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AML Policy

BlackSplit AML Policy.

1. Policy Statement and Platform Positioning

BlackSplit is committed to preventing money laundering, terrorist financing, and other illicit financial activities conducted through or in connection with the use of its platform, and to maintaining a compliant and secure transaction and service environment.

BlackSplit operates as a technology-driven service and platform support system. Its core function is to provide technical tools, system capabilities, and related support services to assist users in conducting lawful activities and utilizing platform functionalities within the platform environment.

This Anti-Money Laundering Policy (the "Policy") is intended to identify and mitigate compliance risks that may arise from platform usage, while clearly defining BlackSplit's role as a neutral platform service provider.

All users of the platform and other relevant participants are required to comply with this Policy and with applicable laws and regulations in connection with their use of the platform.

2. Platform Role and User Definitions

BlackSplit's platform role is strictly limited to the following functions:

  • Providing technical support, system infrastructure, and information display services related to platform usage.
  • Providing payment-related technical support and system interface services, as well as operational support related to fund visibility, dispute handling, and platform functionality.
  • Implementing reasonable compliance and risk management measures strictly within the scope of its platform service role.

For the purposes of this Policy:

  • "Users" refer to registered entities or individuals who access or use platform functions or services.
  • Any business arrangements, fund movements, or related activities between users are independently determined by the users and remain their sole responsibility.

Each user acts as an independent participant and is solely responsible for the legality of their actions, transactional compliance, and sources of funds.

To the extent required by applicable law, users remain responsible for ensuring that funds involved in platform-related activities are derived from lawful sources.

3. Legal and Regulatory Framework

BlackSplit's AML compliance framework is informed by and aligned with generally recognized international standards, including but not limited to:

  • The Financial Action Task Force (FATF) Recommendations on Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT).
  • Applicable AML and CFT laws and regulations in the jurisdictions where BlackSplit operates or provides services.
  • Compliance requirements imposed by payment service providers, financial institutions, and relevant partners.

This Policy is designed to align with recognized AML principles and is implemented only to the extent required by applicable laws and regulatory requirements.

Given BlackSplit's platform service nature, the compliance measures adopted under this Policy are intended to be appropriate and proportionate to its business model and risk profile.

4. Risk-Based Anti-Money Laundering Approach

BlackSplit applies a risk-based approach to AML compliance, under which user behavior and related activities are assessed in an overall and contextual manner.

Users or activities may be categorized into different risk levels based on factors including, but not limited to, behavioral patterns, transaction characteristics, geographic considerations, and payment method risk indicators.

Risk classification is used solely to determine appropriate monitoring, review, or mitigation measures and does not, by itself, indicate illegal or improper conduct.

5. Transaction Monitoring and Suspicious Activity Identification

Within a reasonable and proportionate scope, BlackSplit monitors platform activity to identify patterns that may deviate from the platform's intended use.

Such monitoring does not constitute a determination of illegality and is conducted solely for compliance, risk management, and platform security purposes.

Where appropriate, identified activities may be subject to internal review prior to the implementation of any restrictive measures.

6. Customer Due Diligence and Risk Mitigation Measures

Based on the level of risk identified, BlackSplit may apply proportionate customer due diligence and risk mitigation measures where required by applicable law or payment service provider requirements.

All such measures remain consistent with BlackSplit's role as a platform service provider and do not constitute the provision of financial or payment services.

7. Fund-Related Arrangements, Payment Controls, and Regulatory Cooperation

Any fund-related arrangements associated with the BlackSplit platform relate solely to platform service support and user-initiated fund movements processed by payment service providers, and do not constitute general payment, remittance, money transfer, or custodial services provided by BlackSplit.

Where permitted by applicable law, and for purposes such as dispute resolution, compliance review, or AML assessment, funds processed by payment service providers may be temporarily delayed, restricted, or subject to review within a reasonable period.

Where required by applicable law, BlackSplit may cooperate with payment service providers and competent authorities in relation to AML-related obligations and shall perform its platform-level compliance responsibilities strictly within the scope of its platform service role.

8. Enforcement Measures, Data Protection, and Policy Updates

Where BlackSplit identifies or reasonably suspects violations of applicable AML laws or this Policy, it reserves the right, to the extent permitted by law, to restrict, suspend, or terminate relevant accounts or activities and to conduct internal compliance reviews.

User information and AML-related records are processed and retained in accordance with applicable data protection and privacy laws, generally for no less than five (5) years, unless a longer retention period is required by applicable law.

BlackSplit will periodically review and update this Policy. The latest version will be published on the official website, and continued use of the platform constitutes acceptance of the updated Policy.

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