Legal & Regulation

AML/KYC standards and the Bitunix Market Conduct, Account Integrity, and Enforcement Rulebook.

Risk warning: Trading crypto assets and derivatives carries a high level of risk. You may lose some or all of your capital. Never invest money you cannot afford to lose.

Operator

Operator: Bitunix
Support: support@Bitunix.trading

Sources: Bitunix AML Policy · Market Conduct Rulebook

Anti-Money Laundering (AML / KYC)

This Policy relates to Bitunix's anti-money laundering and countering the financing of terrorism (“AML/KYC”) policies and procedures. This Policy is solely for the purpose of providing general information and is not, in any way, legally binding either on Bitunix and/or on any other person(s) (natural or otherwise).

1. Bitunix's Principles and Approach to AML/KYC Efforts

Bitunix is committed to supporting AML/KYC efforts. In principle, we are committed to, amongst other things:

exercising due diligence when dealing with our customers, natural persons appointed to act for our customers ‘behalf;
conducting our business in conformity with high ethical standards, and to, as far as possible, guard against establishing any business relations that is or may be connected with or may facilitate money-laundering or terrorism-financing;
we will, to the fullest extent possible, assist and cooperate with relevant law authorities to prevent the threat of money-laundering and terrorism-financing.

2. Bitunix's Approach to Risk Assessment and Risk Mitigation

The first layer includes a stringent customer identification(KYC) program, including verifying the identity of our customers, whether individuals or entities. In addition to obtaining identification documents, we obtain for non-natural persons their entities’ beneficial owners/natural persons consistent to international standards such as the Financial Action Task Force (FATF).

The second layer includes a risk-based system to warrant additional customer due diligence(CDD). To accomplish this, we screen our customers (including beneficial owners) against the entities/persons in any government-provided lists of sanctioned individuals and entities. We also may screen against other lists on a discretionary basis to protect our reputation and customers.

The third layer includes ongoing monitoring for suspicious activity. If our program suspects or has reason to suspect suspicious activities have occurred, we will file suspicious activities reports with local regulators. A suspicious transaction is often inconsistent with a customer’s known and legitimate business, or personal activities.

These are the primary components of our compliance program; however, the most important glue or connection to these layers are our leadership team and staff, including AML/Risk personnel that execute training, oversight and a sound compliance culture.

Risk Assessment

We envisage that the majority of our customers would be retail customers, and that we would, as of the date of this Policy.

In this regard, we would:

a. document and/or collect documentation in relation to:

1) the identities of our customers;

2) the countries or jurisdictions that our customers are from or in; and

b. ensure that, to the best of our knowledge, skill and ability, our customers, connected persons of a customer, natural persons appointed to act on behalf of a customer, beneficial owners of a customer will be assessed and screened with the assistance of List of Designated Individuals and Entities which include (but are not limited to) the categories such as:

The Government of the Hong Kong SAR Gazette, United States Office of Foreign Assets Control (OFAC) Sanctions Lists, and the United Nation Security Council Sanctions List, etc

Risk Mitigation

If identified, we shall not deal with any persons identified in the List of Designated Individuals and Entities.

3. Our Approach to New Products, Practices and Technologies

We shall be properly advised, in relation to, identifying and assessing the money laundering and terrorism financing risks that may arise in relation to:

the development of new products and new business practices, including new delivery mechanisms;
the use of new or developing technologies for both new and pre- existing

We shall especially pay special attention to any new products and new business practices, including new delivery mechanisms, and new or developing technologies, that favour anonymity such as digital tokens (whether security, payment and/or utility tokens) that favour anonymity.

4. Our Approach to Customer Due Diligence (“CDD”)

We do not open, maintain or accept anonymous accounts or accounts in fictitious names.

We do not establish business relations with, or undertake a transaction for a customer that we have any reasonable grounds to suspect that the assets or funds of a customer are proceeds of drug dealing or criminal conduct. We shall lodge a Suspicious Transaction Report and extend a copy to the relevant Financial Intelligence Unit for such transactions.

4.1、We perform Customer Due Diligence:

when we establish business relations with any customer;
when we undertake any transaction for any customer whom we had not established business relations with;
when we effect or receive cryptocurrency by transfer for any customer whom we had not established business relations with;
when we have suspicion of money-laundering or terrorism financing;
when we have doubts about the veracity or adequacy of any information.

When we suspect that 2 or more transactions are or may be related, linked or the result of a deliberate restructuring of an otherwise single transaction into smaller transactions in order to evade the Prevention of Money Laundering and Countering the Financing of Terrorism measures, we shall treat the transactions as a single transaction and aggregate their values for the purpose of complying with Prevention of Money Laundering and Countering the Financing of Terrorism principles.

4.2、Identifying our Customers

We shall identify each of our customers.

