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Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy

The MyEthShop (a.k.a. “MES”) AML/CFT Policy is designed to ensure that we comply with the requirements and obligations set out in Hong Kong and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards, which must be complied with by MES and employees and includes:
• Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to MES;
• Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;
• Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
• Procedures for reporting suspicious fraudulent use of identification documents to the relevant law enforcement authorities as appropriate;
• The maintenance of appropriate records for the minimum prescribed periods;
• Training and awareness for all relevant employees;
• And the provision of appropriate management information and reporting to senior management of the Group's compliance with the requirements.
• MES may require its clients to provide additional information or documentation to fulfill our legal obligations and where it deems appropriate refuse any client or transaction that is suspected of being related to financial crime.
The MES AML and KYC policies are as follows:
• Customers trading ETH via the MES trading platform will be subject to our internal AML transaction monitoring.
• Identity documents (e.g. Hong Kong Identity Card and Passport copy) and address proof documents would be required before the actual execution of the trading activities.
• MES would require a declaration regarding the source of funds for each customer before the actual execution of the trading activities. MES may require further supporting documents regarding the source of funds.
• In the case of the customers being a legal entity, identity documents of the ultimate beneficiary owner would be collected.
• Identity and proof of address documents will be maintained for at least six years and will be submitted to regulators as required without prior notification to registered users.
• Customers would be screened against relevant sanctions and PEP lists at risk-based approach according to the “Anti- Money Laundering and Terrorist Financing - Guidance Paper on Politically Exposed Persons” as released by the Hong Kong Monetary Authority. (see ref)

• MES may at any time without liability and without disclosing any reason, suspend the trade with any suspicious user. MES shall notify you after exercising its rights under this clause
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