User Guidance on Anti–Money Laundering (AML) and Counter-Terrorist Financing (CFT)

To prevent and combat money laundering and terrorist financing, ensure the compliance of digital asset trading, and protect the legitimate rights and interests of the platform and its users, the Tebbit platform formulates this Guidance in accordance with applicable international AML/CFT laws and regulations, together with the Platform’s “Tebbit AML Rules,” “User Agreement,” and related policies.
Money laundering and terrorist financing threaten the stability of digital-asset trading, increase legal and operational risks, and may endanger national and international financial security. Tebbit will strictly implement this Guidance and fully perform AML/CFT responsibilities.

Chapter 2 Scope of Application

This Guidance applies to all users trading on the Tebbit OTC trading platform (“OTC Platform”).
All users must comply with AML/CFT laws and regulations in their jurisdictions and implement the requirements of this Guidance to the extent permitted by law. Where local law imposes stricter requirements, local law prevails.

Chapter 3 Definitions of AML and CFT

AML/CFT refers to measures that prevent criminals from using the OTC Platform to disguise or conceal the source and nature of proceeds and benefits derived from the following crimes:
• Drug-related crimes
• Organized crime
• Terrorist activities
• Smuggling
• Corruption and bribery
• Financial fraud
• Crimes disrupting financial administration
Tebbit strictly follows applicable laws and implements compliance controls to ensure trading security.

Chapter 4 AML Principles of the OTC Platform

The OTC Platform monitors customer risk based on the following principles:

  1. Comprehensiveness: Assess all potential ML/TF risk factors and implement effective monitoring.
  2. Prudence: Enforce KYC policies to strengthen identity verification and prudently monitor transactional risk.
  3. Continuity: Continuously review user behavior, periodically update risk ratings, and adjust controls accordingly.
  4. Confidentiality: User identity data, transaction data, and risk assessments are confidential and disclosed only as required by law.
  5. Tiered Management: Apply enhanced due diligence and controls to higher-risk customers.

Chapter 5 Identification of Individual Users

Individual OTC users must provide, as required by AML rules:
• Full name
• Copy of ID card or passport
• Other identity documents as requested by the Platform

Chapter 6 Identification of Institutional Users

Institutional OTC users must provide:
• Company name
• Registered business address
• Legal representative’s name
• Legal representative’s residence
• Business license/registration certificate
• Copy of legal representative’s ID or passport
• Other documents as requested by the Platform

Chapter 7 Review of User Information

In accordance with AML regulations and KYC requirements, the OTC Platform verifies and records user identification materials.
If doubts or anomalies are identified, Tebbit may verify with competent authorities and take further investigative measures.

Chapter 8 Monitoring of Low-Risk Users

Per AML rules, the Platform conducts routine monitoring of low-risk users and reserves the right to re-assess and adjust user risk ratings as appropriate.

Chapter 9 Monitoring of High-Risk Users

For users identified as high risk, the Platform will:
• Re-verify identity every 6 months
• Further verify source of funds and purpose of transactions
• Collect information on financial/operational status
• Enhance monitoring and take measures upon detecting suspicious activity

Chapter 10 Data Storage and Retention

Tebbit takes necessary measures to protect customer identity data and transaction records and retains them as follows:
• Identity information: at least 5 years after business relationship termination
• Transaction records: at least 5 years after the transaction

Chapter 11 User Notes

All OTC users must:
• Not lend accounts to others
• Not rent, sell, or lend identity documents
• Not rent, sell, lend, or disclose bank accounts/cards, passbooks, or passwords
• Cooperate with identity verification and reviews
• Use secure, reliable third-party financial institutions for payments
Violations may lead to account freezes and inclusion on regulatory watchlists.

Chapter 12 Reporting Suspicious Transactions

If you discover suspicious activity or suspect ML/TF, promptly report it to Tebbit.

Chapter 13 Effective Date

This Guidance takes effect upon publication. Tebbit will update AML/CFT policies periodically to reflect legal changes.

Tebbit will rigorously implement AML laws and protect users’ rights while maintaining a safe, stable trading environment.