IntlCOM

Anti-money laundering, anti-terrorist financing, anti-tax evasion

Internal Control System

 

Chapter 1 General Provisions

  1. This system is formulated in accordance with the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances, the United Nations Convention against Transnational Organized Crime, the United Nations Convention against Corruption and the International Convention for the Suppression of the Financing of Terrorism and other relevant laws and regulations in order to prevent illegal and criminal activities against money laundering, terrorist financing and tax evasion (hereinafter referred to as the Three Antis) through the IntlCOM (hereinafter referred to as the Exchange), ensure the legal operation of the Exchange, effectively prevent and control the Three Antis compliance risks, and conscientiously fulfill the Three Antis international social responsibilities.
  2. Anti-money laundering as referred to in this system refers to the practice of an exchange formulating and implementing a series of preventive measures in order to prevent money laundering activities that use financial means to cover up and conceal the source and nature of drug crimes, organized crimes of a mafia nature, terrorist activities, smuggling crimes, corruption and bribery crimes, crimes that disrupt financial management order, financial fraud crimes, and other criminal proceeds and their proceeds as defined by regulators.

Anti-terrorist financing as referred to in this system refers to the act of formulating and implementing a series of preventive measures by the Exchange in order to prevent the criminal activities of providing funds to organizations or individuals engaged in terrorist activities through financial means, or helping organizations or individuals engaged in terrorist activities to raise, manage or transfer funds.

Anti-tax evasion as referred to in this system refers to the practice of the exchange formulating and implementing a series of preventive measures in order to prevent taxpayers from deliberately underpaying or failing to pay taxes by means of deception, concealment, forgery, counterfeiting, etc.

The "three anti-compliance risks" referred to in this system refer to the risks of legal sanctions, regulatory penalties, major financial losses, and reputational losses caused by exchanges and employees failing to strictly fulfill their legal obligations and duties under the "three anti-compliance" regulations.

  1. The Exchange's three-anti work shall follow the following principles:
  1. Principle of compliance with laws and regulations. Strictly abide by the anti-money laundering laws, regulations and regulatory requirements of the United Nations and international anti-money laundering organizations, and comply with the anti-money laundering rules and regulations of the exchange.
  2. Risk-based principle. Scientifically assess the three anti-corruption risks faced by the exchange, reasonably allocate three anti-corruption resources according to the size of the three anti-corruption risks, give priority to investing limited three anti-corruption resources in business areas with higher risks, and adopt simplified prevention and control measures for business areas with lower three anti-corruption risks to improve the effectiveness of the three anti-corruption work.
  3. Principle of full participation. The three anti-corruption activities are the obligations of all employees. Every employee of the Exchange shall be responsible for the three anti-corruption activities and shall take the initiative to do a good job in the three anti-corruption activities within the scope of their unit and job responsibilities.
  4. Principle of maintaining confidentiality. The Exchange and its personnel must strictly abide by the "Three Antis" confidentiality discipline, safeguard the "Three Antis" commercial secrets and information security, and prevent the "Three Antis" leaks.
  1. The goal of the Exchange's "Three Antis" work is to establish and improve a unified "Three Antis" compliance risk management framework that is compatible with the "Three Antis" regulatory requirements and the Exchange's development strategy, so as to achieve effective identification, assessment, monitoring, control and reporting of "Three Antis" risks and effectively prevent and control "Three Antis" compliance risks .

 

Chapter 2 The Organizational Structure and Division of Responsibilities of the Three Antis

  1. According to the three anti-management objectives of the Exchange, a three anti-management working group is established. Each department performs its duties and responsibilities, and jointly manages the organizational management system of the three anti-management work.

The team leader is the general manager, the deputy team leader is the deputy general manager, and the team members are the heads of the market development department, transaction settlement department, system operation and maintenance department, risk control department, finance department, and clearing department.

The head of the anti-corruption working group shall perform the following duties:

  1.   Coordinate and deploy the three anti-corruption work of the exchanges and implement the three anti-corruption supervision requirements.
  2. To study and decide on the Exchange’s major decisions and important matters concerning the “three antis”, and coordinate the resolution of important issues in the “three antis” work.
  3.   Review and determine the Exchange's anti-corruption, anti-violating and anti-smuggling management procedures to ensure the normal operation of the anti-corruption, anti-violating and anti-smuggling management system.
  4. Provide the necessary resources to support the Exchange's anti-corruption, anti-money laundering and anti-corruption work, and grant anti-corruption, anti-money laundering and anti-money laundering management personnel and staff the necessary authorization to perform their duties.

The main responsibilities of the Three Antis Working Group members include:

  1.   Research, formulate and rationalize the division of tasks, and organize the implementation of the "three anti-regulatory" supervision requirements.
  2. Responsible for reporting of large and suspicious transactions of customers.
  3. Analyze and report suspicious transaction reports from exchanges.
  4. Take the lead in the exchange's anti-corruption, anti-money laundering and anti-corruption confidentiality management work; be responsible for internal and external anti-corruption information exchange.

 

Chapter 3 Identification and Reporting of Large-Value and Suspicious Transactions

  1.  During the trading process of the Exchange, if any employee discovers or has reasonable reasons to suspect that a transaction or a trader is suspected of "three anti-criminal activities" during the circulation process, he shall promptly report it to the Exchange's "three anti-criminal activities" leading group. The "three anti-criminal activities" leading group will analyze, identify and confirm that the suspicious transaction is a violation of regulations, form a written report and send it to the customer for early warning. The customer must submit a statement of the situation to the Exchange within 10 days.

