Risk Disclosure and Disclaimer
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 used shall have the same meaning as defined in the Terms of Service. In short, we hope that you understand the important risks and compliance issues when trading on the BitradeX platform.
1. Purpose In order to maintain a sound and compliant digital asset trading platform, we have established and implemented a series of anti-money laundering, anti-terrorist financing and trade and economic sanctions systems ("Anti-Money Laundering/Counter-Terrorist Financing/Sanctions System" or "System"). We are committed to promoting legal and transparent business activities and maintaining a good reputation among users, regulators and the digital asset industry.
2. Business Model BitradeX platform is a global digital asset trading platform or trading market where traders trade as buyers and sellers, commonly known as market makers and market takers. In general, our services facilitate transactions that match users with other users, but in certain circumstances specified in the Terms of Service, BitradeX's affiliates may be counterparties to transactions on the BitradeX platform. Our services are available to users through the BitradeX platform operated by BitradeX.
Risk Disclosure: Trading is risky. The risk of loss from trading or holding digital assets can be substantial. Therefore, you should carefully consider whether trading is appropriate for you based on your financial situation.
3. Regulatory Environment We understand that regulators have adopted a variety of approaches to the laws and regulations of digital assets, including some regulators defining or classifying digital assets as convertible virtual currencies (US Financial Crimes Enforcement Agency) or virtual commodities (Hong Kong). As a trading platform, we believe that all digital assets offered on the NohaEx platform belong to innovative alternative asset classes, and therefore, digital assets should not be referred to as money or currency.
Risk Disclosure: Digital assets are not money or legal tender. Digital assets are not backed by any government or central bank. We may sometimes have our own views on the regulatory approaches taken by various government agencies; however, we will always fully comply with the rules and regulations of the countries in which we operate. We regularly discuss with regulators and peers the best way to regulate 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 Regions, which currently include Afghanistan, Algeria, Bangladesh, Bolivia, Canada, Cuba, El Salvador, France and its overseas territories, Hong Kong, Iran, India, Japan, Malaysia, Nepal, Nigeria, North Korea, Syria, the Crimea, Donetsk and Luhansk regions of Ukraine, the United States of America (including all U.S. territories including Puerto Rico, American Samoa, Guam, the Northern Mariana Island and the U.S. Virgin Islands (St. Croix, St. John and St. Thomas)) and Uzbekistan. BitradeX may restrict services in other jurisdictions, including but not limited to Australia (especially for our derivatives-related and centralized exchange-related services), Bahamas (especially for our retail products), Brazil (especially for our derivatives-related and C2C services), Eritrea (especially for our C2C services), Russia (especially for our fiat currency payment services), Singapore currently supports centralized exchange registration, supports top-up, withdrawal, trading (not supporting derivatives), South Korea (especially for our derivatives-related and C2C services), the United Kingdom (especially for our derivatives-related, centralized exchange-related and C2C services).
We cooperate with governments, respect regulations and comply with applicable regulations. As a good corporate citizen, law enforcement agencies may ask us to provide information, and if permitted by law, we will assist law enforcement agencies in their investigations to track down and prevent illegal activities. This also means that the NohaEx platform is only for law-abiding customers. We hope to provide you with services, and at the same time, we also require you to act legally and legally on the BitradeX platform.
4. Our Anti-Money Laundering/Counter-Terrorism Financing System Through a risk-based multi-level control system, we have designed our system to reasonably prevent money laundering and terrorist financing.
The first layer of the system includes a rigorous user identification process, including verifying the identity of individual and corporate users. In addition to obtaining identification documents, we also obtain the identity of the beneficial owners/natural persons of their institutions for non-natural person users in accordance with international standards such as the Financial Action Task Force (FATF).
The second layer includes a risk-based system to ensure that additional customer due diligence is performed. To this end, we screen users (including beneficial owners) against the lists of institutions/individuals published in the Hong Kong Special Administrative Region Government Gazette, the US Office of Foreign Assets Control (OFAC) sanctions list and the United Nations Security Council sanctions list, as well as other government sanctions lists. We may also screen against other lists as appropriate to protect our reputation and users.
