the customer using reliable, independent source data, documents, or information.

 

Identifying and Verifying the Identity of Natural Persons Acting on Behalf of Customers

 

When a customer designates one or more natural persons to represent them in establishing business relationships with us, or if the customer is not a natural person, we will:

 

Identify each natural person acting on behalf of the customer or designated to act on behalf of the customer by obtaining the following information:

 

• Their full name;
• Their unique identification number;
• Residential address;
• Date of birth;
• Nationality;

 

 

And verify the appropriate authority of each natural person designated to act on behalf of our customer by:

 

Appropriate documentary evidence authorizing our customer to appoint such natural person;

Signature samples of each natural person.

 

If the customer is a government entity, we will only obtain information that may be necessary to confirm that the customer is the government entity it claims to be.

 

 

Identifying and Verifying Beneficial Owners

 

We will inquire whether there are actual beneficial owners related to the customer.

 

If the customer has one or more beneficial owners, we will identify the beneficial owner and take reasonable measures to verify the identity of the beneficial owner using relevant information or data obtained from reliable, independent sources. We will:

 

 

If the customer is a legal person—

Identify the natural person(s) who ultimately own the legal person (whether acting alone or jointly);

 

If there is doubt about whether the natural person who ultimately owns the legal person is the actual beneficial owner, or if no natural person ultimately owns the legal person, identify the natural person who ultimately controls the legal person or has ultimate effective control over the legal person (if applicable); and

 

If no natural person is identified, identify the natural person in the legal person who has executive authority;

 

 

If the customer is a legal arrangement—

For trusts, identify the settlor, trustee, protector (if applicable), beneficiaries, and any natural person who exercises ultimate ownership, ultimate control, or ultimate effective control over the trust; and

 

For other types of legal arrangements, identify persons in equivalent positions.

 

If our customer is not a natural person, we will determine the customer's business nature, ownership, and control structure.

 

 

If the customer's beneficial owner meets the following conditions, we will be required to:

 

Entities listed on stock exchanges;

 

Entities listed on stock exchanges and subject to regulatory disclosure requirements; and adequate transparency requirements regarding their beneficial owners;

 

Financial institutions;

 

Financial institutions that comply with and are supervised to comply with anti-money laundering and counter-terrorism financing requirements consistent with standards developed by the Financial Action Task Force;

 

Or an investment vehicle whose manager is a financial institution or is subject to and supervised to comply with anti-money laundering/counter-terrorism financing requirements consistent with standards developed by the Financial Action Task Force;

 

Unless we have doubts about the authenticity of customer due diligence information or suspect that our customer, business relationship with the customer, or transactions conducted for the customer may be related to money laundering or terrorism financing.

 

We will also document the basis for our decisions.

 

Information on the Purpose and Intended Nature of Business Relationships and Transactions Conducted Without Opening Accounts*

 

When we process applications for establishing business relationships or conducting transactions without customer consent, we shall obtain information from customers about the purpose and intended nature of business relationships or transactions without obtaining customer consent.

 

Review of Non-Account Transactions*

When we conduct one or more transactions ("current transactions") for customers who have not opened accounts, we will review the customer's previous transactions to ensure that current transactions are consistent with our understanding of the customer, their business and risk profile, and (if applicable) sources of funds.

 

When we establish business relationships with customers, payment service providers should review any transactions conducted before establishing business relationships to ensure that business relationships are consistent with our understanding of customers, their business and risk profiles, and (if applicable) sources of funds.

 

We will pay particular attention to all complex, unusually large, or unusual patterns of non-account transactions that have no apparent or visible economic or legitimate purpose. We will investigate the background and purpose of such transactions to the extent possible and document the findings so that we can provide such information to relevant authorities when needed.

 

To review transactions conducted without opening accounts, we will establish and implement appropriate systems and processes commensurate with the size and complexity of payment service providers to:

 

Monitor transactions conducted without opening accounts for customers;

 

And detect and report suspicious, complex, unusually large, or unusual pattern transactions conducted without accounts.

 

If there are reasonable grounds to suspect that transactions conducted without opening accounts for customers are related to money laundering or terrorism financing, and we consider it appropriate to conduct such transactions, payment service providers should verify and document the reasons for conducting such transactions.

 

 

Ongoing Monitoring

 

We will continuously monitor business relationships with customers. In the course of conducting business with customers, we will observe the operation of customer accounts and carefully review transactions conducted throughout the business process to ensure that transactions are consistent with our understanding of customers, their business and risk profiles, and (if applicable) sources of funds.

