AML Statement · 反洗钱与制裁合规声明

Effective date: October 1, 2026

1. Our Commitment

HONG KONG CONNECT WORLD AFFAIRS LIMITED ("we", "us") is committed to operating BillVerse (the "Platform") responsibly and to preventing its use for money laundering, terrorist financing, fraud, sanctions evasion or any other unlawful purpose. This Statement describes the anti-money-laundering (AML) and counter-terrorist-financing (CTF) measures we apply.

2. Nature of the Business

The Platform provides information listing and inquiry-message matching services only: it does not process any transaction and does not handle, custody or transfer any funds. It therefore does not constitute money transmission, currency exchange, deposit-taking or any licensed financial business. This model materially reduces fund-related money-laundering risk, but does not relieve us of our compliance responsibilities regarding platform use.

3. Customer Due Diligence (KYC)

• All users must complete corporate verification before accessing core features;
• Verification requires a certificate of incorporation, registration number, registered address and contact details;
• Overseas discount funders must additionally provide ultimate beneficial owner (UBO) identification and a business scope statement;
• All verification materials pass through dual review (cloud auto-review + manual review); any update re-enters the review process;
• We may request supplementary materials or reject, suspend or terminate any verification at our discretion based on risk.

4. Sanctions Screening

• Entities located in or controlled from sanctioned jurisdictions may not register or use the Platform, including without limitation: Mainland China, Iran, North Korea, Syria, Cuba, the Crimea/Donetsk/Luhansk regions, Russia, Belarus, Afghanistan and Myanmar;
• We reserve the right to screen all users against sanctions lists;
• Where sanctions risk is identified, we will immediately freeze the account and may present a restricted-access page;
• The Platform applies network-level blocking by default to access from restricted regions.

5. Transaction Monitoring & Suspicious Activity Reporting

• All bill listings and inquiries undergo dual review (cloud auto-review + manual review);
• All key operations (registration, login, publication, review, takedown, suspension) are recorded in immutable audit logs;
• Where suspected money laundering, terrorist financing, fraud or sanctions evasion is identified, we may (and where required by law shall) report to competent authorities without prior notice to the user concerned;
• We will cooperate with competent authorities' investigations and enforcement requests to the extent permitted by law.

6. User Obligations

Users undertake and warrant that they will not:

• Use the Platform for money laundering, terrorist financing, fraud, tax evasion, sanctions evasion or export-control violations;
• Publish bills or upload materials that are untrue, unlawful, improperly sourced or not duly authorized;
• List bills that are forged, altered, lacking genuine trade background, or suspected proceeds of crime;
• Fail to cooperate with due-diligence and verification activities under this Statement.

7. Record Retention

Verification materials, operation logs, review records and business records are retained for at least 7 years from creation for audit, compliance verification and access by competent authorities.

8. Consequences of Violation

Users in violation may face any or all of: warning, content takedown, feature restriction, account freeze, account suspension, blacklisting, refusal of refunds, reporting to competent authorities and cooperation with legal proceedings.

9. Updates

We may update this Statement from time to time. Material changes will be notified through prominent means such as in-app notices. Continued use after updates constitutes acceptance.

10. Contact Us