Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy

Last Updated: October 2, 2023

1. Our Commitment to Compliance

2. Why We Have an AML/CFT Policy

As a financial service provider, ChinaitechPay has a legal and ethical obligation to prevent its platform from being used for criminal purposes. An AML/CFT policy is a set of measures designed to combat financial crimes.

Without these robust checks, our services could be exploited by criminals to launder money or finance terrorism, exposing our business and our customers to significant risk. By implementing these procedures, we ensure a secure and trustworthy environment for all legitimate users.

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3. User Identification and Verification (KYC)

A core component of our AML policy is "Know Your Customer" (KYC). If we have a reasonable suspicion that you are using our services for illicit activities, or as part of our risk-based approach, we reserve the right to suspend your transaction and request identity verification. This process may require you to provide:

• A clear copy of a valid government-issued ID (e.g., passport, ID card, driver's license).
• A selfie-photo in which you hold your ID document and state the current date.
• Additional information related to the origin of your funds, including screenshots from the sending wallet or platform, withdrawal history, and links to the transaction on a block explorer.

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4. Transaction Monitoring and High-Risk Activities

We utilize advanced analytical tools to monitor all transactions for suspicious activity. Transactions flagged with a high-risk score (typically above 50%) or linked to the following prohibited sources will trigger enhanced due diligence:

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5. Actions Taken on Suspicious Transactions

If a transaction is flagged as high-risk, the funds may be frozen by our upstream partners (e.g., cryptocurrency exchanges, payment processors) pending investigation. In such cases, ChinaitechPay acts as an intermediary and is bound by the requirements of these third parties.

The standard procedure is as follows:

1. Fund Suspension: The associated funds are immediately placed on hold pending the outcome of our investigation. We cannot process or refund funds that we do not have in our possession.
2. Enhanced Due Diligence: We will request the verification documents outlined in Section 3. You must provide this information for the investigation to proceed.
3. Regulatory Reporting: Information about suspicious activity may be shared with the relevant financial intelligence units or law enforcement authorities as required by law.
4. Fund Resolution:
   • If You Comply and Are Cleared: Once you provide the required documents and the funds are cleared by our partners, we will process a refund to the originating wallet address within 24 hours. A processing fee may be deducted.
   • If You Fail to Comply: If you fail to provide the requested information, the funds will remain frozen. A decision on their release will depend entirely on our upstream partners and potentially law enforcement. ChinaitechPay cannot influence this timeline.

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6. Our Internal Compliance Framework

ChinaitechPay maintains a robust compliance framework to uphold our AML/CFT commitments:

• AML Compliance Officer (AMLO): We have appointed a designated AMLO responsible for overseeing the compliance program, managing risk, and ensuring adherence to regulations.
• Risk-Based Approach (RBA): We assess and manage money laundering and terrorist financing risks through a dynamic, risk-based approach.
• Record Keeping: We securely maintain all necessary records, including KYC data and transaction history, for the minimum period required by law.
• Employee Training: All employees receive regular training on AML/CFT regulations, procedures, and how to identify suspicious activity.
• Confidentiality: All personal information collected as part of our AML/CFT procedures is handled in strict accordance with our Privacy Policy.