The third layer includes continuous monitoring of suspicious activities. If our system suspects or has reason to suspect suspicious transaction activities, we will submit suspicious transaction activity reports to local regulators. Generally, suspicious transactions are inconsistent with the user's known legitimate business or personal activities.
The above are the main components of our compliance system. However, the most important link between these multi-layered risk control systems is our leadership team and employees, including anti-money laundering/risk control personnel who perform training, supervision and form a good compliance culture.
5. Risks and Specific Disclosures Transactions in digital assets are considered to carry a high level of risk. Digital assets are not backed by any government or central bank. The risk of loss from 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 situation.
5.1 Foreign Exchange Conversion 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 be subject to system errors and unexpected failures. If such errors and/or system failures occur (as determined by us in our sole discretion), you may receive a USD or USDT balance that may be different from your local currency balance at the time the payment transaction was initiated. This may result in risk of loss, and you agree that you shall bear all costs associated with any foreign exchange conversion risk resulting from such system errors and/or failures.
5.2 Digital Payment Tokens Risk Notice
If you are a customer of a Digital Payment Tokens (DPT) service provider, the Monetary Authority of Singapore (MAS) requires us to provide you with this risk notice. MAS requires that you:
(a) pay or transfer any money or DPT to your DPT service provider;
(b) enter into an agreement with a third party to buy or sell DPT at the induction of your DPT service provider;
(c) enter into a DPT transfer agreement with a third party pursuant to the arrangements of your DPT service provider;
(d) pay any money or DPT to a third party for the transfer of DPT pursuant to the arrangements of 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 has been exempted by MAS from holding a licence to provide DPT services. Please note that if the business of your DPT service provider or third party fails, you may not be able to recover all money or DPT you paid to the DPT service provider or any other third party mentioned above.
(ii) You should not trade in this DPT if you are not familiar with it. This includes how DPTs are created and how the DPTs you intend to trade are transferred or held by your DPT service provider.
(iii) You should note that the value of DPTs may fluctuate significantly. You should only purchase DPT if you are prepared to accept the risk of losing all the funds you invest in such tokens.
(iv) You should be aware that your DPT service provider, as part of its license to provide DPT services, may provide services related to DPTs that are advertised as having a stable value (commonly referred to as "stablecoins").
5.3 Disclosure on Maintenance of Fiat Currency and Digital Payment Token Custody Accounts (Applicable only to BitradeX SG Pte. Ltd. users)
MAS requires us to disclose to you how your fiat currency and DPT custody accounts are maintained at BitradeX. The fiat currency funds of BitradeX Singapore users will be directly deposited and held in trust in one or more independent custody accounts of one or more duly registered and licensed third-party banking institutions for the benefit of BitradeX Singapore users in accordance with the banking institution's terms of service. BitradeX Singapore users' DPT is held in custody in the secure and isolated hot wallet and cold wallet systems of BitradeX Singapore's affiliates for the benefit of BitradeX Singapore users in accordance with the Safeguard Agreement (no more than 5% of DPT is held in the hot wallet), and BitradeX Singapore strictly supervises and controls the hot wallet and cold wallet systems in accordance with the Safeguard Agreement.
BitradeX Singapore will not perform any operations on your fiat currency and DPT unless you explicitly authorize and instruct. If BitradeX Singapore goes bankrupt, your fiat currency and DPT will not be subject to claims by BitradeX Singapore's creditors in accordance with current 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 US dollars using the conversion rate of the digital asset at the time of the transaction. Trades in non-US dollar base pairs are also converted. Your 30-day trading volume is calculated every day at 00:00 (UTC+8).
All fees will be charged on the assets you purchase. For example, if you buy BTC/USD, the fees are charged in BTC. The rebate is paid in the asset you sold. For example, if you buy BTC/USD, the rebate will be paid in USD.