To identify our customers, we shall obtain, at least:

their full names, including aliases;
their unique identification numbers (such as an identity card number, birth certificate number, or passport number, or where the customer is not a natural person, their business registration numbers); or
their registration address, or if applicable, their registered business address, and if different, their principal place of business;

AND

their date of births, establishment, incorporation or registration; and
their nationality, place of incorporation or registration

Where the customer is a legal person or legal arrangement, we shall apart from obtaining the relevant information as aforesaid above, identify its legal form, constitution and powers that regulate and bind the legal person or legal arrangement; we shall also identify connected parties of it (e.g., directors, partners of and/or persons having executive authority of it), by obtaining at least the following information of each connected party:

full name, including aliases; and
unique identification number such as identify card number, birth certificate number, or passport number of the connected party).

Verifying the Identities of our Customers

We shall verify the identities of our customers using reliable, independent source data, documents or information. Where our customer is a legal person or legal arrangement, we shall verify the legal form, proof of existence, constitution and powers that regulate and bind the customer, using reliable, independent source data, documents or information.

Identifying and Verifying the Identities of Natural Persons Appointed to Act on a Customer’s behalf

Where a customer appoints 1 or more natural person to act on his behalf in establishing business relations with us, or if the customer is not a natural person, we shall:

identify each natural person who acts or is appointed to act on behalf of the customer by obtaining:
their full name;
their unique identification number;
residential address;
date of birth;
nationality; and'
verify the identities of the aforesaid natural persons using reliable, independent source data, documents or
We shall also verify due authority of each natural person appointed to act on behalf of our customers by obtaining:

appropriate documentary evidence authorising the appointment of such natural persons by our customers;

the specimen signature of each natural person

Where the customer is a Government entity, we shall only obtain such information as may be required to confirm that the customer is a Government entity as asserted.

Identifying and Verifying Beneficial Owners

We will inquire if there exist any beneficial owners in relation to a customer.

Where there is 1 or more beneficial owner in relation to a customer, we shall identify the beneficial owners and take reasonable measures to verify the identities of the beneficial owners using relevant information or data obtained from reliable, independent sources. We shall:

if the customer is a legal person –

identify the natural persons (whether acting alone or together) who ultimate own the legal person;

where there is doubt as to whether as to whether natural persons who ultimately own a legal person are the beneficial owners or where no natural person ultimately own the legal person, identify the natural persons (if applicable) who ultimately control the legal person or have ultimate effective control of the legal person; and

where no natural persons are identified, identify natural persons having executive authority in such legal persons;

if the customer is a legal arrangement –

for trusts, identify the settlor, the trustee, the protector (if applicable), the beneficiaries, any natural person exercising ultimate ownership, ultimate control or ultimate effective control over the trust; and

for other types of legal arrangements, identify person in equivalent positions.

Where our customer is not natural person, we shall identify the nature of our customers’ business, its ownership and control structure.

We shall be required if there exist any beneficial owners for customers who are:

an entity listed on the stock exchange;
an entity listed on a stock exchange that is subject to regulatory disclosure requirements; and requirements relating to adequate transparency relating to its beneficial owners;
a financial institution;
a financial institution that is subject to and supervised for compliance with AML/CFT requirements consistent with standards set by FATF; or
an investment vehicle where the managers are financial institutions, or are subject to and supervised for compliance with AML/CFT requirements consistent with standards set by the FATF;

unless we have doubts about the veracity of the CDD information, or suspect that our customers, business relations with, or transactions for the customer, may be connected with money laundering or terrorism financing.

We shall also document the basis for our determination.

Information on the Purpose and Intended Nature of Business Relations and Transactions Undertaken without an Account being Opened*

We shall, when processing the application to establish business relations or undertake transactions without being opened, understood and as appropriate, obtain from the customer information as to the purpose and intended nature of business relations or transaction.

Review of Transactions Undertaken without an Account being Opened*

Where we undertake one or more transactions for a customer without an account being opened (“current transaction”), we shall review the earlier transactions undertaken by that customer to ensure that the current transaction is consistent with our knowledge of the customer, its business and risk profile and where appropriate, the source of funds.

Where we establish business relations with a customer, the payment service provider shall review any transaction undertaken before the business relations are established, to ensure that the business relations are consistent with our knowledge of the customer, its business and risk profile and, where appropriate, the source of funds.

We shall pay special attention to all complex, unusually large or unusual patterns of transactions undertaken without an account being opened that has no apparent or visible economic or lawful purpose. We shall, to the extent possible, inquire into the background and purpose of the aforesaid transactions and document its findings with a view to making this information available to the relevant authorities should the need arise.

For the purposes of reviewing transactions undertaken without an account being opened, we shall put in place and implement adequate systems and processes, commensurate with the size and complexity of the payment service provider to:

monitor its transactions undertaken without an account being opened for customers; and
detect and report suspicious, complex, unusually large or unusual patterns of transactions undertaken without an account being

Where there are any reasonable grounds for suspicion that a transaction for a customer undertaken without an account being opened is connected with money laundering or terrorism financing, and where we consider it appropriate to undertake the transaction, the payment service provider shall substantiate and document the reasons for undertaking the transaction.

