05 AML:CFT Declaration and Risk Information Collection Authorization
1. AML/CFT Compliance Purpose
As an entity involved in digital asset services, the Platform needs to apply risk-based customer due diligence, enhanced due diligence, transaction monitoring, sanctions screening, risk rating, recordkeeping and suspicious activity handling measures. The user authorizes the Platform to collect and process risk information to prevent money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion, market abuse and other unlawful activity.
2. Risk Information Categories
Work status, industry, position, employer or business activity;
Source of funds, source of wealth, trading purpose, expected monthly transaction volume and asset source explanation;
PEP declaration, sanctions lists, adverse media, high-risk countries or regions, device/IP anomalies, duplicate identity or duplicate face risk indicators;
Deposits, withdrawals, wallet addresses, blockchain transaction hashes, counterparty addresses, transaction patterns and KYT risk results;
Backend review decisions, rejection reasons, Additional Verification requirements, manual override notes and suspicious activity handling records.
3. User Declarations and Undertakings
The information submitted by the user is true, complete and accurate, and will be updated as required by the Platform.
The user’s funds, digital assets and transactions are from lawful sources and do not originate from crime, sanctioned persons, terrorist financing, scams, theft, ransomware, darknet markets, mixers or other unlawful sources.
The user does not open or trade the account on behalf of others, will not rent, lend or sell the account to others, and will not split transactions to evade regulation, sanctions screening, transaction monitoring, limits or Platform risk controls.
The user understands that the Platform may require supplementary materials, Additional Verification, source-of-funds evidence, source-of-wealth evidence, proof of address, transaction explanations or other compliance documents based on risk.
4. KYC, AML and KYT Linkage
The user understands and agrees that the Platform may use KYC identity information, AML questionnaire answers, risk tags, Additional Verification results, deposit and withdrawal records, wallet addresses, blockchain transaction hashes and counterparty information for KYT transaction monitoring, funds-flow review, blockchain address risk identification, pre-transaction, in-transaction and post-transaction risk controls, suspicious transaction identification and regulatory reporting.
KYT results may trigger transaction delays, pending deposits, withdrawal blocking, manual review, Additional Verification, account restrictions, asset freezes or reporting to competent authorities.
5. Platform Control Measures
The Platform may risk-rate users and take measures based on risk levels, including restricting deposits, withdrawals, trading, fiat deposits and withdrawals or account functions; requiring re-verification or Additional Verification; delaying transaction processing; freezing or rejecting transactions; refusing onboarding; terminating services; and filing reports or assisting investigations with CNAD, UIF, courts, law enforcement authorities, regulators or other competent authorities.
6. Suspicious Activity, Regulatory Reporting and No Tipping-Off
If the Platform determines, based on internal rules, third-party provider results, regulatory requirements or manual judgment, that user activity is suspicious, the Platform may take necessary measures and submit suspicious activity, suspicious transaction or other regulatory reports without further notice to the user.
The user understands that such reports may be subject to confidentiality or no-tipping-off requirements under law, and the Platform may be unable to disclose report content, trigger rules, processing reasons or regulatory communications to the user.
7. Travel Rule and Blockchain Risk
Where required by applicable law or Platform policy, the Platform may collect, retain, verify and transmit originator and beneficiary information required for virtual asset transfers, including name, account, wallet address, identity document or customer identification information, transaction hash and counterparty VASP information. The Platform may also conduct blockchain risk screening for deposits, withdrawals, self-hosted wallets or counterparty addresses.
8. Refusal to Authorize or Provide Information
If the user refuses to provide risk information, submits false information, refuses Additional Verification, refuses source-of-funds explanations or fails to cooperate with Platform compliance review, the Platform may refuse or restrict use of relevant services and take necessary compliance and risk-control measures.
9. Governing Law, Jurisdiction and Dispute Resolution
Unless otherwise required by mandatory applicable law, this declaration and any matters arising from AML/CFT, KYT, risk rating, transaction monitoring, Additional Verification, account restrictions, regulatory reporting or related disputes shall, in principle, be governed by the laws of the Republic of El Salvador.
If the user has any objection regarding the Platform’s risk rating, account restrictions, information requests or compliance processing, the user may first submit an appeal through the Platform’s customer support or compliance complaints channels. If the dispute cannot be resolved through consultation, it may be submitted to the competent courts or competent authorities of the Republic of El Salvador. For matters involving AML/CFT, suspicious transaction reports, regulatory investigations, law enforcement assistance or no-tipping-off obligations, the Platform may lawfully restrict disclosure of processing reasons, report content or regulatory communications.