AML Compliance Program Policy

1.Company Policy

711Proxy adheres firmly to the highest standards of Anti-Money Laundering (AML) and resolutely prohibits any conduct that may involve money laundering, terrorist financing, or other illegal activities. We strictly comply with the Bank Secrecy Act (BSA) and relevant regulatory requirements. The AML policies, procedures, and internal control mechanisms established by us are designed to fully conform to all applicable BSA regulations and FINRA rules. We will regularly review and dynamically update the aforementioned policies in light of changes in regulations and business development to ensure their continued effectiveness and compliance.

2.Scope of Application

This Program applies to all departments, branches, and employees of the organization, covering all business areas (including but not limited to customer account opening, fund deposits and withdrawals, transfer and settlement, product sales, cross-border business, etc.), as well as all anti-money laundering related work processes such as customer identification, transaction monitoring, suspicious activity reporting, and customer record retention.

3.Provide AML Information to Dederal Law Enforcement

We undertake that, unless otherwise required by law, we will not disclose information shared with or by FinCEN. The receipt of a National Security Letter (NSL) shall be kept strictly confidential as top secret. Even if a Suspicious Activity Report (SAR) is filed after receipt of an NSL, such SAR shall focus solely on reporting identified suspicious activities and shall not contain any content related to the NSL.

4.Monitor Accounts with Suspicious Activity

711Proxy will continuously monitor account activity to prevent transactions of any unusual size, volume, pattern or type, taking into account appropriate risk factors and red flags relevant to the business.

Red Flags:

The user has provided abnormal or suspicious identification documents.

Customers whose legitimate source of funds cannot be determined, or who have provided false or materially inaccurate information.

For transactions involving high-risk jurisdictions, we will maintain special vigilance.

A customer may constitute a risk indicator if they are unable to clearly articulate their business scope and business model, or lack basic knowledge of the industry to which they belong.

The customer fails to provide a clear explanation of the connection between their business needs and the selected services, and is also unable to justify the commercial rationale for choosing a specific jurisdiction.

Customer has a prior record of being refused service or having a relationship terminated by other financial institutions; such instances should be noted.

The customer’s registered or correspondence address is associated with multiple unrelated accounts or businesses.

The customer ostensibly acts as an agent in transactions but is secretive about the undisclosed principal they represent and is unwilling to cooperate in providing the identity information of the ultimate beneficial owner.

If a customer conducts business through trusts, shell companies, or private investment companies but refuses to disclose the underlying ownership structure and ultimate beneficial owners, such lack of transparency shall be handled with caution.

If a customer is involved in known legal proceedings (such as criminal, civil, or regulatory cases) that involve crimes, corruption, misuse of public funds, or if their associates have such backgrounds, such circumstances shall be deemed high-risk signals.

The customer’s background is suspicious, or there is a clear inconsistency or contradiction between their overall background and the business activities they engage in.

The customer maintains multiple accounts in the names of family members or corporate entities without an apparent commercial or other legitimate purpose.

Other Potential Red Flags:

The customer is unwilling to provide the information required for transaction reporting.

The customer is indifferent to transaction costs or fees.

The customer’s business, occupation, or financial resources are inconsistent with the content and nature of their activities.

The customer attempts to prevent employees from submitting necessary reports and records.

The customer lacks a clear business philosophy or apparent investment strategy.

5.AML Record Retention

Responsibilities for AML Record Retention and Suspicious Activity Reporting:Shall be performed by the institution’s designated Anti-Money Laundering Compliance Officer and authorized members of their team. Such personnel shall retain the necessary anti-money laundering records, ensure their accuracy, completeness and secure storage, and timely submit Suspicious Activity Reports (SARs) in accordance with regulatory requirements.

6.Senior Manager Approval

The senior management of 711Proxy has formally approved this Anti-Money Laundering Compliance Program in writing. Confirming the reasonableness of this Program, we are committed to upholding the highest standards of anti-money laundering compliance laws and actively preventing any activities that may jeopardize the integrity of the financial system.