Ongoing Monitoring

We shall monitor business relations with our customers on an ongoing basis. We shall, during the course of business relations with a customer, observe the conduct of the customer’s account and scrutinise transactions undertaken throughout the course of business relations, to ensure that the transactions are consistent with our knowledge of the customer, its business and risk profile and where appropriate, the source of funds.

We shall perform our risk mitigation measures where the transaction involves a transfer of cryptocurrency to or receipt of cryptocurrency from an entity other than:

a financial institution; or
a financial institution that is subject to and supervised for compliance with AML/CFT requirements consistent with standards set by the FATF.

We shall pay special attention to all complex, unusually large or unusual patterns of transactions, undertaken throughout the course of business relations, that have no apparent or visible economic or lawful purpose. We shall, to the extent possible, inquire into the background and purpose of the aforesaid transactions and document its findings with a view to making this information available to the relevant authorities should the need arise.

For the purposes of ongoing monitoring, we shall put in place and implement adequate systems and processes, commensurate with the size and complexity of the payment service provider to:

monitor its business relations with customers; and
detect and report suspicious, complex, unusually large or unusual patterns of transactions undertaken throughout the course of business relations.

We shall ensure that the CDD data, documents and information obtained in respect of customers, natural persons appointed to act on behalf of the customers, connected parties of the customers and beneficial owners of the customers, are relevant and kept up-to-date by undertaking reviews of existing CDD data, documents and information, particularly for higher risk categories of customers.

Where there are any reasonable grounds for suspicion that existing business relations with a customer are connected with money laundering or terrorism financing, and where we consider it appropriate to retain the customer:

we shall substantiate and document the reasons for retaining the customer; and

the customer’s business relations with us shall be subject to commensurate risk mitigation measures, including enhanced ongoing monitoring.

Where we assess the customer or the business relations with the customer to be of higher risk, the payment service provider shall perform enhanced CDD measures, which shall include obtaining the approval of our senior management to retain the customer.

CDD Measures for Non-Face-to-Face Business Relations or Non-Face-to-Face Transactions Undertaken without an Account Being Opened*

We shall develop policies and procedures to address any specific risks associated with non-face-to-face business relations with a customer or nonface-to-face transactions undertaken without an account being opened for a customer (“non-face-to-face business contact”).

We shall implement the policies and procedures when establishing business relations with a customer and when conducting ongoing due diligence.

Where there is no face-to-face contact, the payment service provider shall perform CDD measures that are at least as stringent as those that would be required to be performed if there was face-to-face contact.

Where a payment service provider conducts its first non-face-to-face business contact, the payment service provider shall, at his or its own expense, appoint an external auditor or an independent qualified consultant to assess the effectiveness of the policies and procedures, including the effectiveness of any technology solutions used to manage impersonation risks.

We shall appoint an external auditor or an independent qualified consultant to carry out an assessment of the new policies and procedures, and shall submit the report of the assessment to the Authority no later than one year after the implementation of the change in policies and procedures.

Reliance by Acquiring Payment Service Provider on Measures Already Performed

When we (“acquiring payment service provider”) acquires, either in whole or in part, the business of another payment service provider, we shall perform the measures on the customers acquired with the business at the time of acquisition except where the acquiring payment service provider has:

acquired at the same time all corresponding customer records (including CDD information) and has no doubt or concerns about the veracity or adequacy of the information so acquired; and
conducted due diligence enquiries that have not raised any doubt on the part of the acquiring payment service provider as to the adequacy of AML/CFT measures previously adopted in relation to the business or part thereof now acquired by the acquiring payment service provider, and document such process.

Measures for Non-Account Holder

If we undertake any transaction for any customer who does not otherwise have business relations with us, we shall:

perform CDD measures as if the customer had applied to the payment service provider to establish business relations; and
record adequate details of the relevant transaction so as to permit the reconstruction of the transaction, including the nature and date of the transaction, the type and amount of currency involved, the value date, and the details of the payee or beneficiary

Timing for Verification

We shall complete verification of the identity of a customer, natural persons appointed to act on behalf of the customer and beneficial owners of the customer before:

the payment service provider establishes business relations with the customer;
the payment service provider undertakes any transaction for the customer, where the customer has not otherwise established business relations with the payment service provider; or
the payment service provider effects or receives digital payment tokens by value transfer for the customer, where the customer has not otherwise established business relations with the payment service provider.
We provider may establish business relations with a customer before completing the verification of the identity of the customer, natural persons appointed to act on behalf of the customer and beneficial owners of the customer if:

the deferral of completion of the verification is essential in order not to interrupt the normal conduct of business operations; and

the risks of money laundering and terrorism financing can be effectively managed by the payment service

Where we establish business relations with a customer before verifying the identity of the customer, natural persons appointed to act on behalf of the customer, and beneficial owners of the customer, we shall:

develop and implement internal risk management policies and procedures concerning the conditions under which such business relations may be established prior to verification; and

complete such verification as soon as is reasonably

Where Measures are Not Completed

Where we are unable to complete the measures as required, we shall not commence or continue business relations with any customer, or undertake any transaction for any customer.