If the reasons given by the client are not sufficient to dispel doubts, the exchange will submit a suspicious transaction report to the international anti-money laundering organization within 5 working days after receiving the explanation. At the same time, the exchange reserves the right to freeze the funds of traders, recover the transaction fees from traders and return them preferentially, and recover the transaction fees and commissions from investment agents at all levels.

  1. The anti-counterfeiting, anti-money laundering and anti-corruption working group shall provide true, complete and accurate transaction information and prepare large-value transaction reports and suspicious transaction reports in accordance with the requirements for large-value transaction and suspicious transaction reporting elements.
  2. The following transactions or behaviors shall be reported as suspicious transactions:
  1. A customer who has no transactions or a small transaction volume requests to transfer a large amount of funds to another person's account without any obvious transaction purpose or use;
  2. Buying and selling a large amount of goods in a short period of time after opening an account, and attempting to withdraw funds quickly after the transaction is completed;
  3. The trading account has been idle for a long time, but large-amount payments are frequently made in the capital account;
  4. The client does not conduct transactions for a long period of time or conducts very few transactions, but a large amount of expenditure occurs in his/her capital account;
  5. A long-term idle account is suddenly activated and a large number of transactions occur;
  6.   An account that has not traded for a long time suddenly trades frequently for unknown reasons within a short period of time, and the amount of funds involved is huge;
  7. The Client frequently opens a position at one price and then opens an opposite position at the same or approximately the same price and with the same amount for the same spot contract as the underlying, and attempts to withdraw funds quickly;
  8. The client's trading behavior involves buying high and selling low;
  9.   When the client, as the seller of a spot transaction, delivers imported goods, it fails to provide complete goods-related information;
  10.   The client has business dealings with high-risk areas of the three anti-epidemics;
  11. The client is under criminal investigation by judicial authorities, or is associated with a list of persons involved in terrorism;
  12.   The client requests to change his/her information but the relevant documents and materials he/she provides are suspected of being forged or altered;
  13. The client conceals its actual controller.

 

Chapter 4 Preservation of Customer Transaction Records

  1. Preservation of customer transaction records means that institutions at all levels should properly preserve data information, business vouchers, account books and other relevant materials reflecting each transaction of customers within the prescribed period.
  2. All departments and relevant positions shall properly keep customer transaction records in accordance with the principles of security, accuracy, completeness and confidentiality to ensure that sufficient attention is paid to each transaction so as to provide the information required for monitoring and analyzing transaction conditions, investigating suspicious transaction activities and investigating and handling three anti-corruption cases.

The transaction records that should be kept include: data information, business vouchers, account books about each transaction, and contracts, business vouchers, documents, business letters and other materials that reflect the actual transaction situation as required by relevant regulations.

  1. Customer transaction records shall be kept for the following periods:
  1. Transaction records shall be kept for at least 1 years starting from the year in which the transaction is recorded.
  2. To facilitate case investigation, fund monitoring, anti-corruption, anti-money laundering and anti-corruption supervision and internal audit, records of work related to reviewing abnormal transactions, identifying and analyzing suspicious transactions, and internal processing of suspicious transaction report information should be kept for at least 1 years.

If customer transaction records involve suspicious transaction activities that are under investigation and the investigation has not been completed at the expiration of the minimum retention period specified in the preceding paragraph, they should be retained until the completion of the "three-anti" investigation.

  1. Where customer transaction records with different retention periods are stored on the same medium, the longest retention period shall be used. Where the same customer transaction record is stored on different media, at least one medium of customer transaction record shall be kept in accordance with the above-mentioned retention period requirements.

If laws, administrative regulations and other rules require a longer retention period for customer transaction records, such provisions shall be complied with.

  1. Necessary management and technical measures shall be taken to prevent the loss or damage of customer transaction records and the leakage of customer transaction information.

 

Chapter 5 Three-Anti Training Measures

  1. Actively carry out the "Three Antis" publicity and training work to create a good atmosphere for the "Three Antis" work. Through various forms and means, let the company's employees understand the characteristics of the "Three Antis", international "Three Antis" policies and the results of combating the "Three Antis" activities.
  2. Strengthen the division of labor and cooperation among departments in the "three anti-counterfeiting" and "anti-dumping" activities, establish a "three anti-counterfeiting" supervision system in which "risk control, market development, transaction settlement, system operation and maintenance, clearing, finance and other departments participate in coordination and cooperation", refine the definition of relevant departments, and overcome the bottlenecks encountered by the "three anti-counterfeiting" administrative departments in the process of seeking assistance and cooperation; at the same time, specify the scope of the "three anti-counterfeiting" responsibilities of the relevant departments, and effectively enhance the enthusiasm of departmental cooperation.

 

Chapter 6 Assisting in Three-Anti Investigations and Accepting Three-Anti Supervision Inspections

  1. he Exchange shall cooperate with the anti-three-anti investigation supervision agencies and competent authorities in accordance with the law to carry out anti-three-anti investigation work. The anti-three-anti investigation assistance work shall be led by the anti-three-anti working group. Those who refuse to provide investigation materials or deliberately provide false materials shall bear corresponding legal responsibilities in accordance with the law.
  2. Those who fail to perform their duties conscientiously and cause the omission of major anti-three-anti clues, violate the anti-three-anti confidentiality regulations, etc. will be held accountable in accordance with the relevant regulations.

 

Chapter 7 Supplementary Provisions

  1. Any matters not covered in this system shall be implemented in accordance with relevant international laws and regulations. The Exchange's Anti-Three-Anti Working Group is responsible for interpreting this system.
  2. These Measures shall enter into force on the date of promulgation.

IntlCOM

13th November 2024