Statement on Combating Organized Crime and Compliance Commitment

AnWin adopts a zero-tolerance approach to all forms of organized crime, financial crime, cybercrime, fraud, identity theft, black-market abuse, and any unlawful activity carried out through the use of digital assets, online tools, or third-party accounts.

We are committed to establishing and continuously enhancing mechanisms for risk identification, customer due diligence, transaction monitoring, on-chain analysis, internal control, incident handling, and compliance cooperation, in order to prevent our platform, products, systems, accounts, addresses, devices, or services from being used, directly or indirectly, for organized crime, fraudulent activity, or other serious unlawful purposes.

This Statement reflects AnWin’s core position and governance principles in preventing, identifying, handling, and reporting relevant high-risk conduct.

I. Zero-Tolerance Position

AnWin maintains a zero-tolerance position toward, including but not limited to, the following conduct:

• the use of this platform by organized criminal groups or cross-border criminal networks for fund transfers, asset movement, concealment of assets, or transaction arrangements;
• money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction;
• fraud, telecom fraud, phishing, fake customer support, fake investments, fake airdrops, malicious contracts, and other deceptive schemes;
• identity impersonation, identity theft, false registration, forged or altered documents, and fraudulent verification;
• unlawful control of accounts or assets through trojans, remote access tools, social engineering, malicious software, abnormal authorization, or device hijacking;
• the use of multiple accounts, devices, addresses, proxy networks, VPNs, bulk operations, or other concealment methods to evade monitoring and restrictions;
• disguising the source, destination, beneficial owner, or purpose of funds through layered address transfers, obfuscation paths, abnormal fund chains, or similar methods;
• funds or transactions connected with stolen assets, ransomware, hacking attacks, darknet markets, illegal gambling, narcotics, human trafficking, weapons, or other prohibited criminal activity;
• any other material high-risk conduct in violation of applicable laws and regulations, public order and good morals, or platform rules.

II. Key High-Risk Behavior Patterns

To reduce the risk of the platform being exploited for criminal purposes, AnWin pays particular attention to the following high-risk patterns, including but not limited to:

• coordinated control of multiple accounts, devices, payment tools, receiving addresses, or transaction behavior;
• evasion of monitoring by the same controller or related parties through account dispersion, transaction splitting, abnormal frequency, or similar methods;
• use of false, stolen, misappropriated, or inconsistent identity information for registration, verification, or trading;
• concealment of fund flows through high-risk addresses, abnormal counterparties, complex on-chain paths, or repeated intermediary transfers;
• bulk registration, bulk login, abnormal switching of devices, network environments, or login locations within a short period;
• inducing users to authorize, transfer, or deliver assets through fake projects, fake customer service, fake partnerships, fake investment opportunities, or false incentive schemes;
• use of off-platform trading, third-party payments, collection/payment on behalf of others, or payments not made by the actual user to commit fraud, money laundering, or asset transfer;
• abnormal logins, abnormal device binding, abnormal withdrawals, abnormal authorizations, or other signs of possible account takeover.

III. Preventive, Identification, and Control Measures

Depending on product features, service scope, risk level, and applicable laws and regulations, AnWin may adopt measures including but not limited to the following:

1. Customer Identification and Due Diligence

• implementing customer identification, verification, and ongoing due diligence measures;
• carrying out enhanced due diligence, supplemental verification, and re-verification where appropriate;
• applying a higher level of review to high-risk customers, counterparties, business relationships, or scenarios.

2. Device, Environment, and Behavior Identification

• conducting device identification, login environment identification, and anomaly detection;
• identifying suspicious multi-account control, device linkage, network environment switching, and abnormal operating patterns;
• blocking or restricting abnormal logins, abnormal authorizations, abnormal interactions, or suspected automated behavior.

3. Transaction Monitoring and On-Chain Risk Control

• continuously monitoring transaction behavior, fund flows, address associations, operating frequency, and counterparty risk;
• identifying suspicious activity through on-chain analysis, address labels, risk scoring, and pattern recognition where appropriate;
• applying controls to high-risk addresses, suspicious fund paths, abnormal withdrawals, or abnormal interaction patterns.

4. Restriction, Review, and Escalation

• initiating manual review, supplemental document verification, or further explanation procedures for conduct that triggers risk rules;
• imposing restrictions on login, withdrawal, transfer, authorization, connectivity, or other functions where necessary;
• launching internal escalation, incident handling, evidence preservation, and follow-up notification procedures for major risk events.

5. Compliance Cooperation and Internal Management

• establishing internal risk management, compliance review, access control, audit trail, and training mechanisms;
• cooperating lawfully, within the scope permitted or required by applicable laws and regulations, with partners, professional service providers, regulatory authorities, or competent authorities;
• continuously updating control strategies and handling rules based on evolving risks, regulatory requirements, and criminal techniques.

