AML/CTF

1. Background

As a cryptocurrency exchange, Huobi Australia Pty Ltd ACN 625 496 200 (herein referred to as "Huobi Australia", "we", "our" or "us") is required to be registered with the Australian Transactions Reports and Analysis Centre (AUSTRAC).

As such, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (AML/CTF Rules) require us to put training, processes, and systems in place to identify, manage and mitigate the risk that our services are used to launder money and/or finance terrorism.

2. Our Objectives

The key objectives of our AML/CTF program are to:

· provide guidance and direction to ensure compliance with appropriate regulatory requirements (including the AML/CTF Act and AML/CTF Rules) and to minimise risks associated with money laundering, terrorism financing and other related activities.

· combat, detect and report use of our services for money laundering and terrorism financing.

· protect the name and brand reputation of Huobi Australia.

3. Definitions

ML or money laundering is the process of hiding or disguising he source of illegally obtained ("dirty") funds to make them appear legitimate ("clean"), e.g. by filtering them through the financial system.

TF or terrorism financing differs from money laundering in 3 key ways:

· provide guidance and direction to ensure compliance with appropriate regulatory requirements (including the AML/CTF Act and AML/CTF Rules) and to minimise risks associated with money laundering, terrorism financing and other related activities.

· combat, detect and report use of our services for money laundering and terrorism financing.

· protect the name and brand reputation of Huobi Australia.

4. Our AML/CTF Program

The design and implementation of our AML/CTF program was tailored to our ML/TF risk profile, having regard to specific systems and controls, including (without limitation):

· governance characterised by the designation of an AML/CTF compliance officer responsible for overseeing the AML/CTF program, maintaining senior leadership commitment, establishing AML/CTF compliance guidelines and setting and directing AML/CTF strategy;

· policies and procedures that set our standards with regards to the identification, mitigation and deterrence of money laundering and financing terrorists, including but not limited to know-your-customer (KYC) standards. In addition to the minimum KYC requirements, risk-based procedures to address customer due diligence requirements, record keeping and reporting requirements, as well as processes for the identification, reporting and escalation of suspicious transactions;

· training and risk awareness programs that promote a risk culture that supports AML/CTF compliance through the development of risk awareness training programs;

· an independent review which includes periodic independent evaluation of the AML/CTF program and validates and tests the effectiveness of AML/CTF processes and procedures;

· an employee due diligence program which determines the screening procedure for prospective employees; and

· adherence to the AML/CTF Act and AML/CTF Rules and guidelines issued by the regulators from time to time.

5. Policy Roles and Responsibilities

Huobi Australia's board of directors (the Board) and senior management have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees should comply with these, attend training specific to their role, and report suspicious matters or behaviours.

A dedicated AML/CTF compliance officer will be responsible for monitoring the status and effectiveness of Huobi Australia's AML/CTF risk management and compliance.

6. Further Information

· The Attorney-General's Department: https://www.ag.gov.au/

· AUSTRAC: http://www.austrac.gov.au/

· Australian Crime Commission: https://www.acic.gov.au/