SaviCoin Anti-Money Laundering and Counter-Terrorism Financing Compliance Guidelines

I. Purpose and Legal Basis

To prevent money laundering, terrorism financing, and other illegal criminal activities from adversely affecting the digital asset trading environment, to protect users' legitimate rights and interests, and to maintain the platform’s safe, stable, and compliant operations, SaviCoin has specially formulated these Anti-Money Laundering and Counter-Terrorism Financing Compliance Guidelines (hereinafter referred to as "these Guidelines").

Money laundering and terrorism financing activities may involve corruption, terrorist activities, financial fraud, smuggling, embezzlement and bribery, drug-related crimes, organized crime, tax evasion, illegal fundraising, and other serious illegal criminal acts. Such activities not only undermine financial order but may also harm the legitimate rights and interests of the platform and its broad user base.

SaviCoin will establish and continuously improve an internal compliance management system in accordance with applicable anti-money laundering, counter-terrorism financing, and sanctions compliance laws and regulations, actively identifying, preventing, and combating related illegal activities.

II. Scope of Application

These Guidelines apply to all users who register, log in, trade, deposit, withdraw, transfer assets, or use other related services on the SaviCoin platform.

When using SaviCoin platform services, users must also comply with the anti-money laundering, counter-terrorism financing, anti-fraud, anti-tax evasion, and sanctions compliance laws and regulations of their respective countries or regions.

If the laws and regulations of the user’s location impose stricter requirements on related matters, the user shall prioritize compliance with those local laws and regulations and ensure that all their operations on the platform are legal, truthful, and compliant.

III. Anti-Money Laundering and Counter-Terrorism Financing Measures

To prevent criminals from using the SaviCoin platform to conceal or disguise illegal proceeds and their sources, or to engage in terrorism financing, fraud, illegal fund transfers, and other activities, the platform will, in accordance with relevant laws, regulations, and internal compliance policies, implement measures including but not limited to the following:

1. Establishment of Customer Identification Mechanism

    The platform will identify, verify, record, and retain user identity information based on the user's risk level.

2. Implementation of KYC Review

    The platform may require users to submit identity information, identification documents, facial recognition data, proof of address, explanations of fund sources, or other necessary materials.

3. Establishment of Transaction Monitoring Mechanism

    The platform will monitor user transaction behaviors, deposit and withdrawal activities, account login behaviors, device information, IP information, and on-chain asset flows.

4. Conducting Risk Assessment and Tiered Management

    The platform will assess user risk levels based on identity, transaction behavior, fund sources, geographic location, asset scale, and characteristics of abnormal behavior.

5. Investigation and Handling of Suspicious Transactions

    If abnormal transactions, suspicious fund flows, audit evasion, frequent abnormal deposits or withdrawals are detected, the platform has the right to request supplementary information from users and take corresponding risk control measures.

6. Cooperation with Legal and Regulatory Requirements

    Under the requirements of laws, judicial authorities, or regulatory agencies, the platform has the right to lawfully submit relevant user information, transaction records, and risk reports.

Illegal activities include but are not limited to:

• Drug-related crimes

• Terrorist activity crimes

• Organized crime

• Financial fraud crimes

• Embezzlement and bribery crimes

• Smuggling crimes

• Crimes disrupting financial management order

• Illegal fundraising

• Online fraud

• Money laundering and concealment or disguise of criminal proceeds

IV. Basic Principles of Platform Anti-Money Laundering

When carrying out anti-money laundering and counter-terrorism financing work, SaviCoin will follow the following basic principles:

1. Principle of Comprehensiveness

The platform will comprehensively identify and assess user identity, transaction behavior, fund sources, login environment, on-chain asset flows, and other potential risk factors, implementing continuous risk management for all users.

2. Principle of Prudence

The platform will prudently carry out identity verification, transaction monitoring, and risk assessment based on a full understanding of customer identity and transaction purposes.

For users with incomplete identity information, abnormal transaction behavior, or unclear fund sources, the platform reserves the right to take further review measures.

3. Principle of Continuity

The platform will continuously monitor users’ risk status and dynamically adjust user risk levels and risk control measures according to transaction behavior, account status, fund flows, and external risk changes.

4. Principle of Confidentiality

The platform will strictly protect user identity information, account information, and transaction data. Except as required by laws, judicial authorities, regulatory agencies, or platform compliance reviews, user information will not be disclosed to unrelated third parties.

5. Principle of Tiered Management

The platform will implement differentiated management according to user risk levels. For high-risk users, accounts with abnormal transactions, or suspected illegal accounts, the platform will adopt stricter review, monitoring, and restriction measures.

V. User Identity Data Verification

According to SaviCoin’s anti-money laundering and risk control policies, the platform has the right to verify, record, and retain the identity information and related materials submitted by users.

