AquaRich International Investment Group Limited
Effective Date: [2026/5/1]
Document No.: WEB-AML-001
AquaRich International Investment Group Limited (the “Company”) operates the Anwin digital asset wallet service platform. The Company places great importance on anti-money laundering (AML), counter-terrorist financing (CFT), counter-proliferation financing (CPF/FPADM), and the prevention of other financial crimes. The Company is committed to establishing a compliance management framework that is appropriate for its business model, customer types, wallet service scenarios, and risk profile, in order to prevent the platform, wallet services, accounts, addresses, deposit and withdrawal arrangements, or related services from being used for any form of unlawful or criminal activity.
This statement is issued to the public, partners, and relevant institutions to explain the Company’s compliance position, core principles, and primary control measures. This statement is a principle-based document and does not constitute any commitment or representation regarding the outcome of any individual case, the fulfillment of reporting obligations, or any regulatory status.
The Company maintains a zero-tolerance approach toward money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion, identity misuse, account theft, criminal misuse, handling of stolen digital assets, market manipulation, movement of corrupt funds, and other conduct that may harm financial order, user rights, or public safety.
The Company undertakes to continuously improve its customer identification, wallet activity monitoring, risk classification, suspicious activity identification, recordkeeping, training, audit, and escalation reporting mechanisms in accordance with applicable laws and regulations, regulatory requirements, risk assessment results, and internal policies.
The Company adopts a risk-based approach to establish its AML/CFT/CPF management framework, which includes but is not limited to the following:
1. Customer identification and due diligence: conducting identity identification, verification, risk rating, and necessary ongoing due diligence on customers.
2. Enhanced due diligence: applying enhanced review measures to high-risk customers, customers with abnormal wallet activity, politically exposed persons (PEPs), customers associated with high-risk jurisdictions, and other high-risk situations.
3. Wallet activity monitoring and sanctions screening: conducting monitoring and screening based on business rules, deposit and withdrawal patterns, address risk, asset source and destination risk, and applicable sanctions lists.
4. On-chain risk analysis: identifying and analyzing risks related to on-chain deposits and withdrawals, address associations, and fund paths where applicable.
5. Limit and permission management: applying tiered management of functional permissions and deposit and withdrawal limits based on customer risk level, wallet service features, and service scenarios.
6. Recordkeeping and internal audit trail: retaining identity information, wallet activity records, deposit and withdrawal records, review records, training records, and audit materials in accordance with law.
7. Training and review: conducting regular employee training and continuously improving implementation effectiveness through internal review, sample checks, and independent assessments.
8. Escalation reporting and cooperation: carrying out internal escalation, restrictive measures, reporting obligations, and cooperation with competent authorities when required by law, regulation, or risk needs.
The Company may take one or more of the following control measures based on business nature, customer type, risk level, and applicable laws and regulations:
• implement customer identity identification and verification procedures (KYC/KYB);
• conduct on-chain activity monitoring and risk review based on wallet activity, deposit and withdrawal records, device environment, address information, and other risk factors;
• apply enhanced review to politically exposed persons, sanctioned parties, high-risk addresses, and customers associated with high-risk regions;
• restrict, delay, manually review, or escalate abnormal deposit and withdrawal activity, suspicious conduct, abnormal devices, bulk registrations, abnormal withdrawals, and other high-risk activities;
• take measures such as refusing to establish a business relationship, restricting services, suspending relevant operations, freezing related assets, or preserving records in accordance with applicable laws and regulatory requirements;
• report to or cooperate with competent authorities when required, permitted, or necessary by law.
The Company classifies and manages customer risk based on customer identity, business nature, wallet activity, geographic factors, address risk, on-chain risk labels, and other relevant factors. Customers with different risk levels may be subject to different levels of identity verification, supplementary information requirements, deposit and withdrawal limits, ongoing monitoring frequency, and manual review intensity.
The Company reserves the right to adjust customer risk ratings, applicable permissions, and control measures based on changes in customer behavior, risk event triggers, regulatory requirements, or other reasonable grounds.
The Company may impose access restrictions, service restrictions, or enhanced review measures on certain countries, regions, individuals, entities, addresses, or wallet service scenarios in accordance with applicable laws and regulations, sanctions policies, platform rules, and risk control requirements.
For customers, deposit and withdrawal activities, or addresses that match sanctions lists, have significant associations with high-risk addresses, involve restricted jurisdictions, or present suspected sanctions evasion, the Company may lawfully take measures such as service refusal, processing restrictions, asset freezing, information retention, manual review, or escalation reporting.
The Company will retain customer identity information, wallet activity records, deposit and withdrawal records, review records, training records, audit records, and other necessary materials in accordance with applicable laws and regulations, regulatory requirements, audit needs, dispute handling needs, and internal control policies. Where investigations, audits, complaints, disputes, suspicious activity assessments, or other lawful grounds for retention exist, the retention period of relevant materials may be extended in accordance with law.
The Company will continue to monitor financial crime patterns, on-chain risk types, fraud methods, changes in sanctions rules, and the evolution of business risks, and will update internal policies, rule engines, risk models, review processes, training content, and response measures accordingly.
If you discover that this platform may be involved in money laundering, terrorist financing, fraud, sanctions evasion, identity theft, or other financial crime-related risks, you are welcome to report or inquire through the following channels:
Compliance Email: [email protected]
Support / Complaints Email: [email protected]
Official Website: anwin.tech
The Company will handle reported information lawfully and prudently, and will protect the lawful rights and information security of the reporting person to the extent applicable.