Terms

Anti-Money Laundering and Counter-Terrorist Financing Policy

XIN WANG GOLDEN COMPANY LIMITED is committed to preventing its accounts, precious-metals trading and related fund services from being used for money laundering, terrorist financing, fraud or other illegal activity. This policy explains what clients may need to help with when opening an account, moving funds and using their account. The specific requirements depend on the laws applicable to the Company, its actual business and client risk.

1Legal basis and scope

Hong Kong laws on the proceeds of crime, suspicious transaction reporting and terrorist property, including the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405), the Organized and Serious Crimes Ordinance (Cap. 455) and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575). Whether the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and related guidelines apply to a particular business depends on the entity’s status, the nature of the business, the registration category and the transaction. The Company handles these matters according to the requirements that actually apply and the risks involved.

CGSE membership and Hong Kong Customs registration as a dealer in precious metals and stones are separate regimes. Please check each status and the business it covers separately; member number 019 does not mean every service is subject to the same statutory customer due diligence or record-keeping requirements.

2Client identity verification

When you open an account or use related services, the Company may, as required, verify your identity, contact details, residential or business information and the purpose of the account, and ask for valid proof. Submit true, complete and unaltered information through the designated channels, and don’t send ID documents in public messages, social-media groups or unverified private channels.

3Representatives, corporate clients and beneficial owners

If you act for another person or a company, you must truthfully state your identity and authority. For companies, partnerships, trusts or other entities and arrangements, the Company may check registration details, the nature of the business, ownership and control structure, directors or relevant officers, authorised representatives and the beneficial owners who actually own or control the account. Verification must not be avoided through nominee holdings, borrowed identities or not disclosing the person in control.

4Source of funds and purpose of transactions

The Company may ask about the purpose of the account, your occupation or business, expected fund movements, source of funds and related transactions, and where the risk or applicable requirements call for it, the source of wealth. Supporting documents may include bank records, income, business, asset sale or other lawful-source information proportionate to the matter. The documents needed are decided case by case; not every client must submit the same set.

Identity verification, account ownership checks and source-of-funds and source-of-wealth enquiries deal with different questions. Proving that a payment came from a particular account does not necessarily explain how the money was obtained, and showing you own an asset does not necessarily prove the source of this payment. Provide explanations and documents linked to the people, funds, period and transactions in the enquiry.

5Further risk-based checks

Factors such as the client, region, product, trading method, payment relationships and service channel may affect the depth of verification. Higher-risk cases, politically exposed persons and their associates, applicable sanctions or inconsistent information may require enhanced review. A screening hit or a similar name only means further checks are needed and does not in itself prove the client is involved in wrongdoing.

6Same-name payments and channel checks

The Company does not accept deposits from, or make withdrawals to, third-party bank accounts. Use funding accounts that match the trading account holder and comply with the Company’s rules. Don’t borrow accounts, pay or receive funds for others, or conceal the real payer, controller or beneficiary. Before depositing or withdrawing, check the payment details, available channels, currency and ownership checks under the procedures published in the official Client Portal.

Where a digital-asset or other channel is explicitly offered, you may still need to explain the wallet or payment relationship and source of funds. Applicable checks must not be avoided by splitting transactions or frequently changing payment accounts or wallets. Whether cash, particular payment instruments or particular networks are accepted follows the rules expressly published by the Company that apply to your account.

If you paid from a third-party bank account by mistake, stop paying, keep the original paying account name, transaction reference, amount, date and related proof, and contact the Company immediately through official channels. Any return or further handling requires checking the payment relationship and applicable requirements; don’t arrange for someone else to collect the funds, ask for them to be sent to an unrelated account, or pay again to try to get around verification.

7Ongoing monitoring and updates

Verification may take place at account opening or while the account is open. When trading activity, source of funds, ID validity or known circumstances change, the Company may re-verify information as required or according to risk. Please tell the Company promptly through official channels when your name, address, contact details, company control, beneficial owners or other important details change.

8Unusual account activity or activity needing explanation

For activity inconsistent with what is known about the client, unclear fund relationships or activity needing further explanation, the Company may ask for additional explanations and proof. Cooperating with enquiries helps complete the required verification. Making an enquiry, requesting documents or temporarily holding an operation does not in itself mean the client has been found to be involved in money laundering or other illegal activity.

When asked for more information, you may first check the type of information required, the period concerned, how to submit it and what the enquiry is about, and truthfully explain why you cannot provide a particular proof. Don’t create false documents, hide important information affecting verification, or avoid enquiries by splitting orders or changing payers. No verification document should ever include trading passwords, online banking passwords or one-time codes.

9When verification cannot be completed

If necessary information is missing, there are material inconsistencies, or verification required by applicable law and the service cannot be completed, the Company may, to the extent it has a legal or contractual basis, decline to process the account opening or operation for now, ask for more information, or take proportionate service restrictions and termination measures. How the related funds are handled depends on the actual reason, applicable law and the client agreement. Verification requirements in themselves do not allow the Company to confiscate funds arbitrarily or withhold them indefinitely without a basis.

10Suspicious transaction reporting and lawful cooperation

Where conditions such as knowledge or suspicion under applicable law are met, the Company will make the required disclosures to competent authorities and cooperate with lawful investigations, orders or other requirements. The law may restrict the Company from disclosing whether a report has been made, its content or details of an investigation; in such cases the Company may be unable to provide related information to the client.

11Use of information and record keeping

Identity, account, transaction, fund movement and related communication records are handled under applicable law, the purpose of verification and the Privacy Policy. Different records may have different retention periods and start dates; once the lawful need ends, the Company handles data no longer needed as required. Closing an account does not by itself end obligations to keep records by law, deal with disputes or cooperate with investigations.

12Enquiries and fraud warnings

If you receive a request for more information, first verify it using the contact details published on the Company’s official website. Never pay anyone who claims funds can be released simply by paying an “anti-money-laundering certificate fee”, an “unfreezing deposit” or a private handling fee. If you have questions about verification requirements, fund transactions or use of your information, raise them through official customer service or complaint channels, and keep the related notices and proof.