Article 1 Purpose and Legal Basis
In view of the fact that money laundering and terrorist financing activities may seriously undermine the development of digital asset trading, foster corruption, disrupt social order, harm users’ legitimate rights and interests, weaken the foundation of sound platform operations, and increase legal and operational risks, Hotcoin has formulated these Guidelines, in accordance with the Anti-Money Laundering Rules, User Agreement, and other relevant company policies, to effectively prevent money laundering and terrorist financing activities and to fully comply with applicable AML and CTF laws and regulations.
Article 2 Scope of Application
These Guidelines apply to all users trading on the Hotcoin P2P platform (hereinafter referred to as the “Platform”).
Users shall comply with all applicable AML and CTF laws and regulations in their respective jurisdictions and implement these Guidelines within the scope permitted by local laws. Where stricter regulatory requirements apply in a user’s jurisdiction, such requirements shall prevail.
Article 3 Definition
Anti-money laundering and counter-terrorist financing refer to activities undertaken to prevent criminals from using the Platform to conceal or disguise the source and nature of proceeds and related gains derived from illegal activities, including but not limited to drug-related crimes, organized crime, terrorist activities, smuggling, corruption and bribery, financial fraud, and offenses that disrupt financial order, and to take corresponding measures in accordance with applicable laws and Hotcoin AML policies.
Article 4 Hotcoin AML Provisions
Hotcoin’s AML (including CTF, hereinafter referred to as “AML”) framework includes the Anti-Money Laundering Rules, relevant AML provisions in the User Agreement, and these Guidelines.
In the event of any inconsistency between these Guidelines and other rules, these Guidelines shall prevail.
Article 5 Basic AML Principles for the P2P Platform
The Platform conducts customer risk monitoring based on the following principles:
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Comprehensiveness: The Platform considers various risk factors related to potential money laundering and conducts risk monitoring for all users in a reasonable manner.
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Prudence: The Platform enhances customer identification based on a thorough understanding of users and conducts risk monitoring with due diligence.
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Continuity: The Platform continuously monitors customer risks and adjusts its measures in a timely manner based on actual circumstances.
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Confidentiality: The Platform strictly safeguards customer identity information, transaction data, and risk classification information, and will not disclose such information to any entity or individual except as required by laws, regulations, or regulatory authorities.
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Tiered Management: The Platform implements differentiated management based on user risk levels and conducts stricter reviews for high-risk users.
Article 6 Submission of Individual User Information
Individual users of the P2P platform shall submit the following information and documents in accordance with Hotcoin AML requirements:
Article 7 Submission of Institutional User Information
Institutional users of the P2P platform shall submit the following information and documents in accordance with Hotcoin AML requirements:
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Company name;
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Registered business address;
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Legal representative;
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Residential address of the legal representative;
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Business license;
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Copy of the legal representative’s identification document or passport;
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Other information or documents as required by the Platform.
Article 8 Review of User Information
The Platform shall verify and record user-submitted information in accordance with the customer identification system under Hotcoin AML policies.
Where there are doubts regarding the submitted information, the Platform reserves the right to verify such information with relevant competent authorities or departments.
Article 9 Monitoring of Low-Risk Users
The Platform shall monitor low-risk users in accordance with AML requirements and reserves the right to adjust their risk classification.
Article 10 Monitoring of High-Risk Users
The Platform shall review high-risk users at least once every six months, update their identity information, and assess their source of funds, use of funds, and financial or business conditions.
Article 11 Retention of User Information
The Platform shall retain user identity information and transaction records for a required period in accordance with applicable laws.
In line with international standards, identity information shall be retained for at least five years after the end of the business relationship, and transaction records shall be retained for at least five years after the completion of the transaction.
Article 12 User Obligations
Users shall comply with the following requirements when using the Platform:
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Not lend, transfer, or otherwise make accounts available to others;
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Not rent or lend personal identification documents;
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Not disclose account credentials, bank cards, passbooks, or passwords;
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Cooperate with customer identification procedures;
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Use secure and reliable third-party financial institutions for payments.
Article 13 Reporting of Suspicious Activities
If users identify any accounts potentially involved in money laundering or terrorist financing, they may report such activities to the Platform.
Article 14 Interpretation
These Guidelines shall be interpreted by Hotcoin.
Article 15 Effective Date
These Guidelines shall take effect from the date of publication.