Information users may be required to submit includes but is not limited to:

• Real name

• Identification card or passport information

• Contact information

• Residential address or proof of address

• Facial recognition data

• Explanation of fund sources

• Occupation or source of income information

• Explanation of transaction purpose

• Other compliance materials deemed necessary by the platform

If the platform has reasonable doubts about the authenticity, completeness, legality, or validity of the information provided by the user, it has the right to request supplementary materials, re-authentication, manual review, or to lawfully verify with relevant authorities or third-party verification agencies.

If a user refuses to provide information, submits false information, provides expired information, or fails verification, the platform has the right to restrict or suspend related services.

VI. Low-Risk User Monitoring

For users assessed as low risk, the platform will conduct routine monitoring in accordance with internal compliance policies.

Low-risk users must still comply with all platform rules and cooperate with necessary identity updates, information verification, and risk investigations when requested by the platform.

If low-risk users exhibit the following situations, the platform reserves the right to reassess their risk level:

• Significantly abnormal transaction amounts or frequency

• Abnormal deposit or withdrawal behavior

• Frequent changes of login devices or IP addresses

• Suspicious fund sources or destinations

• Involvement with high-risk regions or high-risk addresses

• Other risk situations deemed by the platform

The platform reserves the right to dynamically adjust risk levels based on actual user behavior.

VII. High-Risk User Management

For users assessed as high risk, SaviCoin will implement enhanced due diligence measures, including but not limited to:

• Regularly updating identity information

• Requiring proof of fund sources

• Requiring explanations of transaction purposes and fund uses

• Verifying user occupation, income sources, or business conditions

• Reviewing deposit and withdrawal fund flows

• Restricting certain transactions, deposits, or withdrawals

• Increasing the frequency of account transaction monitoring

• Requiring users to provide other necessary compliance materials

If the platform detects abnormal fund flows, suspected money laundering, terrorism financing, fraud, audit evasion, or other illegal activities by high-risk users, it has the right to take further risk control measures, including restricting transactions, suspending withdrawals, freezing accounts, terminating services, and reporting to relevant authorities in accordance with the law.

VIII. User Precautions

To ensure account security and compliant use, users should adhere to the following requirements:

1. Do not lend, rent, sell, or transfer your account to others;

2. Do not rent, lend, sell, or transfer identification documents, verification materials, or other identity information;

3. Do not register, verify, trade, deposit, withdraw, or transfer assets on behalf of others;

4. Do not use the platform for money laundering, terrorism financing, fraud, gambling, illegal fundraising, tax evasion, or other illegal activities;

5. Do not assist others in hiding, transferring, exchanging, or disposing of illegal proceeds;

6. Do not disclose account passwords, verification codes, Google Authenticator codes, API keys, or other important security information;

7. Ensure that identity materials submitted to the platform are truthful, accurate, complete, and valid;

8. Actively cooperate with the platform in identity verification, transaction checks, risk investigations, and compliance reviews.

If users violate the above requirements, they shall bear all resulting risks, responsibilities, and losses; the platform has the right to take corresponding measures according to the rules.

IX. Reporting Suspicious Behavior

If users discover any suspicious behaviors that may involve money laundering, terrorism financing, fraud, account hacking, illegal fund flows, or other illegal activities during their use of the SaviCoin platform, they may report through official customer service or platform compliance channels.

Reported content may include:

• Suspicious account information

• Suspicious transaction records

• Suspicious deposit or withdrawal addresses

• Descriptions of suspected fraud or illegal activities

• Relevant screenshots, chat records, or other supporting materials

Upon receiving reports, the platform will investigate and handle them in accordance with relevant laws, regulations, and internal compliance policies, and will legally protect the rights and interests of whistleblowers.

X. Platform Handling Measures

If the platform discovers users suspected of money laundering, terrorism financing, fraud, illegal fund transfers, KYC evasion, or other high-risk behaviors, it has the right to take measures based on the risk level, including but not limited to:

• Requesting users to supplement identity information

• Requesting explanations of fund sources and uses

• Suspending certain account functions

• Restricting transactions, deposits, or withdrawals

• Freezing accounts or related assets

• Canceling related transactions or earnings

• Terminating platform services

• Reporting to judicial authorities, regulatory agencies, or relevant competent departments

• Cooperating with lawful investigations and asset disposals

XI. Special Statement

1. SaviCoin reserves the right to update and adjust these Guidelines from time to time based on laws, regulations, regulatory requirements, market risks, and platform operational needs.

2. Continued use of SaviCoin platform services by users shall be deemed as having read, understood, and agreed to comply with these Guidelines.

3. These Guidelines do not constitute legal advice. If users have doubts about the legality or compliance of their own actions, they should consult professional legal advisors.

4. SaviCoin will continue to optimize its compliance system, risk control capabilities, and risk management mechanisms, striving to create a safe, transparent, compliant, and stable digital asset trading environment for users.