"Pay OTC365 Platform Anti-Money Laundering and Anti-Terrorist Financing User Guidelines"

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Article 1: Purpose and basis of the formulation Given that money laundering activities will seriously harm the development of digital asset transactions, encourage and breed corruption, undermine the social atmosphere, damage the legitimate rights and interests of users, undermine the foundation of the stable operation of digital asset trading platforms, and increase digital assets In order to prevent money laundering and terrorist financing activities, Huobi Group fully implements the relevant provisions of anti-money laundering and anti-terrorist financing laws, in accordance with the "Huobi Anti-Money Laundering Rules", "Client Agreement", and "Large Value Transaction Management" regarding the legal and operational risks of the trading platform. These guidelines are formulated according to company regulations such as the Measures.

Article 2: Scope of Application These guidelines apply to all users who trade on the Pay OTC365 platform (hereinafter referred to as the "OTC platform"). Users shall comply with the laws and regulations on anti-money laundering and anti-terrorism financing in the country or region where they are located, and implement the provisions of these guidelines within the scope of the laws and regulations of the region where the users are located. If the country or region where the user is located has more stringent requirements, follow its regulations.

Article 3: Anti-money laundering and anti-terrorist financing refers to the purpose of preventing criminals from transacting through the OTC platform to conceal and conceal drug crimes, organized crimes of a criminal nature, terrorist activities, smuggling crimes, corruption and bribery crimes, financial fraud crimes, and sabotage Financial management order crimes and other illegal income and the source and nature of money laundering activities, in accordance with relevant laws and Huobi anti-money laundering regulations to take relevant measures.

Article 4: Huobi Anti-Money Laundering Regulations Huobi Group’s anti-money laundering (including anti-terrorist financing, the same below) relevant rules include the "Huobi Anti-Money Laundering Rules", the anti-money laundering part of the "User Agreement", and the "Large Value Transaction" Management Measures" and this guide. If the content stipulated in this guideline conflicts with other rules, this guideline shall take precedence.

Article 5: Fundamental Principles of Anti-Money Laundering on OTC Platform The OTC platform carries out customer risk monitoring work in accordance with the following principles:
The principle of comprehensiveness. The OTC platform will comprehensively consider various risk factors that customers may be involved in money laundering, and adopt reasonable methods to monitor all customers' risks.

The principle of prudence. On the basis of fully understanding customers, the OTC platform will improve its ability to identify customers and prudently monitor customer risks.
The principle of continuity. The OTC platform will continue to pay attention to customer risks and respond appropriately according to the actual situation.
The principle of confidentiality. The customer identity information, transaction information, and risk level information held by the OTC platform are strictly confidential, and will not be provided to any unit or individual unless it is in accordance with legal regulations and regulatory requirements.
The principle of hierarchical management. The OTC platform regularly reviews the basic customer information stored according to the customer's risk level. The review of customers with higher risk levels should be stricter than the review of customers with lower risk levels.

Article 6: Submission of individual user files OTC individual users shall submit the following information and materials in accordance with the relevant provisions of Huobi Anti-Money Laundering:
Personal name
Copy of ID card or passport;
Other information or documents that should be provided upon request of OTC.

Article 7: Submission of Institutional User Documents OTC institutional users shall submit the following information and materials in accordance with the relevant provisions of Huobi Anti-Money Laundering:
Company Name;
Company registered office address;
The legal representative of the company;
The domicile of the legal representative of the company;
Business license;
A copy of the ID card or passport of the legal representative of the company;

Other information or documents that should be provided upon request of OTC.
Article 8: Review of user documents The OTC platform will verify and record the relevant information submitted by the customer in accordance with the customer identification system in the relevant regulations of Huobi Anti-money Laundering. If the OTC platform has any questions about the information submitted by the customer, it has the right Check with relevant authorities or departments.

Article 9: Monitoring of low-risk users The OTC platform will detect low-risk users according to the specific requirements of Huobi's anti-money laundering regulations, and the OTC platform reserves the right to adjust the level of low-risk users.

Article 10: Monitoring of high-risk users The OTC platform will review high-risk customers every six months to update the basic information of the customer's identity and learn about the source of funds, the use of funds, economic conditions, or operating conditions.

Article 11: Preservation of user files The OTC platform will take necessary measures in accordance with the law to store customer identity information and transaction information for a certain period of time. With reference to internationally accepted rules, user identity data should be kept for at least five years after the end of the business relationship and customer transaction information since the end of the transaction.

Article 12: Attention to users OTC users should pay attention to the following:
It is forbidden to lend the user's own account to others for use;
It is forbidden to rent or lend the user's personal ID card;
It is forbidden to rent, lend, reveal the user's own account, bank card, passbook, password and other important personal property information;
Users should actively cooperate with the OTC platform for customer identification;
When conducting transactions on the OTC platform, select and use safe and reliable third-party financial institutions for payment activities.

Article 13: Reporting of suspicious behavior If an OTC platform user discovers that any account may be engaged in money laundering or terrorist financing activities during platform transactions, the user can report to the OTC platform.

Article 14: Interpretation of the Guidelines This Guidelines is interpreted by the OTC platform.

Article 15: Effective period. These guidelines will be implemented from the date of issuance.