 

If transactions involve transferring cryptocurrency to or receiving cryptocurrency from the following entities, we will take risk mitigation measures:

 

Financial institutions;

 

Or financial institutions that comply with anti-money laundering and counter-terrorism financing requirements developed by the Financial Action Task Force and are supervised accordingly.

 

We will pay particular attention to all complex, unusually large-scale, or unusual pattern transactions conducted during business relationships that have no apparent or visible economic or legitimate purpose. We will investigate the background and purpose of such transactions to the extent possible and document the findings so that we can provide such information to relevant authorities when needed.

 

For ongoing monitoring, we will establish and implement appropriate systems and processes commensurate with the size and complexity of payment service providers to:

 

• Monitor business relationships with customers;
• And detect and report suspicious, complex, unusually large, or unusual transaction patterns that occur during business relationships.
   

We will ensure the relevance and timeliness of due diligence data, documents, and information obtained about customers, natural persons acting on behalf of customers, customer affiliates, and actual beneficial owners of customers by reviewing existing customer due diligence data, documents, and information (particularly for high-risk category customers).

 

If there are reasonable grounds to suspect that existing business relationships with customers are related to money laundering or terrorism financing, and we consider it appropriate to retain the customer:

 

• We will verify and document the reasons for retaining the customer;
• And the customer's business relationship with us should adopt corresponding risk mitigation measures, including enhanced ongoing monitoring.

 

When we assess that a customer or business relationship with a customer has higher risk, payment service providers should implement enhanced customer due diligence measures, including obtaining approval from our senior management to retain the customer.

 

Customer Due Diligence Measures for Non-Face-to-Face Business Relationships or Non-Face-to-Face Transactions Without Opening Accounts*

We will develop policies and procedures to address any specific risks associated with non-face-to-face business relationships with customers or non-face-to-face transactions conducted without opening accounts for customers ("non-face-to-face business contacts").

 

We should implement these policies and procedures when establishing business relationships with customers and conducting ongoing due diligence.

 

If there is no face-to-face contact, payment service providers should implement customer due diligence measures that are at least as stringent as those for face-to-face contact.

 

When payment service providers conduct initial non-face-to-face business contacts, payment service providers should, at their own expense, engage external auditors or independent qualified consultants to assess the effectiveness of policies and procedures, including the effectiveness of any technical solutions used to manage impersonation risks.

 

We will engage external auditors or independent qualified consultants to evaluate new policies and procedures and submit evaluation reports to the Authority within one year after the implementation of policy and procedure changes.

 

Acquiring Payment Service Provider's Reliance on Implemented Measures

When we (the "acquiring payment service provider") acquire all or part of another payment service provider's business, we will implement measures for customers acquired through that business at the time of acquisition, unless the acquiring payment service provider:

 

Simultaneously acquires all corresponding customer records (including customer due diligence information) and has no doubts or concerns about the authenticity or adequacy of the acquired information; and

 

Conducts due diligence, and the results do not raise any doubts in the acquiring payment service provider about the adequacy of anti-money laundering/counter-terrorism financing measures previously taken by the business or part of the business it is currently acquiring, and documents this process.

 

 

Measures for Non-Account Holders*

 

If we conduct any transactions for any customers who do not have business relationships with us, we will:

 

• Implement customer due diligence measures as if the customer had applied to the payment service provider to establish a business relationship; and
• Document sufficient details of relevant transactions to enable reconstruction of transactions, including the nature and date of transactions, types and amounts of currencies involved, value dates, and details of payees or beneficiaries.

 

Verification Timing

 

We will complete verification of the identity of customers, natural persons acting on behalf of customers, and actual beneficial owners of customers under the following circumstances:

 

• Payment service providers establish business relationships with customers;
• Payment service providers conduct any transactions for customers, but customers have not yet established business relationships with payment service providers; or
• Payment service providers facilitate or receive digital payment tokens for customers through value transfers, and customers have not yet established business relationships with payment service providers.

 

Under the following circumstances, we may establish business relationships with customers before completing verification of the identity of customers, natural persons acting on behalf of customers, and actual beneficial owners of customers:

 

• It is necessary to delay completion of verification in order not to interrupt normal business operations;
• Payment services can effectively manage money laundering and terrorism financing risks.

 

When we establish business relationships with customers before verifying the identity of customers, natural persons acting on behalf of customers, and actual beneficial owners of customers, we will:

 

• Develop and implement internal risk management policies and procedures regarding conditions for establishing such business relationships before verification; and
• Complete such verification as soon as possible.

 

 

Where Measures Have Not Been Completed

 

If we cannot complete measures as required, we will not begin or continue business relationships with any customers or conduct any transactions for any customers.

 

If we cannot complete these measures, payment service providers should consider whether the circumstances are suspicious to warrant submitting suspicious transaction reports.

