1.Overview
HedgerX Exchange is committed to implementing and maintaining a robust Know-Your-Customer (KYC) and Anti-Money Laundering (AML) compliance framework to ensure adherence to applicable laws and regulations while aligning with global industry best practices. We adopt a zero-tolerance policy toward money laundering, terrorist financing, sanctioned entities, and high-risk jurisdictions. Our goal is to uphold platform integrity, protect users' legitimate interests, and contribute to the security and stability of the global financial system.
As a globally operating platform, HedgerX Exchange adheres to international standards, particularly the Financial Action Task Force (FATF) recommendations, and complies with stricter legal requirements where applicable based on users' jurisdictions.
2.Scope
This policy applies to all users of the HedgerX Exchange platform, including individuals, institutional clients, employees, partners, and other relevant stakeholders. It covers all products, services, and transaction activities provided by HedgerX Exchange.
3.Risk-Based Approach (RBA)
HedgerX Exchange adopts a Risk-Based Approach (RBA) in compliance with FATF guidelines and jurisdictional regulations to ensure the effectiveness and adaptability of its AML measures. We conduct periodic risk assessments across various dimensions, including products, services, customers, and geographic locations, to establish a comprehensive risk management strategy.
Risk Identification Factors
Customer Identity (Individual/Institutional)
Customer Risk Profile (Transaction history, industry type, source of funds, etc.)
Transaction Patterns (Unusual transactions, cross-border transfers, large-value transactions, etc.)
High-Risk Jurisdictions (Sanctioned countries, regions with weak regulatory oversight, etc.)
Risk Classification
Low Risk: Transparent customers and transactions with clear regulatory oversight
Medium Risk: Clients with partial opacity in information or complex transaction patterns
High Risk: Customers from high-risk countries, anonymous transactions, suspicious sources of funds
Continuous Monitoring and Adjustments
Implement real-time monitoring and periodic reviews to adjust risk assessment strategies
Adapt to regulatory changes and evolving business needs to ensure AML measures remain effective
Apply stricter scrutiny to high-risk customers and transactions
4.Customer Due Diligence (CDD)
HedgerX Exchange enforces strict Customer Due Diligence (CDD) measures to ensure the authenticity of customer identities, legitimacy of business activities, and compliance with AML regulations.
CDD Triggers
CDD is conducted under the following circumstances:
Establishing customer relationships (user registration and onboarding)
Executing transactions (especially for customers without a prior formal relationship)
Receiving crypto assets (fund deposits)
Detecting suspicious transactions (potential money laundering or terrorist financing)
Doubts about the accuracy or completeness of customer information
Customer Information Collection
(i) Individual Customers
Legal full name (as per government-issued ID)
Date of birth (for age verification)
Residential address (supporting documents may be required for certain thresholds)
Contact information (phone number, email, etc.)
Nationality and country of residence (for regulatory compliance and sanction checks)
(ii) Institutional Customers
Legal entity name (matching official registration documents)
Registration number and legal structure (corporation, LLC, etc.)
Information on directors and senior management (including Ultimate Beneficial Owners - UBOs)
Source of funds and business activities
Screening for sanctions and adverse media
5.Enhanced Due Diligence (EDD)
For high-risk customers, transactions, and jurisdictions, HedgerX Exchange applies Enhanced Due Diligence (EDD), including:
Additional information collection (identity, financial, and business activity details)
Continuous monitoring (higher frequency transaction reviews)
Adverse media screening (taking necessary action if negative news is found)
Frequent reassessments (more regular reviews for high-risk clients)
5.1 EDD Triggering Factors
Politically Exposed Persons (PEPs)
High-risk jurisdictions
Complex or opaque corporate structures (e.g., shell companies)
Anonymous or high-value transactions (involving privacy coins or significant amounts)
Frequent or unusual transaction patterns (large fund movements within short timeframes)
High-risk industries (e.g., virtual asset service providers, offshore finance)
Non-face-to-face customers (remote account openings)
Adverse media reports (involvement in financial crimes or money laundering)
Use of intermediaries or third-party agents
6.Ongoing Monitoring
HedgerX.com employs both automated and manual transaction monitoring to detect suspicious activity and take necessary actions.
Transaction Monitoring Standards
Unusual transaction patterns (deviations from customer’s normal behavior)
Large-value transactions (single or cumulative transactions exceeding predefined thresholds)
Frequent transactions (unusually high trading frequency or repetitive patterns)
Cross-border transactions (involving high-risk jurisdictions)
Monitoring Mechanisms
Automated Monitoring Systems: Machine learning and data analytics to enhance detection accuracy
Manual Reviews: Compliance teams investigate flagged transactions
6.3 Suspicious Transaction Reporting (STR)
If a transaction raises concerns, HedgerX Exchange will file a Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit (FIU) without notifying the customer, in compliance with legal obligations. Transactions or accounts may also be suspended where necessary.
7.Policy Review and Updates
HedgerX Exchange will review this policy at least annually or whenever there are significant regulatory, operational, or risk-related changes to ensure ongoing compliance and effectiveness.
8.User Responsibility for Account Security
Protecting account credentials (passwords, private keys, etc.)
Reporting suspicious activities (unauthorized account access, potential fraud, etc.)
9.Language Disclaimer
In case of discrepancies between different language versions of this policy, the English version shall prevail.
HedgerX Exchange is a global digital asset trading platform. We are proud to provide fully transparent trading, listing, and digital asset development services. Thanks to every user for their support to us, please look forward to HedgerX Exchange innovative products!
Risk Warning: Cryptocurrency investments have high market risks. Please invest carefully. HedgerX Exchange will do its best to select high-quality coins, but will not be responsible for your investment losses.