This Risk Disclosure and Disclaimer should be read together with the BitradeX Terms of Service ( " Terms of Service ") . 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 BitradeX platform.
1. Purpose 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 ( “ AML / CTF / Sanctions System ” or “ System ” ). We are committed to advancing lawful and transparent business activity and to maintaining a good reputation among users, regulators and the digital-asset industry.
2. Business Model BitradeX 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 BitradeX may be the counter-party to trades conducted on the BitradeX platform. Users access our services through the BitradeX platform operated by BitradeX .
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.
3. Regulatory Environment 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 BitradeX platform to fall within an innovative alternative asset class; therefore, digital assets should not be referred to as money or currency.
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, BitradeX 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. BitradeX 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 C2C services), Eritrea (especially regarding our C2C services), Russia (especially regarding our fiat-payment services), Singapore (currently supports centralized-exchange registration, deposits, withdrawals and trading (derivatives not supported)), South Korea (especially regarding our derivatives-related and C2C services), United Kingdom (especially regarding our derivatives-related, centralized-exchange-related and C2C services).
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 BitradeX 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 BitradeX platform.
4. Our AML / CTF System Through a risk-based, multi-layered control system, we have designed our system to reasonably prevent money laundering and terrorist financing.
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).
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.
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.
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.
5. Risks and Specific Disclosures 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. You should carefully consider whether interacting, holding or trading digital assets is suitable for you in light of your financial condition.
5.1 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. In some cases, this foreign-exchange conversion process may experience system errors and unexpected malfunctions. Should such errors and / or malfunctions occur (as determined by us in our sole discretion), you may receive USD or USDT balances that may differ from your local-currency balance at the time the payment transaction was initiated. 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 / or malfunctions.
5.2 Digital Payment Token Risk Warning
If you are a customer of a Digital Payment Token ( DPT ) service provider, the Monetary Authority of Singapore ( MAS ) requires us to provide you with this risk warning. MAS stipulates that before you:
(a) pay or transfer any money or DPT to your DPT service provider;
(b) enter into any agreement to buy or sell DPT with a third party at the instigation of your DPT service provider;
(c) enter into any DPT transmission agreement with a third party arranged by your DPT service provider;
(d) pay any money or DPT to a third party for transmission of DPT arranged by your DPT service provider; or
(e) transfer any digital payment token instrument to your DPT service provider,
you should note the following:
(i) Your DPT service provider is exempted by MAS from holding a licence to provide DPT services. Please note that if your DPT service provider or any third party fails, you may not be able to recover all money or DPT you paid to the DPT service provider or any such other third party.
(ii) You should not trade this DPT if you are not familiar with it. This includes how the DPT is created, and how the DPT you intend to trade is transferred or held by your DPT service provider.
(iii) You should be aware that the value of DPT may fluctuate greatly. You should buy DPT only if you are prepared to accept the risk of losing all the money you put into such tokens.
(iv) You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services relating to DPT that are advertised as having a stable value (commonly referred to as “ stablecoins ” ).
5.3 Disclosure on Maintenance of Fiat and Digital Payment Token Custody Accounts (applicable only to BitradeX SG Pte. Ltd. users)
MAS requires us to disclose to you how your fiat and DPT custody accounts at BitradeX are maintained. Fiat funds of BitradeX 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 BitradeX Singapore users. DPT of BitradeX Singapore users are held for the benefit of BitradeX Singapore users in secure and segregated hot- and cold-wallet systems of BitradeX Singapore’s affiliates under a safeguarding agreement (no more than 5% of DPT is kept in hot wallets), under which BitradeX Singapore exercises strict oversight and control of the hot- and cold-wallet systems.
Unless you expressly authorize and instruct, BitradeX Singapore will not exercise any control over your fiat and DPT . If BitradeX Singapore becomes insolvent, your fiat and DPT will not be subject to claims by BitradeX Singapore’s creditors under applicable laws and practices.
6. Fees
6.1 Trading fees: Your trading fees are determined by your trading volume over the past 30 days. All trading volumes are converted to USD using the digital asset’s exchange rate at the time of the trade. Trades in non-USD base-pair markets are also converted. Your{' '} 30 -day volume is calculated every day at 00:00 (UTC+8) .
All fees are charged in the asset you purchase. For example, if you buy BTC/USD , the fee is charged in BTC . Rebates are paid in the asset you sell. For example, if you buy BTC/USD , the rebate is paid in USD.
6.2 Additional fees and charges: BitradeX offers multiple deposit and withdrawal channels. Deposit and withdrawal fee information can be viewed.
If you select BitradeX as the third-party provider, fees will be charged for credit-card / debit-card transactions ( Visa only).
6.3 Country / region-specific pricing: Country / region-specific pricing may vary depending on the user’s place of residence or location.
7. Contact If you have questions about our customer due-diligence controls or need assistance, please feel free to contact our 24/7 customer-service representatives via live chat or email at the Help Centre.
8. Version This “ Risk Disclosure and Disclaimer ” may be published in different languages. In case of any discrepancy, the English version shall prevail.