IPMAX Anti-Money Laundering (AML) Compliance Program

1 Company Policy

Hong Kong 詞元之境網絡科技有限公司 is firmly committed to actively preventing money laundering, any activity that facilitates money laundering, and the financing of terrorist or criminal activities. This commitment is aligned with all applicable requirements of the Bank Secrecy Act (BSA) and related laws.

Implementation Details

2 Providing Anti-Money Laundering Information

We will not disclose information requested or obtained by FinCEN unless disclosure is necessary to comply with the information request. Receipt of a National Security Letter (NSL) will be handled with the highest level of confidentiality.

Any Suspicious Activity Report (SAR) filed after receipt of an NSL will not mention the receipt or existence of the NSL, and will focus only on the facts and circumstances of the detected suspicious activity.

3 Monitoring Accounts for Suspicious Activity

We will carefully monitor account activity for unusual size, volume, patterns, or transaction types while considering risk factors and red flags appropriate to our business.

Red Flags

Red flags that may indicate money laundering or terrorist financing include, but are not limited to:

1. The customer provides unusual or suspicious identification documents that cannot be readily verified or are inconsistent with other statements or documents.
2. The customer is unwilling or refuses to provide complete customer due diligence information.
3. The customer refuses to identify a legitimate source of funds or provides false, misleading, or materially incorrect information.
4. The customer resides in or transacts with jurisdictions known for bank secrecy, tax avoidance, high-risk activity, or conflict areas.
5. The customer has difficulty describing the nature of their business or lacks general knowledge of their industry.
6. The customer has been rejected by or had a relationship terminated by another financial services company.
7. The customer's legal or mailing address is associated with multiple other apparently unrelated accounts or businesses.
8. The customer appears to act as an agent for an undisclosed principal but is unwilling to provide information.
9. The customer is a trust, shell company, or private investment company and is unwilling to provide information about controlling parties and potential beneficial owners.
10. The customer is publicly known or known to be subject to criminal, civil, or regulatory proceedings.
11. The customer maintains multiple accounts without an apparent business purpose.
12. An account is opened in the name of a legal entity involved in activities related to known terrorist entities.

Other Potential Red Flags

13. The customer shows unusual concern about the company's compliance with government reporting requirements.
14. The customer attempts to persuade staff not to file required reports.
15. Law enforcement issues a subpoena or freeze letter regarding the customer or account.
16. The customer conducts high-value transactions inconsistent with their known income.
17. The customer seeks to conduct transactions that lack business sense or an apparent investment strategy.
18. A securities transaction is unwound before maturity without an apparent reason.
19. The customer is unconcerned about transaction costs.

4 Anti-Money Laundering Recordkeeping

Anti-money laundering compliance personnel and their designees will ensure AML records are properly maintained and SARs are filed as required.

5 Clearing / Introducing Firm Relationships

We will work closely with our clearing firms to detect money laundering activity. Information, records, data, and exception reports will be exchanged as needed to comply with anti-money laundering laws.

6 Senior Manager Approval

Senior management has provided written approval for this AML Compliance Program and considers it reasonably designed to achieve and monitor the company's ongoing compliance with the BSA and its implementing regulations.