Where we are unable to complete the measures, the payment service provider shall consider if the circumstances are suspicious so as to warrant the filing of an STR.

Completion of the measures means the situation where the payment service provider has obtained, screened and verified (including by delayed verification as allowed under paragraphs 6.43 and 6.44) all necessary CDD information under paragraphs 6, 7 and 8, and where the payment service provider has received satisfactory responses to all inquiries in relation to such necessary CDD information.

Joint Accounts

In the case of a joint account, we shall perform CDD measures on all of the joint account holders as if each of them were individual customers of the payment service provider.

Screening

We shall screen a customer, natural persons appointed to act on behalf of the customer, connected parties of the customer and beneficial owners of the customer against relevant money laundering and terrorism financing information sources, as well as lists and information provided by the Authority for the purposes of determining if there are any money laundering or terrorism financing risks in relation to the customer.

We shall screen the people:

when, or as soon as reasonably practicable after, we establish business relations with a customer;
before we undertake any transaction for any customer who has not otherwise established business relations with the payment service provider;
before we effect or receive digital payment tokens by value transfer, for a customer who has not otherwise established business relations with us;
on a periodic basis after we establish business relations with our customers; and
when there are any changes or updates to:
the lists and information provided by the Authority to the payment service provider; or
the natural persons appointed to act on behalf of a customer, connected parties of a customer or beneficial owners

We shall screen all value transfer originators and value transfer beneficiaries, against lists and information provided by the Authority for the purposes of determining if there are any money laundering or terrorism financing risks.

We shall document the results of all screenings.

5. Our Approach to Enhanced Customer Due Diligence

Politically Exposed Persons

We shall use all reasonable means to determine if a customer, any natural person appointed to act on behalf of a customer, any connected party of the customer or any beneficial owner of the customer, is a politically exposed person, or a family member or close associate of a politically exposed person.

We shall, in addition to performing CDD measures, perform at least the following enhanced due diligence measures where a customer or any beneficial owner of the customer is determined by us to be a politically exposed person, or a family member or close associate of a politically exposed person:

obtain approval from senior management to establish and continue business relations with the customer;
establish by reasonable means, the source of wealth and source of funds of the customer and any beneficial owner of the customer; and
conduct, during the course of business relations with the customer, enhanced monitoring of the business relations with the customer. We shall increase the degree and nature of monitoring for any transactions that appear unusual

Higher Risk Categories

We recognise that the following circumstances where a customer presents or may present a higher risk for money laundering or terrorism financing include but are not limited to the following:

where a customer or any beneficial owner of the customer is from or in a country or jurisdiction in relation to which the FATF has called for countermeasures, the payment service provider shall treat any business relations with or transactions for any such customer as presenting a higher risk for money laundering or terrorism financing; and

where a customer or any beneficial owner of the customer is from or in a country or jurisdiction known to have inadequate AML/CFT measures, as determined by the payment service provider for itself or notified to payment service providers generally by the Authority or other foreign regulatory authorities, the payment service provider shall assess whether any such customer presents a higher risk for money laundering or terrorism

We will perform enhanced CDD for customers who present a higher risk for money laundering or terrorism financing or any customer the Authority notify to us as presenting higher risk for money laundering and terrorism financing.

6. Our Approach to Bearer Negotiable Instrument and Restriction of Cash Payout

We will not make any payment for any sum of money in the form of a bearer negotiable instrument.

We will not pay any cash in any amount in the course of carrying on our business.

7. Record Keeping

We will keep proper records as required for a time period of at least 5 years.

8. Personal Data

We will safeguard the personal data of our customers in the manner prescribed.

9. Suspicious Transactions Reporting (“STR”)

We will inform the relevant authorities and file STR Reports as required by law. We will also keep all records and transactions relating to all such transactions and STR Reports.

Our Policies on Compliance, Audit and Training

Amongst other things, we shall and take proactive measures in regularly training our employees and employees on AML/CFT matters.

Enterprise-wide money-laundering/terrorism financing risk assessment

We will employ and enterprise-wide money-laundering/terrorism financing risk assessment in 3 phases:

Phase 1: Assessing inherent risk

We will assess the inherent risk in relation to our:

customer or entity: we will make an assessment in relation to our customers and/or entities we deal with;
product or services: we will and are mindful of who we serve in our cryptocurrency OTC services;
Geographical level: we will not deal with customers from the List of Designated Individuals and Entities.

Phase 2: Assessing mitigating control

We will assess our mitigating controls in relation the aforesaid, any and/or all customer(s) whom we find suspicious will be first monitored, followed by exercising enhanced due diligence.

Phase 3: Assessing residual risk

We will assess our residual risks after assessing our mitigating controls.

Thank you for your trust and support in Bitunix!

