AMLATFPUAA 2001/AML/ATF/Sanctions Program

• I. Purpose of Program 

  We have discretionarily established and implemented an Anti-Money Laundering, Anti-Terrorist Financing and Trade & Economic Sanctions Program (“AML/ATF/Sanctions Program” or “Program”) to ensure a robust, long-lasting and value-added ecosystem to all customers. We promote legal, transparent business activities and maintain a strong reputation among remittance businesses, regulators and consumers.

• II. Our Role and Activity 

  We are a global, blockchain transfer network operator that provide services to Transfer and Delivery companies (our customers). OKLink is not a remittance company. The sender is a customer of the Transfer company, while the recipient is a customer of the Delivery company. We utilize blockchain technology to quickly and securely move digital tokens (such as OK Dollars) from the Transfer Company to the Delivery Company, and vice versa for refunds as instructed by the respective companies.

• III. AML/ATF/Sanctions Landscape 

  We understand that regulatory bodies have taken a diverse approach to the laws and regulations regarding blockchain and digital currency/asset activities. We may at times have opinions of such diverse approaches; however, at all times, we will fully abide by rules and regulations. We regularly outreach to regulators and industry on the best approach to regulate digital currency/asset activities, especially with the context of a level-playing field with existing regulations for similar traditional activities. As an operator of a transfer platform, OKLink does not currently fall within the coverage of existing AML/ATF frameworks in the countries we operate. We abide by local/Hong Kong laws and regulations, including trade and economic sanctions due to its general applicability regardless of whether we operate with or without the blockchain. Furthermore, to promote a robust ecosystem, we have screened our customers (including beneficial owners) against the United Nations, United Kingdom Majesty and Office of Foreign Asset Control Specially Designated Nationals Lists.

• IV. Our AML/ATF Program 

  We have designed our discretionary Program to reasonably prevent money laundering and terrorist financing through a risk-based, multi-layer control system. The first layer includes strong customer due diligence and onboarding of qualified Transfer and Delivery companies. As part of this assessment, Transfer and Delivery companies will be judged based on their adopted AML/KYC procedures, their local market reputation, and whether they have obtained applicable remittance related licenses from local regulatory bodies. The second layer includes a stringent customer identification program, including verifying the identity of Transfer and Delivery companies via business registration and incorporation documents. We also identity and verify the entities’ beneficial owners/natural persons consistent to international standards from FATF and US’ Bank Secrecy Act and EU’s AML Directive. Furthermore, we believe that human talent is ultimately needed to maintain a robust program; and therefore, we have the best AML/Risk personnel to execute training, oversight and a sound compliance culture. If you have questions or require customer due diligence controls to onboard OKLink’s platform, please do not hesitate to reach out to your OKLink representative.