xmoney.hk Anti-Money Laundering (AML) & Identity Verification (KYC/KYB) Policy (V1.0)

xmoney.hk ("we," "us," or "the Platform") is committed to complying with all applicable anti-money laundering (AML), counter-terrorist financing (CFT), and related financial regulations to maintain the integrity of the Platform, protect user assets, and prevent the Platform from being used for any illicit purposes. This Anti-Money Laundering (AML) & Identity Verification (KYC/KYB) Policy (hereinafter referred to as "this Policy") outlines the principles, procedures, and controls we implement to achieve these objectives.

This Policy is an integral part of the xmoney.hk Terms of Service. All users ("you") utilizing our services must comply with this Policy.

For clarity, the following key terms are used in this Policy:

• AML (Anti-Money Laundering): Refers to the set of laws, regulations, and procedures designed to prevent, detect, and report money laundering and related financial crimes.
• CFT (Combating the Financing of Terrorism): Refers to measures aimed at preventing the flow of funds to terrorist organizations or for terrorist activities.
• KYC (Know Your Customer): Refers to the due diligence procedures we undertake to identify and verify the identity of individual users.
• KYB (Know Your Business): Refers to the enhanced due diligence procedures we undertake to identify and verify the identity, ownership structure, nature of business, and other relevant information of institutional users (such as [XM Merchant Partners]).

We implement our AML/CFT compliance program using a Risk-Based Approach. This means that the level of due diligence (KYC/KYB) required and the intensity of ongoing monitoring will be determined based on our assessment of various factors, including user type, transaction patterns, geographic risk, and other relevant considerations. We reserve the right, based on the outcome of our risk assessment, to request additional information from users or impose stricter account limitations at our sole discretion.

As a critical component of our AML/CFT compliance framework, all users must complete identity verification procedures satisfactory to us before registering or using certain features of the Service.

• 4.1. Information Collection: Depending on the assessed risk level, we will require you to provide necessary identity information.
  • For Individual Users (KYC): This may include, but is not limited to, your full name, date of birth, nationality, residential address, contact details, and a copy or image of a valid government-issued identification document (e.g., ID card, passport).
  • For Institutional Users (KYB): This may include, but is not limited to, the company's registration documents, business address, information on directors and senior management, details of beneficial owners, description of the nature of business, etc..
• 4.2. Information Verification: We will take reasonable measures to verify the authenticity and accuracy of the information you provide. This may involve:
  • Cross-referencing your information against government databases or trusted third-party identity verification services.
  • Requesting additional supporting documents (e.g., proof of address, proof of funds source).
  • In certain high-risk situations, requiring video verification or other enhanced verification measures.
• 4.3. Ongoing Monitoring and Updates: KYC/KYB is not a one-time process. We will conduct ongoing monitoring of user accounts and transaction activities. We also reserve the right to request that you periodically update your identity information to ensure it remains current and accurate.

• Providing Truthful Information: You must provide information and documents that are true, accurate, complete, and up-to-date. Providing any false or misleading information constitutes a material breach of the Terms of Service.
• Timely Updates: You are responsible for promptly notifying us and providing updated documentation if your identity information changes.
• Cooperation with Inquiries: You must cooperate when we, based on risk assessment or compliance requirements, request additional information or explanations regarding your transaction purposes or source of funds.

We employ a combination of automated systems and manual reviews to conduct ongoing monitoring of transaction activities on the Platform to detect suspicious patterns that may indicate money laundering, terrorist financing, or other illicit activities.

If we identify suspicious transactions or activities, we will, as required by applicable laws and regulations, file Suspicious Activity Reports (SARs) with the relevant financial intelligence units or law enforcement agencies. We may be prohibited by law from disclosing to you the fact that an SAR has been filed.

• Restrict Account Functionality: E.g., limiting transaction amounts, suspending specific transaction types (buy/sell), restricting the transfer or use of [X-Dollar].
• Request Additional Information: Requiring you to provide more detailed proof of identity, source of funds documentation, or other relevant information.
• Suspend Account: Temporarily freezing your account access and all activities pending investigation.
• Terminate Account: Permanently closing your account and handling any remaining assets in accordance with legal requirements (which may involve reporting to or transferring assets to regulatory authorities).
• Report to Authorities: Reporting your information and activities to relevant law enforcement or regulatory bodies.

All personal data collected in the course of implementing this Policy will be processed in accordance with the xmoney.hk Privacy Policy. The primary legal bases for collecting and using your identity information are to fulfill our legal obligations (AML/CFT compliance) and for our legitimate interests in protecting the Platform and the community from fraud and illicit activities.

We provide regular AML/CFT policy and procedure training to relevant employees. We also periodically review and update this Policy based on changes in laws, regulations, regulatory guidance, and the evolving risk profile of the Platform.

This Policy is written in English. We may provide translations into Chinese or other languages. All translated versions are provided solely for user convenience. In the event of any conflict, ambiguity, or inconsistency between the English version and any translated version, the English version shall prevail. The English version possesses final and exclusive legal binding force.

If you have any questions regarding this AML & KYC/KYB Policy, please contact our compliance department via email:

Email: compliance@xmoney.hk