Introduction

PayZila acknowledges the critical threat that money laundering poses to digital asset trading, promoting corruption, eroding social integrity, and violating user rights. To combat this, PayZila has established comprehensive Rules to prevent money laundering and terrorist financing, adhering to all relevant regulations. These Rules are founded on the User Agreement of the PayZila Website, the User Agreement of the PayZila APP, and other relevant documentation.

Scope of Application

These Rules apply to all users trading on the PayZila website and the PayZila APP (collectively, "the Platform"). Users must comply with anti-money laundering (AML) and anti-terrorist financing (CTF) laws and regulations in their respective countries or regions. Stricter requirements in the user's location will take precedence.

Combating Money Laundering and Terrorist Financing

PayZila's measures to prevent money laundering address crimes related to narcotics, organized crime, terrorism, smuggling, graft, bribery, financial fraud, and financial regulation breaches. The Platform's anti-money laundering framework includes these Rules, relevant sections in the User Agreements, Measures for the Management of Large-sum Transactions, and the OTC Platform Guidelines for Users.

Basic Principles

The Platform monitors user risks based on principles of comprehensiveness, prudence, sustainability, confidentiality, and hierarchical management.

Responsible Body

The Platform manages anti-money laundering operations through a guidance group and an anti-money laundering team, composed of members from the risk control and compliance departments.

Responsibilities of the Responsible Body

The guidance group plans, guides, and coordinates anti-money laundering efforts, while the team implements policies, analyzes suspicious transactions, assesses user risk levels, and reports to authorities.

Due Diligence

The Platform conducts thorough due diligence on all users, with enhanced due diligence for high-risk users.

Required Documents for Users

Individual Users: Must provide personal information, including name, address, date of birth, nationality, contact information, a recent photo, and identity documents.

Institutional Users: Must provide details such as the institution's name, address, contact information, articles of association, equity structure, legal representative's information, business license, and account opening consent.

Document Language and Verification

Documents must be submitted in Chinese or English, or translated and notarized if in another language. Copies must be checked against the original, notarized, and certified.

Photograph-based Verification

Users must provide a photograph holding their identity document and a statement confirming their account opening with PayZila.

Identification of Beneficial Owners

PayZila identifies the actual or beneficial owner or controller of user accounts.

Third-party Authentication

Third-party institutions authenticating user identity must meet stringent requirements, including measures for user identification and data storage.

Review of User Documents

PayZila diligently verifies user information submitted during registration and transaction activities. This involves examining identification documents and utility bills. Users may be asked for additional documentation to comply with AML/CTF regulations.

User Risk Classification

Users are categorized into different risk levels based on transaction behavior, geographical location, and other factors. This classification helps apply appropriate measures to mitigate risks associated with money laundering and terrorist financing.

Identification of High-risk Users

High-risk users are identified based on criteria such as being under criminal investigation, holding prominent public positions, residing in high-risk jurisdictions, operating in high-risk industries, or exhibiting unusual transaction patterns. These users undergo enhanced due diligence.

Identification of Low-risk Users

Low-risk users include established financial institutions, reputable companies, and individuals with a history of compliant behavior. These users are subject to standard due diligence procedures.

Identification of Medium-risk Users

Medium-risk users fall between low-risk and high-risk categories and may require additional scrutiny due to certain characteristics or transaction patterns.

Adjusting Risk Levels

User risk levels are regularly reviewed and adjusted based on changes in user behavior or circumstances to ensure a dynamic and responsive risk management approach.

Monitoring High-risk Users

High-risk users undergo continuous monitoring to detect and prevent potential illicit activities. This proactive approach allows the Platform to identify suspicious behavior and take appropriate action.

Ongoing User Identification

The Platform conducts ongoing user identity verification to maintain a secure and compliant environment.

Re-identification of Users

Users may need to undergo re-identification if there are changes in personal information or suspected involvement in illicit activities.

Trading Limits

The Platform establishes trading limits, including maximum withdrawal amounts, to prevent money laundering and terrorist financing activities. These limits ensure the safety and integrity of the Platform's services.

Suspicious Transactions Identification

The Platform actively monitors transactions for signs of suspicious activity, such as large or frequent transactions, unusual patterns, or involvement of high-risk jurisdictions. Suspicious transactions are promptly investigated and reported.

Detecting Terrorist Financing

The Platform implements measures to detect and prevent terrorist financing. This includes monitoring for indicators and reporting suspicious activities to authorities.

Handling Suspicious Conduct

If users refuse to provide valid information or engage in suspicious behavior, the Platform may suspend transactions, freeze accounts, or report such conduct to authorities.

Data Storage System

The Platform maintains a secure system for storing user identity information and transaction records, ensuring compliance with regulatory requirements.

Data Storage Scope and Term

User identity information and transaction records are stored securely for a minimum of five years to comply with audit and regulatory requirements.

Assistance to Judicial Investigations

The Platform cooperates fully with judicial, law enforcement, and competent authorities, providing necessary information and materials for investigations.

Confidentiality

The Platform enforces strict confidentiality for all staff regarding user identity information, suspicious transactions, and related information.

User Cautions

Users are reminded not to share their accounts, identity certificates, or personal information with others and to cooperate fully with the Platform in user identification processes.

Reporting Suspicious Conduct

Users are encouraged to report any suspicious activities encountered during trading to help maintain a secure environment.

Interpretation and Enforcement

These Rules are interpreted and enforced by the Platform to ensure compliance with AML/CTF regulations and maintain service integrity.

Effective Date

These Rules are effective immediately upon promulgation, ensuring all users are subject to the same standards and requirements for AML/CTF compliance.