Bitunix Team

Disclaimer

This article is not intended to provide:

(i) investment advice or investment recommendations;

(ii) an offer, invitation, or solicitation to buy, sell, or hold digital assets;

(iii) financial, accounting, legal, or tax advice.

Digital assets, including stablecoins and NFTs, carry significant risk and price volatility. Evaluate whether trading or holding digital assets is appropriate for your financial situation. Seek guidance from your legal, tax, or investment adviser regarding your specific circumstances.

Bitunix assumes no responsibility for any investment outcomes. You are solely responsible for understanding and complying with all applicable local laws and regulations.

Market Conduct, Account Integrity & Enforcement

This Rulebook forms part of the contractual framework governing the use of the Bitunix Platform and applies to every person who accesses or uses any Bitunix product or service.

It establishes the standards of conduct applicable to all users and provides the framework under which Bitunix may monitor market activity, investigate suspected misconduct, implement protective measures and take enforcement action where necessary to preserve market integrity, platform security and user protection.

This Rulebook applies in addition to the Bitunix User Agreement, the Privacy Policy, the Bitunix Restricted Regions and User Eligibility Notice, the Risk Disclosure, the Anti-Money Laundering Policy, product-specific rules and any other policies published by Bitunix from time to time. Together, these documents govern the relationship between Bitunix and its users.

In the event of any inconsistency, applicable law shall prevail. Subject to applicable law, the Bitunix User Agreement shall prevail over this Rulebook unless expressly stated otherwise. This Rulebook shall prevail over any campaign or promotional rules to the extent necessary to protect market integrity, platform security or regulatory compliance.

1.2 Interpretation

This Rulebook shall be interpreted in a manner consistent with its purpose of maintaining a fair, orderly and secure marketplace.

In determining whether conduct constitutes a breach of this Rulebook, Bitunix may consider the economic substance and commercial purpose of the relevant activity, the overall pattern of trading, relationships between accounts, the practical effect of the conduct and the totality of the surrounding circumstances, rather than merely the legal form, technical structure or appearance of any individual transaction or arrangement.

The examples contained in this Rulebook are illustrative only and do not constitute an exhaustive list of prohibited conduct. Conduct not expressly described in this Rulebook may nevertheless constitute a breach where Bitunix reasonably determines that such conduct is inconsistent with the objectives of this Rulebook or otherwise threatens market integrity, platform security, regulatory compliance or the legitimate interests of users.

1.3 Powers of Bitunix

To maintain the integrity and security of the Platform, Bitunix may monitor user activity, conduct reviews and investigations, request information and supporting documentation, verify user information, assess account risk, restrict or suspend access to products or services, cancel, reverse or adjust transactions where appropriate, recover improperly obtained rewards or benefits, and take any other action reasonably necessary to protect the Platform, its users or its legal and regulatory obligations.

Where Bitunix reasonably considers it necessary to prevent ongoing harm, preserve evidence or protect market integrity, protective measures may be implemented before an investigation has concluded.

Nothing in this Rulebook limits Bitunix's right to take immediate action where required for security, legal, regulatory or operational reasons.

1.4 User Responsibilities

Users are expected to use the Platform honestly, fairly and in good faith and only for lawful and legitimate purposes. Each user must comply with this Rulebook, the Bitunix User Agreement and all applicable Bitunix policies, provide complete and accurate information whenever requested, cooperate fully with any compliance review or investigation and follow any reasonable instruction issued by Bitunix in connection with risk management, regulatory compliance or platform security.

Users must not engage in conduct that undermines market integrity, circumvents platform controls, interferes with the proper operation of the Platform or unfairly prejudices other users. A failure to cooperate with Bitunix during a review or investigation may itself constitute a breach of this Rulebook and may result in the application of protective measures or enforcement action.

CHAPTER 2

MARKET CONDUCT AND PROHIBITED ACTIVITIES

#### 2.1 General Standard of Conduct

The Bitunix Platform is intended to facilitate genuine market participation and legitimate trading activities. Users are expected to conduct their activities independently, honestly and in good faith, and to use the Platform only in a manner consistent with its intended commercial purpose.

No user may engage in any conduct that undermines market integrity, interferes with the orderly operation of the Platform, circumvents applicable rules or controls, or otherwise obtains an unfair advantage over other users. Compliance with the literal wording of this Rulebook shall not, by itself, prevent Bitunix from determining that particular conduct is abusive where its purpose, economic substance or practical effect is inconsistent with the objectives of this Rulebook.

#### 2.2 Market Manipulation

Users must not engage in any activity that creates, attempts to create or is reasonably capable of creating a false or misleading appearance of market activity, liquidity, trading volume, supply, demand or price.

Market manipulation may arise from a single transaction, a series of transactions or coordinated activity between multiple accounts or participants. Whether a particular practice constitutes manipulation shall be determined by reference to all relevant circumstances, including the user's intent where it can reasonably be inferred, the foreseeable effect of the conduct and its overall commercial context.

