Legal Documents

Anti-Money Laundering Ordinance

According to the definition of the Basel Committee on Banking Supervision (an international authoritative body), "money laundering" refers to the act where criminals transfer funds from one account to another through the financial system to conceal the true source and beneficial ownership of the funds, or use the fund custody services provided by the financial system to store funds.

Huanghe Holdings Strictly Complies with Anti-Money Laundering Regulations

"Know Your Customer" (KYC) Arrangements for Account Opening

To prevent criminals from opening accounts and using Huanghe Holdings for money laundering activities, the Company strictly implements "Know Your Customer" (KYC) arrangements throughout the account opening process. These arrangements not only prevent criminals from opening accounts but also protect the interests of all new clients.

New clients are required to fill out an account opening form to complete the initial identity verification. To ensure the security and authenticity of clients' identities, the Company requires all new clients to provide a copy of their ID card or passport, a copy of their bank card or bank statement, and a valid proof of address after account opening. These documents are used to verify the information provided by the client; if necessary, the Company will also make a phone call to the new client to confirm their identity. If a client fails to pass the relevant verification process, the Company will reject their account opening application.

Arrangements for Clients' Deposits, Withdrawals and Transactions

Huanghe Holdings does not accept deposits from third-party bank accounts (non-client's own accounts) or in cash. All client withdrawals must be credited to the client's own bank account to ensure the security of each withdrawal.

• If it is found that a client has deposited funds using a third-party account (non-own account) without conducting any transactions, the Company has the right to deduct 10% of all third-party deposits as a related fee, and then return the remaining amount to the depositing bank account;
• If it is found that a client has deposited funds using a third-party account (non-own account) and has conducted transactions:
  1. The Company has the right to cancel all transactions and preferential treatments (including but not limited to rebates and bonuses) caused by the third-party deposits;
  2. After deducting 10% of all third-party deposits as a related fee, return the remaining amount to the depositing bank account;
  3. The Company has the right to immediately freeze the client's account for investigation and prohibit all transactions in the account;
  4. If the Company suspects that any account manipulates prices, execution processes or the platform through any means (including but not limited to third-party transactions conducted by the client without the Company's approval), it has the right to retain the relevant rights to investigate and review the account, and may deduct the profits earned from the relevant activities from the suspected account;
  5. The Company may, at its discretion, report the relevant incident to any relevant regulatory authority or law enforcement agency.

Huanghe Holdings understands that the above arrangements may cause a certain degree of inconvenience to clients during the account opening, deposit and withdrawal processes. However, all these arrangements are not only required by regulations but also help the Company to more effectively protect the rights and interests of all clients, reduce the risk of clients' accounts being stolen by criminals, and allow all clients to enjoy the international-level investment services provided by the Company in the safest environment in the future.

As a major international financial city, Hong Kong has always imposed strict supervision on the anti-money laundering arrangements of local financial institutions. In 2012, the Hong Kong government further enacted the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance to further improve the system for combating money laundering activities and terrorist financing in the financial industry. In addition, many large international financial institutions have also formulated extremely strict internal measures and systems for preventing money laundering to protect clients' interests and fulfill corporate responsibilities.

As a financial institution registered in Hong Kong that values corporate responsibility, Huanghe Holdings not only strictly complies with the guidelines and requirements of the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance but also follows the example of other large international financial institutions to formulate rigorous internal measures and systems. It also implements a series of arrangements in the client account opening, fund deposit and withdrawal links to eliminate the possibility of being used by criminals for money laundering activities or embezzling clients' funds, thereby protecting the interests of all clients.