Sanctions policy

01Commitment and scope

NIO X PTE. LTD., a company registered in Singapore, operates the NioX spot exchange. NioX is committed to full compliance with every financial sanctions regime, trade sanctions regime and export control measure that applies to its business, and it treats that compliance as an absolute condition of access to the service.

This policy binds everyone connected to the service, from applicants and account holders through to counterparties and every member of staff. Acceptance of the terms of service is acceptance of this policy in full.

The measures NioX observes are those that apply where NIO X PTE. LTD. is registered, together with the measures of any other jurisdiction that reach a customer, a counterparty, a currency, an asset or a transaction connected to the service. Where more than one regime applies, NioX follows the strictest of them.

NioX maintains the screening described here under the permissions it holds to operate, and it applies these controls whether or not any single regime compels a particular step. NioX reserves the right to refuse an application, to suspend or restrict an account, to freeze an asset, to file a report and to close a relationship where it considers such action necessary to remain within applicable sanctions measures, and it may do so without prior notice and without giving reasons.

02Screening

NioX screens against applicable sanctions lists and watch lists at more than one moment, and screening is continuous rather than a single event at onboarding.

1. Before any account is opened, each applicant is screened as a condition of onboarding, and no account is opened while a check remains unresolved.
2. Whenever a relevant sanctions list or watch list is added to or amended, the entire customer base is screened again against the updated measure without delay.
3. On every deposit and every withdrawal, the counterparty is screened, and for a digital asset movement the receiving address and the history of the addresses connected to it are screened as well.
4. At recurring intervals as part of continuing due diligence, with the interval set by the risk rating carried by each account and shortened whenever that risk rises.

A screening check examines the person's full name and every alias by which they are known, their date of birth, their nationality and their place of residence, the ownership and control behind any entity, the internet protocol address used to reach the service and, for digital assets, the receiving address together with every counterparty that blockchain analytics associate with it.

NioX keeps its screening data current as measures evolve, and it applies automated and manual review together so that new designations, amendments to a list and newly identified addresses are captured as soon as they take effect. Sanctions measures change often, and NioX treats the reach of a measure as extending to any successor, affiliate or address that a designated person owns or controls.

03Restricted jurisdictions and prohibited persons

NioX will not open an account for, or provide any service to, a person designated under an applicable sanctions measure, a person owned or controlled by such a person, or a person acting on their behalf. Any such person is prohibited from using the service.

Where a jurisdiction sits under comprehensive sanctions, NioX will neither open an account for anyone resident there nor serve anyone present there at the moment they reach the service.

The list of jurisdictions that NioX will serve is maintained by the compliance function and changes as the underlying measures change. Anyone applying from beyond that list is refused. Where a current account holder moves to a jurisdiction that has fallen off the list, the account is restricted to withdrawals alone, and only so far as the law still permits a withdrawal to be paid.

Reaching the service from a jurisdiction NioX does not serve is a breach of the terms of service, and that remains true where any tool is used to disguise the origin of a connection. NioX may block, suspend or close any account used in this way.

04Handling a positive match

When a check identifies a possible match, NioX follows the sequence set out below, and no payment is released while the review remains open.

1. Whatever is under way, whether an application or a transaction, is halted at once and no asset is paid out or released.
2. The alert is assessed against the identifying information on file to establish whether it is a genuine match or a false positive.
3. A false positive is recorded together with the reasoning behind the decision, and the matter proceeds.
4. A confirmed match results in the account being blocked, the relevant assets being frozen so far as the applicable measure requires, and a report being filed with the competent authority within the period that authority sets.
5. Nothing about a report is disclosed to the person it concerns or to any other party, except where the law requires or permits disclosure.

05Frozen assets

An asset frozen under a sanctions measure remains where it is. It is released only where the competent authority grants a licence to release it, or where the measure behind the freeze is lifted. For as long as the freeze holds, NioX will not deal in that asset, will not permit any trade against it and will not act on any instruction to move it.

NioX reserves the right to freeze an asset as a precaution while a review remains open, and to keep it frozen until that review is resolved.

06Evasion and circumvention

Any attempt to evade or circumvent sanctions is strictly prohibited, and each of the behaviours below will result in the account being closed and reported.

• Concealing where an account holder is located or where a transfer has originated.
• Using another person to hold or move assets for a sanctioned person or to disguise a sanctioned interest.
• Breaking a transfer into smaller parts so that a screening threshold is never reached.
• Providing false or misleading identity, ownership or address information at any stage.
• Using an intermediary, a proxy, a mixing service or any technology whose purpose is to defeat screening.

An attempt to evade sanctions is treated with the same seriousness as a completed breach, and NioX may act on an attempt exactly as it would act on a confirmed match.

07Customer obligations

Each applicant and account holder must provide accurate, complete and current information at onboarding and whenever NioX requests it, and must inform NioX without delay of any change to their identity, ownership, control, residence or circumstances that bears on this policy.

Each applicant and account holder must confirm that they are not a designated person, that they are not owned or controlled by a designated person and that they are not acting for one. Providing false or incomplete information, or failing to disclose a relevant change, is a breach of this policy and of the terms of service, and NioX may suspend, restrict or close the account and file a report as a result.

08Governance, training and records

This policy is owned by the compliance function, which may block an account, freeze an asset, refuse a transaction and file a report entirely on its own authority, with no requirement to obtain clearance from the commercial side of the business. The rights reserved to NioX throughout this policy may be exercised by the compliance function at its discretion.

Everyone who joins completes sanctions training at the outset and repeats it no less than once each year afterwards.

The results of checks, the decisions taken on review, the blocks applied, the assets frozen and the reports filed are recorded and retained for a minimum of five years, and for longer whenever the competent authority requires it.

NioX reviews and updates this policy as sanctions measures and the technology used to apply them develop, and the current version always prevails.