Anti-Money Laundering Policy

Scope: This Anti-Money Laundering Policy (the “Policy”) applies to the ZKE Exchange website, app, H5 pages, APIs, and related services (collectively, the “Services”) operated by ZKE Global Limited and its affiliates (collectively, “ZKE”, “we”, “us”, or the “Platform”).

This Policy, together with the Service Agreement, Privacy Policy, Risk Disclosure, fee schedules, and any other rules/announcements published by the Platform from time to time, forms part of the binding terms governing your use of the Services. In case of conflict, the more specific or later-issued product terms/rules shall prevail.

1. Purpose and Core Principles

1. This Policy is intended to prevent and combat money laundering, terrorist financing, sanctions evasion, and other financial crimes, and to safeguard the Platform and users.
2. We implement reasonable measures based on applicable laws and compliance requirements, and adopt a risk-based approach to customer due diligence, ongoing monitoring, risk controls, record retention, and cooperation with competent authorities.
3. You acknowledge and agree that, for compliance and security purposes, we may review, restrict, suspend, or delay certain account activities and transactions, and we may require you to provide additional information or documentation.

2. Key Definitions (Summary)

For ease of reference, the following terms include but are not limited to:

• AML/CFT: Anti-money laundering / counter-terrorist financing measures and requirements.
• KYC: Know Your Customer (customer identification and verification).
• Sanctions/Restrictive Measures: Restrictions imposed by relevant governments or international bodies, which may involve certain jurisdictions, entities, individuals, assets, or activities.
• Suspicious Activity: Abnormal fund flows, inconsistencies in identity information, attempts to evade monitoring, or indications linked to illegal activities, among others.

3. Customer Due Diligence (KYC) and Information Requirements

1. Obligation to Provide Information You must provide true, accurate, complete, and up-to-date identity information and verification materials as required by the Platform, and promptly update such information if it changes.
2. Tiered Verification and Service Limitations The Platform may apply different KYC levels and requirements for different products, features, and limits. If your account does not meet the required level, certain features may be unavailable or subject to limitations.
3. Enhanced Due Diligence (EDD) In higher-risk situations (including but not limited to large or unusual transactions, triggered risk indicators, sanctions/PEP hits, or requests from competent authorities), we may require additional information or supporting documents, such as source of funds (SoF), source of wealth (SoW), purpose of transactions, bank statements, proof of address, or other evidence, to the extent lawful and necessary.
4. Consequences of Refusal or Non-Cooperation If you refuse, fail, or do not timely cooperate with KYC/EDD requests or explanations, we may impose restrictions, suspend certain functions, or terminate Services in accordance with Section 6.

4. Ongoing Monitoring and Sanctions Screening

1. To identify and mitigate financial crime risks, we may continuously monitor account activities and transaction patterns, deposits/withdrawals, fiat-related activities (if applicable), and security signals (including device and login risks), using automated tools and/or manual reviews.
2. We may conduct sanctions screening and politically exposed person (PEP) screening based on user information and other lawful sources, and may take necessary measures based on screening results.
3. We may restrict or prohibit access to some or all Services for users in certain jurisdictions or for sanctioned/restricted persons or entities, in accordance with applicable laws, Platform rules, and announcements.

5. User Representations and Prohibited Conduct

1. Lawful Source of Funds You represent that funds and digital assets used for deposits, trading, or withdrawals on the Platform are from lawful sources and are not derived from any illegal activity.
2. Strictly Prohibited Conduct (including but not limited to):
   • Money laundering, terrorist financing, sanctions evasion, fraud, bribery, tax evasion, illegal fundraising, payment laundering/“mule” activities, or similar conduct;
   • Structuring/splitting transactions, circular transfers, unusually frequent small transactions, multi-account schemes, or other attempts to evade monitoring;
   • Using false identities, forged documents, impersonation, or stolen identities/accounts;
   • Using the Platform as a conduit for third-party fund transfers, “pass-through” payments, or to conceal the origin/destination of funds;
   • Any conduct that violates applicable laws, regulatory requirements, or Platform rules.
3. If you (or your affiliates/beneficial owners, where applicable) engage in the above conduct, the Platform may take measures described in Section 6 and may cooperate with investigations or lawful requests.

6. Risk Control and Compliance Measures (Our Rights)

Where we reasonably determine that compliance or security risks exist (including but not limited to KYC/AML requirements, suspicious activity, abnormal transactions, account compromise risks, sanctions/PEP matches, lawful requests from competent authorities, or Platform rule requirements), we may take one or more of the following measures:

1. Require you to supplement or update KYC/compliance information and provide explanations;
2. Restrict or suspend certain account functions (including deposits, trading, withdrawals, and API access);
3. Delay processing of transactions or withdrawals for compliance review;
4. Freeze accounts or related assets to the extent permitted by applicable law;
5. Disqualify participation in campaigns, refuse to issue rewards/commissions, or claw back rewards where applicable;
6. Terminate Services and close accounts;
7. Make reports to competent authorities or cooperate with investigations where required or permitted by law.

You acknowledge that, for compliance and security reasons, we may not be able to disclose the details of our risk controls, review logic, or specific thresholds.

7. Record Retention and Information Disclosure

1. We retain necessary records in accordance with applicable laws and compliance needs, including (where applicable) KYC records, transaction records, and risk handling records.
2. We may disclose necessary information and take relevant restrictive measures when required to comply with lawful and valid requests from regulators, law enforcement, courts, or other competent authorities, or to fulfill legal obligations.
3. Our processing and protection of personal information is governed by the Privacy Policy.

8. Fiat-Related Activity and Banking Risk Reminders (User Guidance)

If you use fiat-related services (including third-party payment channels, OTC/fiat trading, or similar features, if applicable), you understand that banks and payment institutions may review, restrict, or freeze accounts based on their internal risk policies. To reduce misunderstanding and support compliance communications, you may consider:

1. Keeping order screenshots, payment receipts, platform transaction logs, and relevant communications;
2. Avoiding patterns that commonly trigger bank risk controls (e.g., unusually high frequency, concentrated large payments, frequent transactions with numerous unfamiliar counterparties);
3. Providing truthful explanations and relevant proof if questioned by a bank or payment institution;
4. Following your local laws and the applicable bank/payment institution rules.

This guidance is general information only and does not constitute legal, financial, or banking advice.

9. Account Restrictions/Freezes and Support (If Applicable)

1. If your bank or payment account is restricted/frozen, contact the bank/payment institution first to understand the reason and required documents.
2. If you need Platform assistance with records or statements that the Platform can provide, contact: support@zke.com.
3. To protect privacy and ensure compliance, we generally provide assistance only where permitted under Platform rules and applicable law, and/or upon receipt of valid legal documentation or lawful requests.

10. Updates and Interpretation

1. We may update this Policy from time to time due to changes in laws, regulatory requirements, or business operations, and will notify you via announcements, in-app messages, pop-ups, or other reasonable means. Continued use of the Services after the effective date constitutes acceptance.
2. If this Policy is available in multiple languages, the English version shall prevail in case of conflict (unless the Platform explicitly states otherwise).

11. Contact

If you have questions about this Policy or compliance requirements, contact: support@zke.com