HUBCHANGE is committed to maintaining controls designed to detect, prevent, and respond to money laundering, terrorist financing, sanctions evasion, fraud, corruption, market abuse, and other illicit activity.
1. Risk-based approach
HUBCHANGE may apply a risk-based approach to users, businesses, wallets, transactions, assets, countries, RWA projects, and services. Risk levels may change over time based on account activity, transaction behavior, documents, blockchain analytics, sanctions data, regulatory changes, or internal review.
2. KYC and KYB
Users may be required to complete identity verification. Business users may be required to complete KYB, including company documents, authorized representatives, beneficial owners, directors, ownership structure, business purpose, source of funds, and source of wealth.
3. KYT and transaction monitoring
HUBCHANGE may monitor deposits, withdrawals, wallet addresses, transaction hashes, blockchain activity, counterparties, order behavior, trading patterns, and other risk indicators. Transactions may be screened for suspicious activity, sanctioned exposure, high-risk wallets, mixers, scams, darknet markets, stolen funds, or other illicit indicators.
4. Sanctions and restricted activity
Users must not use HUBCHANGE to violate sanctions, export controls, AML laws, counter-terrorist financing rules, or other applicable restrictions. HUBCHANGE may block or restrict users, countries, wallets, assets, transactions, or counterparties where risk is identified.
5. Enhanced due diligence
HUBCHANGE may request additional information, documents, explanations, proof of address, proof of funds, proof of wallet ownership, business records, invoices, contracts, bank statements, or other evidence before allowing or continuing Services.
6. Account restrictions and freezing
HUBCHANGE may delay, reject, freeze, block, review, reverse, or restrict accounts, orders, deposits, withdrawals, wallet addresses, API access, or other Services when required by law, compliance controls, sanctions screening, law-enforcement requests, court orders, suspicious activity reviews, security concerns, or internal risk decisions.
7. Reporting and record keeping
Where required by applicable law or internal controls, HUBCHANGE may keep records, report suspicious activity, respond to lawful requests, and cooperate with regulators, courts, law enforcement, banks, payment providers, and compliance partners.
8. Prohibited behavior
Submitting false documents, using another person’s identity, hiding beneficial ownership, account sharing, selling accounts, using mule accounts, attempting to bypass verification, using VPNs to evade restrictions, concealing source of funds, layering transactions, or using the platform for unlawful purposes is prohibited.
9. RWA project screening
RWA issuers, sponsors, assets, documents, custodians, beneficiaries, ownership structures, contracts, redemption paths, and related parties may be subject to review before listing, trading, transfer, or publication.
10. No waiver of rights
Publication of this AML Policy does not limit HUBCHANGE’s right to apply additional checks, reject activity, restrict accounts, pause services, or take other measures where necessary to protect the platform, users, partners, or comply with applicable requirements.