IV. User Responsibilities and Prohibited Conduct

When using AnWin services, users must ensure that their identity, information, source of funds, transaction purpose, and conduct are genuine, lawful, and in good faith, and must not, directly or indirectly:

• use this platform to carry out, participate in, assist, promote, or facilitate any unlawful or criminal activity;
• use a false identity, impersonate another person, or provide false or misleading information;
• hold assets, register, verify identity, receive payments, make payments, or operate accounts on behalf of others in order to evade monitoring, restrictions, or legal requirements;
• obtain another person’s account, authorization, or assets through fraud, inducement, coercion, trojans, malicious links, or other improper means;
• engage in any conduct that may harm platform security, the safety of others’ assets, or market order.

If a user discovers suspicious projects, fraudulent conduct, impersonation of official channels, abnormal links, suspicious receiving addresses, abnormal authorization prompts, or other security risks, the user should report them to AnWin promptly.

V. Enforcement Measures for Violations

Where conduct is suspected to involve organized crime, financial crime, fraud, identity theft, abuse by illicit networks, suspicious fund activity, or other material risk, AnWin has the right, based on risk level, facts, platform rules, and applicable laws and regulations, to take one or more of the following actions, including but not limited to:

• issuing security alerts, risk warnings, or compliance notices;
• requiring supplemental identity information, transaction background, source of funds, transaction purpose, or other explanations;
• imposing restrictions on relevant logins, transactions, withdrawals, authorizations, devices, addresses, interfaces, or service functions;
• suspending, delaying processing, reviewing, or terminating relevant accounts, orders, transactions, addresses, or assets;
• preserving, organizing, and securing relevant information, operational records, risk markings, and evidence;
• reporting to or cooperating with regulatory authorities, law enforcement agencies, or other competent bodies where required, permitted, or deemed necessary by the platform;
• taking other reasonable and necessary risk control or legal preservation measures.

VI. Cooperation with Regulators and Competent Authorities

Within the framework of applicable laws and regulations, AnWin will cooperate lawfully with regulatory authorities, law enforcement agencies, judicial authorities, and other competent bodies in relation to suspected criminal conduct, major risk incidents, or legally mandated investigations.

Where required by law, court order, regulatory requirement, or risk control needs, AnWin may impose restrictions, preservation measures, freezes, disclosures, reports, or other necessary actions with respect to relevant accounts, transactions, data, records, or services. Where notice is prohibited by applicable law, AnWin may be unable to provide prior notice to the affected user.

VII. Internal Integrity and Employee Obligations

AnWin requires all employees, management personnel, and cooperating personnel to observe principles of integrity, confidentiality, prudence, and compliance, and they must not:

• establish improper cooperation with criminal organizations, fraud rings, high-risk counterparties, or restricted parties;
• use their position to circumvent risk control, compliance monitoring, audit requirements, or internal controls;
• disclose internal monitoring logic, investigation measures, sensitive data, or handling arrangements;
• accept, request, or provide improper benefits that may affect the impartial performance of duties.

If internal misconduct, assistance to criminal activity, abuse of authority, or conflicts of interest are discovered, AnWin will deal with such matters seriously in accordance with internal rules and applicable laws and regulations and, where necessary, refer them to competent authorities.

VIII. Commitment to Continuous Improvement

AnWin will continue to monitor the evolution of organized crime, financial crime, and emerging risks in the digital asset sector, and will periodically review and update, based on business development, regulatory requirements, technological change, and practical experience:

• risk identification models;
• identity verification and customer review mechanisms;
• transaction monitoring and on-chain analysis rules;
• incident response and internal escalation procedures;
• customer protection, data retention, and compliance management systems.

IX. Reporting and Contact Information

If you suspect that this platform is being used for unlawful or criminal activity, or if you identify any suspicious conduct, fake official communications, abnormal receipts, fraudulent information, or security risks, please contact us promptly through the following channels:

• Compliance Reporting Email: [email protected]
• Customer Support Email: [email protected]
• Website: anwin.tech

Please do not provide your password, verification code, private key, seed phrase, or any other sensitive information to any unofficial channel.

X. Disclaimer and Reservation of Rights

This page is intended to describe AnWin’s general position, governance principles, and general measures in combating organized crime and related high-risk activities. It does not constitute a commitment or guarantee with respect to any specific risk situation, identification result, handling outcome, or service availability.

The identification of risks, restrictive measures, reporting obligations, handling methods, and scope of application will be determined by AnWin based on actual circumstances, available information, internal rules, technical capabilities, and applicable laws and regulations, and AnWin reserves the final decision-making authority in this regard.