AML Policy

Guidance for Anti-money Laundering, Anti-illegitimate Funds; Procedures of Unblocking Bank

Accounts

Anti-money laundering (AML) is a broad term for laws and regulations put in place to prevent criminals

from making money illegally or moving illicit funds. While many illegal activities are targeted by AML

laws, some of the most important are tax evasion, public corruption, and market manipulation through

methods such as wash trading.

Many governmental institutions and pieces of legislation play roles in establishing AML requirements. In

the US, agencies like the Securities and Exchange Commission (SEC) and the Commodity Futures Trading

Commission (CFTC) provide general information and resources for broker-dealers, and futures

commission merchants to set AML standards.

Laws that have contributed to anti-money laundering requirements in the United States include the

Bank Secrecy Act of 1970, the Money Laundering Control Act of 1986 and the USA PATRIOT Act of 2001.

While in Canada, similar ACT also introduced by FINTRAC and is regulated for the MSB registration.

Owing to the complexity of the relevant laws, many financial institutions use AML software to detect

questionable activity. These software solutions perform functions that range from checking customer

names against government lists of prohibited users to generating records that are necessary for

maintaining compliance.

AML is tightly linked to Know Your Customer (KYC) requirements, which essentially involve verifying

customers' identities and the sources of their income. KYC also requires financial institutions to monitor

their users' activity on an ongoing basis. Like AML, modern KYC procedures are heavily automated, and

many institutions use the client onboarding process as an opportunity to acquire proper identification

from new customers.

AML programs are also relevant to the cryptocurrency space. Many cryptocurrency exchanges have

made concerted efforts toward compliance with anti-money laundering laws as regulators started to

place more focus on the cryptocurrency market. Still, there is some criticism toward KYC and AML

requirements within the crypto space, as critics argue that compliance decreases their privacy and

nullifies the benefits of decentralization by placing sensitive personal data in centralized databases.

Proponents, however, argue that solutions can be devised that will meet regulatory requirements while

still ensuring user privacy.

One interesting trend relating to AML and KYC compliance in the cryptocurrency ecosystem is the

willingness of many exchanges to self-regulate, even when they do not fall within the purview of existing

regulatory guidelines. In some cases, companies have even banded together to form industry bodies

aimed at creating frameworks for self-regulation. This kind of voluntary compliance both minimizes

future legal risks for the crypto-related businesses and also improves the likelihood of wider adoption of

cryptocurrency.

In ZKE Exchange, have registered and will be registering to corresponding government agencies to follow

strictly to all the local AML laws and regulations.

I. How to avoid illegitimate funds, and prevent your bank accounts from being frozen?

ZKE Exchange reserves the right to take actions to ensure that users can trade with security. Money

laundering will dramatically impair the development of digital token transactions, encourage and breed

corruption, degrade social conducts, damage users' legitimate rights and interests, weaken the

foundation for the operation of the digital token trading platform, and increase corresponding legal and

operational risks. Therefore, ZKE Exchange will guide users and will follow the following rules, to prevent

illegitimate funds to be introduced to the platform. Users will be held accountable for their activities on

the platform and need to make sure to follow the rules and to understand that they are part of the antimoney launder action.

1.When you are in fiat tradings, make sure not to accept transactions from a different person other than

your trading counterparty. If you receive payments from different people, please refund to the same

source.

2.If you receive payment with sensitive references as “crypto”, “Bitcoin”, etc, you can filter the

transaction or refund, and note with “unidentified reference”. You will reduce the risks of being

surveilled or bank accounts being frozen.

3.Use different cards for paying and receiving. Use multiple of your own bank cards for buying and

selling. Because the transaction receiving card has a higher risk of being frozen, therefore it is advisable

to filter the incoming funds and transfer them to another safer card. The card you use to receive funds

must be the same card that is bonded with the platform.

4.Do not hold large funds in your frequently used cards. You should filter and withdraw your funds once

in a while, and stop using this card for a period of time. This way you can protect yourself from being

contaminated by illegitimate funds.

5.Before you reuse an old card, you should always check first that if this card can receive funds or make

payments.

6.The platform verifies users’ IDs when they register. Users shall make sure that all related accounts are

registered and used by the person himself/herself. ZKE Exchange will not take any responsibility if the

user violates Terms of Use, Policies, government laws, or involves in illegal activities. ZKE Exchange will

assist police with investigations when necessary.

II. How to filter your funds?

1.After receiving payments, you can transfer the funds to your Financial Management accounts which

has a large lump sum. Then you can filter the funds out and transfer them to a secured bank account.

2.If your received fund amount is not big, you can withdraw it to cash, then deposit it to another

secured bank account.

III. Procedures of unblocking bank accounts

The account could be frozen by your bank or due to legal issues.

1.Bank freeze

a. Reasons: frequent high volume transactions; frequent transactions with too many people; no credit

balance or transaction histories for a long period of time; transactions with sensitive references. These

actions above would trigger banks’ risk control systems or anti-money laundering systems. Normally the

account online systems would show information such as “non-face to face operations are paused”,

“receiving only” etc..

b. If your card is frozen due to the reasons above, you can check with your bank and provide the

required information to unblock your account.

2.Due to legal issues

a. It is a more difficult situation if your card is frozen due to legal issues. Normally it is related to financial

fraud cases. The length of frozen could be anywhere between 3 days to half a year or even longer. For

example, if the illegitimate fund being transferred through five accounts, all five accounts would be

frozen. Furthermore, this type of frozen wouldn’t occur right after the transaction, it would happen a

couple of days after the transaction. It depends on when would victims file a case with the police and

when the case would be investigated.

b. If it’s just temporary frozen for a few days, your card/bank account would be defrosted after a few

days as long as you coordinate with authorities with their investigation.

If it’s a longer frozen such as half a year, you need to contact your bank as soon as you can to clarify

when was it frozen, how long would it be frozen, the contact information of the local authorities which

froze your card. Once you have the above information, you need to contact the party who frozen your

card and coordinate the investigation.

3.Notes:

a. Supporting information: most likely you will be asked to provide the source of income, trading details.

You can find these under “Account management” - “Trading history”.

b. If you require ZKE Exchange to provide you with supporting documents, you must advise the local

authority to provide Proof of Evidence or Judicial Decisions or have the authority to contact us directly:

[email protected]

c. The process varies depends on the location you are at and the complication of the case. Once your

card is defrosted, please make sure that you withdraw funds to avoid being frozen again.