 

Completion of measures refers to situations where payment service providers have obtained, screened, and verified (including delayed verification permitted under paragraphs 6.43 and 6.44) all necessary CDD information in accordance with paragraphs 6, 7, and 8, and payment service providers have received satisfactory responses to all inquiries related to such necessary CDD information.

 

 

Joint Accounts

 

For joint accounts, we will implement customer due diligence (CDD) measures for all joint account holders as if each of them were individual customers of the payment service provider.

 

 

Screening

 

We will screen customers, natural persons acting on behalf of customers, customer affiliates, and beneficial owners of customers against relevant money laundering and terrorism financing information sources and lists and information provided by the Authority to determine whether customers have any money laundering or terrorism financing risks.

 

We will screen the following persons:

 

• When we establish business relationships with customers, or as soon as possible thereafter;
• Before we conduct any transactions for any customers who have not yet established business relationships with payment service providers;
• Before we facilitate or receive digital payment tokens through value transfers for customers who have not yet established business relationships with us;
• Regularly after we establish business relationships with customers;
• And when any of the following information changes or is updated:
• Lists and information provided by the Authority to payment service providers; or
• Natural persons designated to act on behalf of customers, customer affiliates, or beneficial owners.

 

We will screen all value transfer originators and value transfer beneficiaries against lists and information provided by the Authority to determine whether there are money laundering or terrorism financing risks.

 

We will document the results of all screenings.

 

5.Our Enhanced Customer Due Diligence Approach

Politically Exposed Persons

 

We will use all reasonable means to determine whether customers, any natural persons acting on behalf of customers, any affiliates of customers, or any actual beneficial owners of customers are politically exposed persons, or family members or close associates of politically exposed persons.

 

In addition to implementing customer due diligence measures, when we determine that customers or any actual beneficial owners of customers are politically exposed persons, or family members or close associates of politically exposed persons, we will also implement at least the following enhanced due diligence measures:

 

Obtain approval from senior management to establish and continue business relationships with customers;

 

Determine the sources of wealth and sources of funds of customers and any of their actual beneficial owners through reasonable methods;

 

And enhance monitoring of business relationships with customers during the course of conducting business relationships with customers. For any unusual transactions, we will enhance the degree and nature of monitoring.

 

 

2.Higher Risk Categories

We recognize that situations where customers have or may have higher money laundering or terrorism financing risks include but are not limited to the following situations:

 

If customers or any of their actual beneficial owners come from or are located in countries or jurisdictions where the Financial Action Task Force has required countermeasures to be taken, payment service providers should consider any business relationships or transactions with such customers as having higher money laundering or terrorism financing risks;

 

And if customers or any of their actual beneficial owners come from or are located in countries or jurisdictions known to have inadequate anti-money laundering/counter-terrorism financing measures, and such countries or jurisdictions are determined by payment service providers themselves or notified to payment service providers by the Authority or other foreign regulatory agencies, payment service providers should assess whether such customers have higher money laundering or terrorism risks.

 

We will conduct enhanced customer due diligence on customers with higher money laundering or terrorism financing risks or any customers that regulatory authorities notify us have higher money laundering and terrorism financing risks.

 

6.Our Approach to Bearer Negotiable Instruments and Cash Payment Restrictions

We will not make any payments in the form of bearer negotiable instruments.

 

We will not pay any amount in cash during the course of conducting business.

 

7.Record Keeping

We will maintain appropriate records for at least 5 years as required.

 

8.Personal Information*

We will protect customers' personal data in the prescribed manner.

 

9. Suspicious Transaction Reports ("STR")

We will notify relevant authorities and submit suspicious transaction reports as required by law. We will also retain all records and transactions related to all such transactions and suspicious transaction reports.

 

10.Our Compliance, Audit, and Training Policies

Among other things, we will take proactive measures to regularly train our staff and employees on anti-money laundering/counter-terrorism financing matters.

 

Enterprise-wide Money Laundering/Terrorism Financing Risk Assessment

 

 

We will conduct enterprise-wide money laundering/terrorism financing risk assessments in three phases:

 

Phase 1: Assess Inherent Risk

We will assess inherent risks related to:

Customers or entities: We will assess our customers and/or entities we deal with;

Products or services: We will be and will be mindful of whom we serve in cryptocurrency over-the-counter trading services;

Geographic level: We will not deal with customers on designated individual and entity lists.

 

Phase 2: Assess Mitigation Controls

We will assess mitigation controls related to the above, and any and/or all customers we find suspicious will first be monitored and then subjected to enhanced due diligence.

 

Phase 3: Assess Residual Risk

After assessing our mitigation controls, we will assess our residual risks.