In order to effectively fulfill legal obligations relating to Anti-Money Laundering (“AML”) and Counter-Terrorist Financing (“CTF”), prevent the misuse of digital asset trading platforms for unlawful activities, safeguard users’ legitimate rights and interests, and ensure the stable and compliant operation of the platform, ASTX hereby formulates these Anti-Money Laundering and Counter-Terrorist Financing User Guidelines (hereinafter referred to as the “Guidelines”).
Article 1 Purpose and Legal Basis
Money laundering and terrorist financing activities seriously endanger financial order and public interests. Such activities may facilitate corruption, foster criminal conduct, disrupt market stability, and pose significant risks to the platform’s compliance operations and reputation.
ASTX establishes and maintains a comprehensive risk management framework in accordance with applicable AML and CTF laws, regulatory requirements, and internal compliance policies, with the objective of preventing, identifying, and reporting unlawful activities.
Article 2 Scope of Application
These Guidelines apply to all users who register on and use services provided by ASTX.
Users must comply with the AML and CTF laws and regulations applicable in their respective countries or regions when using the platform’s services. In the event that local laws impose stricter requirements than these Guidelines, such local laws shall prevail.
Article 3 AML and CTF Management
ASTX strictly prohibits any individual or organization from using the platform to conceal, disguise, or transfer the proceeds or nature of illegal activities. Such unlawful activities include, but are not limited to:
Drug-related crimes
Organized crime
Terrorist activities
Smuggling
Corruption and bribery
Financial fraud
Crimes disrupting financial management order
Other serious criminal activities as defined by applicable laws and regulations
To mitigate these risks, the platform shall implement measures including customer identification procedures, risk classification, transaction monitoring, anomaly detection, and suspicious transaction reporting in accordance with applicable laws.
Article 4 Fundamental Principles of AML and CTF
In conducting AML and CTF activities, ASTX adheres to the following principles:
Principle of Comprehensiveness
Risk identification and monitoring shall apply to all users, covering potential risk exposures comprehensively.Principle of Prudence
Risk assessments shall be conducted based on adequate understanding of customer identity, source of funds, and transaction behavior, with appropriate control measures implemented accordingly.Principle of Continuity
Customer risk profiles shall be subject to ongoing monitoring, and management measures shall be dynamically adjusted in response to changes in risk levels.Principle of Confidentiality
User identity information, transaction data, and risk assessment results shall be protected in accordance with applicable laws. Such information shall not be disclosed to unrelated parties unless required by law or regulatory authorities.Principle of Tiered Management
Differentiated management shall be applied based on customer risk levels, with enhanced due diligence and ongoing monitoring measures for high-risk customers.
Article 5 Customer Identification and Documentation Review
In accordance with AML customer due diligence requirements, the platform shall review, verify, and retain user identity information and related documentation.
Where necessary, the platform may verify relevant information with competent authorities or lawful institutions in accordance with applicable laws. Users shall cooperate with identity verification and due diligence procedures conducted by the platform.
Article 6 Risk Classification Management
Management of Low-Risk Customers
Customers assessed as low risk shall be subject to routine monitoring in accordance with internal policies. The platform reserves the right to adjust risk classifications based on transaction behavior or evolving risk factors.Management of High-Risk Customers
Customers assessed as high risk shall undergo review at least once every six months. Such review may include, but is not limited to:
Updating identity information
Verifying source and purpose of funds
Reviewing economic or business background
Assessing the reasonableness of transaction behavior
Where necessary, the platform may implement enhanced due diligence measures, restrict certain account functions, or apply other risk control measures.
Article 7 User Compliance Obligations
To safeguard account security and ensure compliant operations, users shall:
Not lend, transfer, or authorize others to use their accounts
Not lease, lend, or transfer identity documents or related information
Not disclose account credentials, passwords, or other sensitive security information
Cooperate with identity verification, risk reviews, and investigations conducted by the platform
If a user violates the above provisions, the platform reserves the right to take measures including, but not limited to, account restrictions, suspension of services, or termination of services in accordance with applicable laws and platform rules.
Article 8 Reporting of Suspicious Activities
Users who identify any accounts or transactions potentially related to money laundering or terrorist financing shall promptly report such activities to the platform.
The platform shall review relevant information and take appropriate action in accordance with applicable laws and regulatory requirements.
Article 9 Interpretation and Amendments
ASTX reserves the right to amend these Guidelines in accordance with changes in laws, regulatory policies, or business developments. Any amendments shall be announced through official channels, including the website.
The final right of interpretation of these Guidelines rests with ASTX.