Without limiting the generality of this provision, market manipulation includes conduct commonly known as wash trading, self-trading, spoofing, layering, quote stuffing, painting the tape, momentum ignition, ramping, market cornering, abusive squeezing, artificial liquidity creation and any comparable practice designed to distort genuine market conditions or interfere with fair price discovery.

The absence of actual market impact or financial loss shall not prevent Bitunix from determining that manipulative conduct has occurred where the available evidence reasonably demonstrates an attempt to manipulate the market.

#### 2.3 Artificial Trading and Coordinated Activity

The Platform is designed for users who assume, manage or transfer genuine market risk. Users must not establish, participate in or facilitate any arrangement that artificially removes, transfers, predetermines or neutralises genuine market exposure for the primary purpose of obtaining platform benefits, promotional incentives or other commercial advantages.

Bitunix may regard trading activity as abusive where multiple accounts, participants or entities coordinate their trading behaviour to transfer profits or losses, predetermine trading outcomes, manipulate rankings or competitions, circumvent platform restrictions or otherwise obtain benefits that would not ordinarily arise through genuine and independent market participation.

The existence of separate accounts, different legal entities or different registered users shall not prevent Bitunix from assessing their conduct collectively where there are reasonable grounds to conclude that the relevant activity forms part of a coordinated arrangement or serves a common commercial objective.

#### 2.4 Account Integrity

Each Bitunix account is intended to represent an independent user conducting genuine trading activities.

Users must not create, acquire, control or operate multiple accounts in a manner that circumvents eligibility requirements, platform restrictions, compliance measures or risk controls. Likewise, users must not establish paired, mirrored, offsetting or complementary account structures designed to reduce genuine market exposure, transfer value between accounts or manipulate the operation of the Platform.

Where Bitunix reasonably believes that two or more accounts are connected through ownership, control, beneficial interest, trading behaviour, funding arrangements, devices, networks or any other relevant relationship, Bitunix may consider those accounts collectively when applying this Rulebook.

#### 2.5 Abuse of Promotions and Platform Benefits

Promotions, campaigns, competitions, bonuses, rebates, referral programmes and other incentives are intended to reward genuine participation in the Platform.

Users must not exploit such programmes through artificial trading activity, coordinated participation, repetitive trading structures, reward farming, artificial qualification or any other arrangement that is inconsistent with the intended purpose of the relevant programme.

Bitunix may disregard any activity that it reasonably considers artificial when determining eligibility for rewards or promotional benefits. Where benefits have been obtained through abusive conduct, Bitunix may refuse, cancel, recover or adjust those benefits together with any profits directly attributable to them.

Participation in any campaign or promotional programme does not create an unconditional right to receive or retain any reward until Bitunix has completed such verification and compliance review as it reasonably considers appropriate.

#### 2.6 Technical Abuse, Misrepresentation and Circumvention

Users must not exploit software defects, pricing anomalies, latency, system vulnerabilities, operational errors or unintended platform functionality for commercial advantage.

Users must not provide false, misleading or incomplete information during registration, identity verification, compliance reviews, investigations, appeals or any other interaction with Bitunix. Nor may users conceal the true nature of their trading activities, account ownership or relationships between accounts, or otherwise seek to circumvent jurisdictional restrictions, platform controls, compliance requirements or other measures implemented by Bitunix.

Any attempt to circumvent this Rulebook may constitute a violation irrespective of whether the attempt ultimately succeeds. Likewise, a failure to cooperate with a reasonable request made by Bitunix during a compliance review or investigation may itself constitute a separate breach of this Rulebook.

2.7 Exploitation of Abnormal Market Conditions

Users must not knowingly exploit abnormal market conditions, pricing anomalies, valuation errors, delayed market adjustments, technical malfunctions, operational errors or other unintended circumstances affecting the operation of the Platform.

CHAPTER 3 MARKET SURVEILLANCE, INVESTIGATIONS AND INFORMATION REQUESTS

3.1 Market Surveillance

Bitunix continuously monitors activity across the Platform for the purpose of maintaining fair, orderly and secure markets. Monitoring may be carried out through automated systems, manual reviews or any other methods reasonably considered appropriate by Bitunix.

Market surveillance is not limited to completed transactions. Bitunix may monitor orders, cancellations, account activity, trading behaviour, funding activity, campaign participation, device information, blockchain transactions and any other information relevant to the operation and security of the Platform.

The existence of market surveillance does not limit Bitunix's ability to conduct further reviews or investigations whenever additional information becomes available.

3.2 Investigations

Bitunix may initiate a review or investigation whenever it reasonably considers that further examination is necessary.

An investigation may arise from automated alerts, abnormal trading activity, unusual account behaviour, suspicious transactions, customer complaints, compliance reviews, security incidents, technical alerts, campaign reviews, reports from third parties, requests from regulators or law enforcement agencies, or any other information that reasonably indicates further review may be appropriate.

Bitunix is not required to establish that a violation has occurred before commencing an investigation, nor is it required to disclose the source of any information giving rise to an investigation.

