Icoin Anti-Money Laundering and Counter-Terrorist Financing User Guidelines

I. Purpose and Legal Basis

In order to prevent the adverse impact of money laundering and terrorist financing activities on the digital asset trading environment, protect the legitimate rights and interests of users, and maintain the stable operation and compliant development of the platform, Icoin hereby formulates these Guidelines.

Money laundering and terrorist financing activities may involve corruption, terrorist activities, financial fraud, smuggling, embezzlement, bribery, and other serious illegal and criminal acts.

Icoin will, in accordance with applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations, establish and continuously improve its internal compliance system, and actively prevent and combat related illegal activities.

II. Scope of Application

These Guidelines apply to all users who register and use services on the Icoin platform (hereinafter referred to as the “Platform”).

When using the Platform’s services, users shall also comply with the anti-money laundering and counter-terrorist financing laws and regulations of their country or region.

If the laws and regulations of the user’s local jurisdiction impose stricter requirements, the user shall give priority to complying with the laws of their place of residence.

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

To prevent criminals from using the Platform to disguise or conceal illegal proceeds and their sources of income, Icoin will, in accordance with relevant laws and internal compliance policies, adopt measures including but not limited to the following:

1. Establishing a customer identity verification mechanism (KYC)

Implementing transaction monitoring and risk identification mechanisms

Conducting ongoing risk assessments and tiered management

Investigating and handling abnormal transaction activities

2. Illegal activities involved include but are not limited to: drug-related crimes, terrorist activities, organized crime, financial fraud, corruption and bribery, and acts disrupting financial management order.

IV. Basic Principles of the Platform’s Anti-Money Laundering Program

When carrying out AML and CTF work, Icoin adheres to the following basic principles:

1. Comprehensiveness Principle:

Comprehensively identify and assess various potential risk factors and implement risk management for all users.

2. Prudence Principle:

Conduct risk identification and monitoring prudently based on a full understanding of customer identity and transaction behavior.

3. Continuity Principle:

Maintain continuous attention to user risk and dynamically adjust risk control measures according to actual circumstances.

4. Confidentiality Principle:

Strictly protect user identity information and transaction data. Except as required by laws, regulations, or regulatory authorities, no disclosure will be made to irrelevant third parties.

5. Tiered Management Principle:

Implement differentiated management based on risk levels, and apply stricter review measures for high-risk users.

V. Review of User Identity Information

In accordance with Icoin’s AML policy, the Platform will verify, record, and retain the identity information and relevant documents submitted by users.

If there is reasonable suspicion regarding the authenticity, completeness, or legality of the information provided by the user, the Platform has the right to request supplementary materials for further verification, and may conduct checks with the competent authorities in accordance with the law.

VI. Monitoring of Low-Risk Users

The Platform will classify users based on risk levels and conduct monitoring at an appropriate frequency for low-risk users.

At the same time, the Platform reserves the right to adjust a user’s risk level based on changes in transaction behavior.

VII. Management of High-Risk Users

For users assessed as high-risk, the Platform will conduct enhanced reviews on a regular basis, including but not limited to:

• Updating identity information

• Understanding the source and purpose of funds

• Verifying economic conditions or business operations

If abnormal circumstances are identified, the Platform has the right to take further risk control measures.

VIII. User Precautions

To ensure account security and compliant use, users should pay attention to the following:

1. Users must not lend, lease, or transfer their accounts for use by others;

2. Users must not lease, lend, or transfer identity documents;

3. Users must not disclose account passwords, verification codes, or other important information;

4. Users should actively cooperate with the Platform in identity verification and risk investigations.

IX. Reporting of Suspicious Activities

If users discover any suspicious activities that may involve money laundering or terrorist financing during the use of the Platform, they may report them through official customer service or compliance channels.

The Platform will investigate and handle such reports in accordance with relevant laws and internal policies.

Icoin will continue to optimize its compliance system and risk management mechanisms, and is committed to creating a