\n This Risk Disclosure and Disclaimer should be read together with the\n \n BitradeX\n Terms of Service\n (\n "\n Terms of Service\n ")\n \n . Unless otherwise defined herein, all defined terms shall have the same meaning as set out in the Terms of Service. In short, we want you to understand the important risks and compliance matters when trading on the\n \n BitradeX\n platform.\n
\n\n 1. \n Purpose\n \n \n To maintain a sound and compliant digital-asset trading platform, we have established and implemented a set of anti-money-laundering, counter-terrorist-financing and trade & economic sanctions systems (\n \n “\n AML\n /\n CTF\n /\n Sanctions System\n ”\n or \n “\n System\n ”\n \n ). We are committed to advancing lawful and transparent business activity and to maintaining a good reputation among users, regulators and the digital-asset industry.\n \n
\n\n 2. \n Business Model\n \n BitradeX\n \n is a global digital-asset trading platform or marketplace where traders buy and sell with each other, commonly known as makers and takers. Generally, our services facilitate trades that match users with other users, but under certain circumstances described in the Terms of Service an affiliate of\n \n BitradeX \n may be the counter-party to trades conducted on the \n BitradeX\n platform. Users access our services through the \n BitradeX \n platform operated by \n BitradeX\n .\n
\n\n \n Risk Disclosure: Trading is risky. The risk of loss in trading or holding digital assets can be substantial. Accordingly, you should carefully consider whether trading is appropriate for you in light of your financial condition.\n \n
\n\n 3. \n Regulatory Environment\n \n \n We understand that regulators have taken a variety of approaches to laws and regulations regarding digital assets, including classifying or defining them as convertible virtual currency (FinCEN, USA) or virtual commodities (Hong Kong). As a trading platform, we consider all digital assets offered on the\n \n BitradeX\n \n platform to fall within an innovative alternative asset class; therefore, digital assets should not be referred to as money or currency.\n \n
\n\n \n Risk Disclosure: Digital assets are not money or legal tender. They are not backed by any government or central bank. We may sometimes have our own views on how various government agencies regulate; however, we will always fully comply with the rules and regulations of the countries in which we operate. We regularly engage with regulators and peers to explore best practices for regulating digital-asset businesses. In addition,\n \n BitradeX\n \n does not accept certain customers. We may not offer all services in all markets and jurisdictions, and may restrict or prohibit the use of all or part of the services in restricted areas, currently including Afghanistan, Algeria, Bangladesh, Bolivia, Canada, Cuba, El Salvador, France and its overseas territories, Hong Kong, Iran, India, Japan, Malaysia, Nepal, Nigeria, North Korea, Syria, Crimea, Donetsk and Luhansk regions of Ukraine, the United States of America (including Puerto Rico, American Samoa, Guam, the Northern Mariana Islands and the US Virgin Islands (St. Croix, St. John and St. Thomas) and all other US territories), and Uzbekistan.\n \n BitradeX \n \n may restrict services in additional jurisdictions, including but not limited to Australia (especially regarding our derivatives-related and centralized-exchange-related services), Bahamas (especially regarding our retail products), Brazil (especially regarding our derivatives-related and\n \n C2C\n services), Eritrea (especially regarding our \n C2C\n \n services), Russia (especially regarding our fiat-payment services), Singapore (currently supports centralized-exchange registration, deposits, withdrawals and trading (derivatives not supported)),\n \n South Korea (especially regarding our derivatives-related and \n C2C\n \n services), United Kingdom (especially regarding our derivatives-related, centralized-exchange-related and\n \n C2C\n services).\n
\n\n \n We cooperate with governments, respect regulations and comply with applicable laws. As good corporate citizens, law-enforcement agencies may request information from us and, where permitted by law, we will assist in investigations to trace and stop illegal activity. This also means the\n \n BitradeX\n \n platform is available only to law-abiding customers. We hope to serve you, and we also require you to act lawfully and legally on the\n \n BitradeX\n platform.\n
\n\n 4. \n Our AML\n /\n CTF System\n \n \n Through a risk-based, multi-layered control system, we have designed our system to reasonably prevent money laundering and terrorist financing.\n \n
\n\n \n The first layer includes stringent user-identification procedures, including verifying the identity of individual and corporate users. In addition to obtaining identification documents, we also obtain identification of beneficial owners/natural persons of non-natural-person users in accordance with international standards such as those of the Financial Action Task Force (FATF).\n \n
\n\n \n The second layer includes a risk-based system to ensure additional customer due diligence is performed. To this end, we screen users (including beneficial owners) against the Hong Kong SAR Government Gazette, the U.S. Office of Foreign Assets Control (OFAC) sanctions list, the UN Security Council sanctions list and other government sanctions lists. We may also screen against additional lists at our discretion to protect our reputation and users.\n \n
\n\n \n The third layer includes ongoing monitoring for suspicious activity. If our system suspects or has reason to suspect suspicious transaction activity, we will file suspicious-transaction reports with local regulators. Generally, suspicious transactions are inconsistent with a user’s known legitimate business or personal activities.\n \n