3.3 Information Requests

During a review or investigation, Bitunix may request any information or documentation reasonably relevant to the matter under consideration.

Such requests may relate to identity verification, source of funds, source of wealth, beneficial ownership, account control, trading activity, transaction history, business activities, device information or any other information that Bitunix reasonably considers necessary to assess compliance with this Rulebook or applicable law.

Users are expected to provide complete, accurate and timely responses. Information that is false, misleading, incomplete or deliberately withheld may itself constitute a breach of this Rulebook.

3.4 Verification

Bitunix may verify any information provided by users using internal records, blockchain analytics, transaction analysis, device analysis, public sources, third-party verification providers or any other lawful verification method.

Where the available information is inconsistent, incomplete or gives rise to reasonable compliance concerns, Bitunix may require further verification before permitting continued use of the Platform or particular services.

Bitunix is not required to rely exclusively on information supplied by a user and may independently assess the reliability and completeness of any explanation or supporting documentation.

3.5 Related Accounts

Where there are reasonable grounds to believe that multiple accounts are connected, coordinated or subject to common ownership or control, Bitunix may review those accounts collectively.

In determining whether accounts are related, Bitunix may consider all relevant circumstances, including ownership, beneficial interests, funding sources, devices, IP addresses, trading patterns, transaction behaviour, operational control, commercial relationships or any other information reasonably available at the time.

Separate registrations or differences in legal ownership shall not prevent Bitunix from treating multiple accounts as related where the overall evidence reasonably supports such a conclusion.

3.6 Confidentiality of Investigations

To preserve the integrity of its investigations, Bitunix is not required to disclose its surveillance systems, monitoring methodologies, internal risk models, investigative techniques, detection thresholds, compliance procedures or internal assessments.

Nor is Bitunix required to provide copies of internal reports, evidence, communications or investigative findings unless disclosure is required by applicable law.

Nothing in this Rulebook obliges Bitunix to disclose information where doing so could prejudice an investigation, compromise platform security, facilitate circumvention of the Platform's controls or otherwise undermine Bitunix's legal or regulatory obligations.

3.7 Investigation Outcomes

Upon completion of an investigation, Bitunix may determine that no further action is required, that continued monitoring is appropriate, that interim protective measures should remain in place or that one or more enforcement actions should be imposed under this Rulebook.

The conclusion of an investigation does not prevent Bitunix from reopening or expanding the matter if additional information subsequently becomes available.

CHAPTER 4 INTERIM PROTECTIVE MEASURES

4.1 General

Where circumstances reasonably indicate that user activity may present a risk to market integrity, platform security, other users or compliance with applicable legal or regulatory obligations, interim protective measures may be implemented at any stage of a review or investigation.

The implementation of a protective measure is precautionary in nature and shall not, of itself, constitute a finding that a breach of this Rulebook has occurred.

4.2 Nature of Protective Measures

Protective measures are intended to preserve the integrity of the Platform while relevant matters remain under review.

Depending upon the circumstances, access to particular products, services or account functions may be restricted, additional verification may be required, trading activity may be limited, withdrawals or deposits may be delayed or restricted, participation in campaigns or reward programmes may be suspended, positions may be required to be reduced or closed, or any other temporary measure reasonably necessary to manage the identified risk may be applied.

The particular measure adopted in any individual case shall depend upon the nature of the identified risk and the information reasonably available at the relevant time.

4.3 Verification Requirements

Where additional verification is considered necessary, continued access to the Platform or particular services may be made conditional upon the completion of further due diligence.

Such verification may include enhanced identity verification, proof of source of funds or source of wealth, confirmation of beneficial ownership, verification of trading purpose, device verification, liveness verification or any other information reasonably required to satisfy legal, regulatory or compliance obligations.

Failure to complete any requested verification within a reasonable period may result in the continuation or expansion of existing protective measures.

4.4 Related Accounts

Where protective measures are considered necessary in respect of one account, the same or similar measures may also be applied to any account reasonably believed to be connected through common ownership, control, beneficial interest or coordinated activity.

The application of protective measures to related accounts does not require conclusive proof of common ownership and may be based upon the information reasonably available at the time.

4.5 Duration and Variation

Protective measures shall remain in place only for so long as reasonably necessary, having regard to the nature of the relevant matter, the information available, the level of user cooperation and any applicable legal or regulatory requirements.

As additional information becomes available, existing measures may be maintained, varied, expanded or lifted without prior notice where circumstances reasonably require.

The removal of a protective measure shall not prevent further action from being taken should subsequent information justify additional review or intervention.

CHAPTER 5 ENFORCEMENT ACTIONS

5.1 General

Where a breach of this Rulebook has been established, or where the available evidence reasonably supports such a conclusion, appropriate enforcement action may be taken having regard to the nature of the conduct, its seriousness, its duration, its impact upon other users or the Platform, any benefit obtained, the level of user cooperation and all other relevant circumstances.

