Anti-Illegal Activity Policy

The “Company”, “HitBTC” does not enter into business relationships with criminals and/or terrorists and/or others illegal structures, does not transfer assets which result from criminal and/or terrorist and/or other illegal activity and does not facilitate any transfer of assets involving criminal and/or terrorist and/or other illegal activity. The Company reserves the right to implement any policies and procedures necessary to prevent all types of illegal activity and to comply with all applicable legislation in this regard.

1. Introduction

1.1. The Company Anti-Illegal Activity Policy (hereinafter - the “Policy”) is designated to prevent and mitigate possible risks of HitBTC being involved in any kind of illegal activity.

1.2. Both international and local regulations require HitBTC to implement effective internal procedures and mechanisms to prevent illegal transfer of assets, drug, human, organ and any other illegal trafficking, poaching, pornography, trade in arms, terrorism and crime financing, corruption and bribery, money laundering, and to take action in case of any form of suspicious activity from its users (a “User”).

1.3. The Policy covers the following matters:

1.3.1. Verification procedures.

1.3.2. Compliance Officer.

1.3.3. Monitoring trade activity of assets.

1.3.4. Risk Assessment.

2. Verification Procedures

2.1. One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, HitBTC establishes its own verification procedures within the standards of “Know Your Customer” frameworks.

2.2. HitBTC’s identity verification procedure requires the User to provide HitBTC with reliable, independent source documents, data or information. For such purposes, HitBTC reserves the right to collect User’s identification information for the purposes of the Policy.

2.3. HitBTC will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and HitBTC reserves the right to investigate certain Users who have been determined to be risky or suspicious.

2.4. HitBTC reserves the right to verify User’s identity on an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). The Company can identify an activity as suspicious on its sole discretion.

2.5. HitBTC reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

2.6. User’s identification information will be collected, stored, shared and protected strictly in accordance with the HitBTC’s Privacy Policy and related regulations.

2.7. Once the User’s identity has been verified, HitBTC considers itself being removed legally not liable in a situation where its Services are used to conduct illegal activity.

3. Compliance Officer

3.1. The Compliance Officer is the person, duly authorized by HitBTC, whose duty is to ensure the effective implementation and enforcement of the Policy.

3.2. It is the Compliance Officer’s responsibility to supervise all aspects of implementing the Policy including but not limited to:

3.2.1. Collecting Users’ identification information;

3.2.2. Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations;

3.2.3. Monitoring the transfer of assets and investigating any significant deviations from normal transfer activity;

3.2.4. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;

3.2.5. Updating risk assessment regularly.

3.3. The Compliance Officer is entitled to interact with competent authorities, involved in the prevention of all types of illegal activity.

4. Monitoring of Assets’ Transferring

4.1. The Users can be known not only by verifying their identity (who they are) but, more importantly, by analyzing their assets’ transferring patterns (what they do). Therefore, HitBTC relies on data analysis as a risk-assessment and suspicion detection tool. HitBTC may perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

4.2. Monitoring system functionalities may include:

4.2.1. Aggregating transfers of assets by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable.

4.2.2. Case and document management

4.3. With regard to the Policy, HitBTC will monitor all transfers of assets and it reserves the right to:

4.3.1. Ensure that transfers of assets of suspicious nature are reported to the proper competent authority through the Compliance Officer;

4.3.2. Request the User to provide any additional information and documents in case of suspicious transfers of assets;

4.3.3. Suspend or terminate User’s Account when HitBTC has a reasonable suspicion that such User engaged in illegal activity.

4.4. The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

5. Risk Assessment

5.1. The Company, in line with the international requirements, has adopted a risk-based approach to identify and combat against an illegal activity. By adopting a risk-based approach, HitBTC is able to ensure that measures to prevent an illegal activity are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

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