\n\n \n The above are the main components of our compliance system. However, the most important link in these multi-layered risk-control systems is our leadership team and staff, including AML/risk-control personnel who conduct training, supervision and foster a strong compliance culture.\n \n
\n\n 5. \n Risks and Specific Disclosures\n \n \n Digital-asset trading is considered high risk. Digital assets are not backed by any government or central bank. The risk of loss in trading or holding digital assets can be substantial.\n You should carefully consider whether interacting, holding or trading digital assets is suitable for you in light of your financial condition.\n \n
\n\n 5.1 \n \n Foreign-exchange risk: You agree and understand that any credit-card payment you make in your local currency will go through a standardized foreign-exchange conversion process.\n In some cases, this foreign-exchange conversion process may experience system errors and unexpected malfunctions.\n Should such errors and\n \n /\n or malfunctions occur (as determined by us in our sole discretion), you may receive USD or \n USDT \n \n balances that may differ from your local-currency balance at the time the payment transaction was initiated.\n This may give rise to a risk of loss, and you agree that you shall bear all costs associated with any foreign-exchange risk arising from such system errors and\n \n /\n or malfunctions.\n
\n\n 5.2\n Digital Payment Token Risk Warning\n
\n\n If you are a customer of a Digital Payment Token (\n DPT\n ) service provider, the Monetary Authority of Singapore (\n MAS\n ) requires us to provide you with this risk warning. \n MAS \n stipulates that before you:\n
\n\n (a) \n pay or transfer any money or \n DPT \n to your \n DPT \n service provider;\n
\n\n (b) \n enter into any agreement to buy or sell \n DPT \n with a third party at the instigation of your \n DPT \n service provider;\n
\n\n (c) \n enter into any \n DPT \n transmission agreement with a third party arranged by your \n DPT \n service provider;\n
\n\n (d) \n pay any money or \n DPT \n to a third party for transmission of \n DPT \n arranged by your \n DPT \n service provider; or\n
\n\n (e) \n transfer any digital payment token instrument to your \n DPT \n service provider,\n
\n\n you should note the following:\n
\n\n (i) \n Your \n DPT \n service provider is exempted by \n MAS \n from holding a licence to provide \n DPT \n services. Please note that if your \n DPT \n service provider or any third party fails, you may not be able to recover all money or \n DPT \n you paid to the \n DPT \n service provider or any such other third party.\n
\n\n (ii) \n You should not trade this \n DPT \n if you are not familiar with it. This includes how the \n DPT \n is created, and how the \n DPT \n you intend to trade is transferred or held by your \n DPT \n service provider.\n
\n\n (iii) \n You should be aware that the value of \n DPT \n \n may fluctuate greatly.\n You should buy\n \n DPT\n only if you are prepared to accept the risk of losing all the money you put into such tokens.\n
\n\n (iv) \n You should be aware that your \n DPT \n \n service provider, as part of its licence to provide\n \n DPT \n \n services, may offer services relating to\n \n DPT \n \n that are advertised as having a stable value (commonly referred to as\n \n “\n stablecoins\n ”\n ).\n
\n\n 5.3 \n Disclosure on Maintenance of Fiat and Digital Payment Token Custody Accounts (applicable only to \n BitradeX SG Pte. Ltd. \n users)\n
\n\n MAS \n requires us to disclose to you how your fiat and \n DPT \n custody accounts at \n BitradeX\n are maintained. Fiat funds of \n BitradeX\n Singapore users will be deposited directly and held in trust in one or more segregated custody accounts with one or more duly registered and licensed third-party banking institutions, in accordance with the banking institution’s terms of service, for the benefit of \n BitradeX\n Singapore users. \n DPT \n of \n BitradeX \n Singapore users are held for the benefit of \n BitradeX \n Singapore users in secure and segregated hot- and cold-wallet systems of \n BitradeX \n Singapore’s affiliates under a safeguarding agreement (no more than \n 5%\n of \n DPT \n is kept in hot wallets), under which \n BitradeX\n Singapore exercises strict oversight and control of the hot- and cold-wallet systems.\n
\n\n Unless you expressly authorize and instruct, \n BitradeX \n Singapore will not exercise any control over your fiat and \n DPT\n . If \n BitradeX \n Singapore becomes insolvent, your fiat and \n DPT\n will not be subject to claims by \n BitradeX \n Singapore’s creditors under applicable laws and practices.\n
\n\n 6. \n Fees\n
\n\n 6.1 \n Trading fees: Your trading fees are determined by your trading volume over the past \n 30 \n \n days. All trading volumes are converted to USD using the digital asset’s exchange rate at the time of the trade.\n Trades in non-USD base-pair markets are also converted. Your{' '}\n \n 30 \n -day volume is calculated every day at \n 00:00 (UTC+8)\n .\n
\n\n All fees are charged in the asset you purchase. For example, if you buy \n BTC/USD\n , the fee is charged in \n BTC\n . Rebates are paid in the asset you sell. For example, if you buy \n BTC/USD\n , the rebate is paid in USD.\n
\n\n\n 6.2 \n Additional fees and charges: \n BitradeX \n offers multiple deposit and withdrawal channels. Deposit and withdrawal fee information can be viewed.\n
\n\n If you select \n BitradeX \n as the third-party provider, fees will be charged for credit-card\n /\n debit-card transactions (\n Visa\n only).\n
\n\n 6.3\n Country\n /\n region-specific pricing: Country\n /\n region-specific pricing may vary depending on the user’s place of residence or location.\n
\n\n 7. \n Contact\n \n \n If you have questions about our customer due-diligence controls or need assistance, please feel free to contact our\n \n 24/7\n customer-service representatives via live chat or email at the Help Centre.\n
\n\n 8. \n Version\n \n This \n “\n Risk Disclosure and Disclaimer\n ”\n may be published in different languages. In case of any discrepancy, the English version shall prevail.\n