Nothing in this Rulebook requires any particular enforcement measure to be applied in any particular order. Different measures may be imposed individually or in combination according to the circumstances of the case.

5.2 Available Enforcement Measures

Enforcement action may include the issuance of warnings, enhanced monitoring, disqualification from campaigns or promotional programmes, cancellation or recovery of rewards, adjustment or reversal of transactions, removal of profits or other benefits improperly obtained, restrictions upon trading or particular services, suspension or closure of accounts, refusal of future access to the Platform, disclosure to competent authorities where required or appropriate, or any other measure reasonably necessary to preserve market integrity, platform security or compliance with applicable law.

Where more than one measure is appropriate, each may be applied independently or concurrently.

5.3 Improper Benefits

No user acquires any vested right to retain profits, rewards, rebates, bonuses, incentives or other benefits obtained through conduct that is inconsistent with this Rulebook.

Where a benefit would not have arisen but for abusive conduct, artificial trading activity, technical exploitation, manipulation, misuse of promotional programmes or any comparable conduct, the benefit may be removed, adjusted or recovered, together with any profits directly attributable to it.

Where reasonably practicable, consideration may be given to distinguishing between user principal, legitimate trading profits and improperly obtained benefits. Nothing in this Rulebook, however, requires any gain determined to be improper to be preserved.

5.4 Transaction Adjustments

Transactions, positions, balances or account records may be adjusted where reasonably necessary to correct technical errors, operational failures, pricing anomalies, abusive conduct or any other circumstance that materially affects the integrity of the Platform.

Any adjustment shall be determined having regard to the information reasonably available at the relevant time and the need to preserve fairness between users and the orderly operation of the market.

5.5 Account Suspension and Closure

Access to the Platform may be suspended or permanently terminated where continued access would present an unacceptable legal, regulatory, operational or market integrity risk.

Closure of an account shall not prevent further action in relation to associated accounts, previously completed transactions or any matter arising before the closure took effect.

A user whose access has been terminated may be refused access to future products or services offered by Bitunix, whether through the same account or otherwise.

CHAPTER 6 REVIEWS AND APPEALS

6.1 Requests for Review

A user who is directly affected by a protective measure or enforcement action may request that the relevant decision be reviewed through the procedures designated by Bitunix.

A request for review should clearly identify the decision being challenged and include any information or supporting documentation that the user considers relevant. Repeating arguments that have already been considered, without presenting any material new information, may result in the request being declined without further review.

The submission of a request for review does not suspend or invalidate any protective measure or enforcement action already in effect.

6.2 Review Process

A review shall be conducted on the basis of the information reasonably available at the time, together with any additional material provided by the user or otherwise obtained during the review.

Further enquiries may be undertaken where considered appropriate. Additional explanations, documents or verification may be requested if necessary to clarify matters relevant to the review.

The review process is administrative in nature and is intended to ensure that decisions are assessed fairly and consistently within the framework of this Rulebook.

6.3 Outcomes

Following completion of a review, the original decision may be affirmed, varied or withdrawn, either in whole or in part.

Where new information materially changes the factual basis upon which the original decision was made, protective measures or enforcement actions may be amended accordingly.

The completion of a review does not prevent further action being taken if subsequent information gives rise to additional compliance concerns or identifies further breaches of this Rulebook.

6.4 Information and Confidentiality

A review does not create any entitlement to disclosure of internal investigations, surveillance records, monitoring methodologies, compliance assessments, legal advice, risk models or any other confidential or proprietary information.

Information may be withheld where disclosure would prejudice an investigation, compromise platform security, facilitate circumvention of the Platform's controls or conflict with applicable legal or regulatory obligations.

6.5 Final Determination

Following completion of the review process, Bitunix shall issue its final determination for the purposes of the Platform's internal procedures.

Nothing in this Rulebook limits any rights or remedies that may otherwise be available under applicable law.

GENERAL PROVISIONS

Amendments

This Rulebook may be amended, supplemented or replaced from time to time to reflect changes in applicable law, regulatory requirements, market practices, technology, security considerations or the operation of the Platform.

Unless otherwise required by applicable law or where immediate implementation is reasonably necessary to protect the Platform or its users, any material amendment shall become effective upon publication through the Platform or by any other method reasonably considered appropriate by Bitunix.

Continued access to or use of the Platform after the effective date of an amendment constitutes acceptance of the revised Rulebook.

Severability

If any provision of this Rulebook is held to be invalid, illegal or unenforceable under applicable law, that provision shall be severed to the extent necessary without affecting the validity or enforceability of the remaining provisions.

Governing Documents

This Rulebook forms part of the contractual framework governing the relationship between Bitunix and its users and shall be read together with the Bitunix User Agreement and all other applicable policies published by Bitunix from time to time.

In the event of any inconsistency, the order of precedence set out in Chapter 1 shall apply.

Effective Date

This Rulebook takes effect on the date published by Bitunix and remains in force until amended or withdrawn.

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