Guo Wengui / Miles Guo — criminal case · ORDER · ECF #208-3

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- Profile- Balances- Ledger- Deposits- Deposit Addresses- Withdrawals- Redemption Limits- Standard- Addresses- Bank Accounts- Active Orders- Completed Orders- Trades- Tiers- Mail Queue- Notifications- Activity- Error Log- Exploit Attempts- Referrals- Referral Bonuses- Whitelisted IPs- Risk Scoring- API

- Profile- Balances- Ledger- Deposits- Deposit Addresses- Withdrawals- Redemption Limits- Withdrawal Addresses- Bank Accounts- Active Orders- Completed Orders- Trades- Tiers- Mail Queue- Notifications- Activity- Error Log- API Key- Plot Attempts- Referrals- Referral Bonuses- Whitelisted IPs- Risk Scoring

Overall, KYC Onboarding Analyst is of the view that the initial AML/CTF assessment result is consistent with the Customer's profile and does not pose the de- [REDACTED] cision to onboard the Customer with Medium Risk (4%).

- Profile- Balances- Ledger- Transaction Monitoring- Security Question- Support- Manager Deposits- Deposit Addresses- Withdrawals- Redemption Limits- Withdrawal Addresses- Bank Accounts- Active Orders- Completed Orders- Trades- Mail Queue- Notices- Notifications- Activity- Error Log- Exploit Attempts- Referrals- Referral Bonuses- Whitelisted IPs- Risk Scoring

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... and based on the information provided, the KYC Onboarding Analyst supports the decision to onboard the Customer with the view that the initial Medium Risk (Risk Score 355-361) assessment result is consistent with the Customer's profile and

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How many years of experience do you have in crypto trading?

Let us know what your level of experience is with cryptocurrency trading? Please select one:

Please tell us which countries the funds will be received and or transferred from.

How much do you plan to deposit per year (USD and crypto combined)?

Please select the service(s) you plan to use. Select more than one box if necessary. Crypto Trading, tong term investment, Crypto payment Please rell us about your source(s) of wealth? Select more than one box if necessary. Property sale, Employment income, Business profits Please rell us about your source(s) of Income : funds. Select more than one pox if necessary. Pension / social benefits, Investments, Savings Blease tall us about your annual turnover, in individual or business activity, which is handled in crystocurrency. 0-1 0% (none or little of my turnover is in cryptocurrency) Blease tell us about your annual turnover, in individual or business activity, which is handled in cash.

Is your individual schip or pushess registered or conducted in prefrential any 2014 (for instance, free economic zone, offshore jurisdical)

BRESS TEll is about pushess you may conduct in other county(s) pesides where rogistered for tax purposes)

Please tell us about your occupation or business activity.

Please tell us about your current employment status.

Based on the KYC responses, the Customer is Medium Risk considering the following risk factors according Customer Risk Model: Customer: Per Customer's reply in Zendesk, he was a green card holder until he went through official procedures with US embassy in Hong Kong and gave up his green card permanently since 2019. The reason for him to open a Bank of America account (joint account with son) is because he could support his son for college education (i.e. daily expenses), and he may remit some funds to his son for further expenses. Based on KYC questionnaire, customer's score is 20 points. In addition, client is retired and planning to deposit USD10K - 100K annually which accounts for additional 40 points. In total, client's risk score is 60 points which is not shown in KYC questionnaire. Screening is performed against the Customer and there is 0 hit. Overall, Senior KYC onboarding analyst [REDACTED NAME] is of the view that the initial AML/CTF assessment result is consistent with Customer's profile and does not oppose the decision to onboard the Customer. Medium Risk - Risk Score 60. Senior KYC onboarding analyst [REDACTED] 4/29/2021 1:19:19 PM

- Whitelisted IPs- Risk Score- Funding- Transaction Monitoring- Security Questions- Supporting Documents- Redemption Limits- Profile- Balances- Ledger- Deposits- Deposit Addresses- Withdrawals- Withdrawal Addresses- Bank Accounts- Active Orders- Completed Orders- Trades- Tiers- Mail Queue- Notifications- Sessions- Activity- Error Log- Exploit Attempts- Referrals- Referral Bonus

DATE & TIME FULL NAME ROLE RISK SCORE RISK LEVEL

12/28/2021 11:57:00 AM Auto (System) Auto (System) 10 Low

Left Column Right Column |:--- :--- |Risk Settings Login |Mobile Address Sets |Linked Accounts Withdrawal Limits |Specialized IPs Redemption Limits |Deposit Standard Addresses |Transaction Mode Linked Accounts |Security Question Active Orders |Supporting Documents Completed Orders Wallets Tiers Market Outline Notifications Activity Error Log Data Login Attempts Records Referral Bonuses

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Please tell us about your current employment status. Retired Please tell us about your occupation or business activity. 退休人員 Please tell us about business you may conduct in other countries besides where you are registered for tax purpose? No Is your individual activity or business registered or conducted in preferential tax zone (free economic zone, offshore jurisdiction)? No Please tell us about your annual turnover, in individual or business activity, which is handled in cash. 0-10% (none or little of my turnover is in cash) Please tell us about your annual turnover, in individual or business activity, which is handled in cryptocurrency. 0-10% (none or little of my turnover is in cryptocurrency) Please tell us about your source(s) of income. Select more than one box if necessary. Pension, Social benefits Please tell us about your source(s) of wealth? Select more than one box if necessary. Inheritance, Employment income Please select the service(s) you plan to use. Select more than one box if necessary. Crypto trading, Long term investment, Crypto payment How much do you plan to deposit per year (USD and crypto combined)? 10 000-100 000 Please tell us which countries the funds will be received and/or transferred from. China

Let us know what your level of experience is with cryptocurrency trading? Please select one. Beginner How many years of experience do you have in crypto trading? < 1 Year Are you, an immediate family member, or a close associate, entrusted, or have been entrusted, with prominent public functions in any country or international institution? This could be a public office, a government role, a regulatory role or a senior military position, at home or overseas. No

Profile Balances Ledger Deposits Deposit Addresses Withdrawals Redemption Limits Withdrawal Addresses Bank Accounts Active Orders Completed Orders Trades Tiers Mail Queue Notifications Activity Error Log Exploit Attempts Referrals Referral Bonuses WhiteListed IPs Risk Scoring

Transaction Monitoring Security Question Supporting Documents

COMPLYADVANTAGE LINK ComplyAdvantage Link VERIFICATION APPLICATION STATUS Auto-Approved CATEGORY Save & Inform User NUMBER OF ATTEMPT TO JUMIO 1 Reset Risk Score Update History DATE & TIME FULL NAME ROLE RISK SCORE RISK LEVEL 3/6/2022 4:56:08 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:52:03 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:51:48 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:50:14 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:48:58 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:48:16 AM Auto (System) Auto (System) 25 Low 3/6/2022 4:47:03 AM Auto (System) Auto (System) 25 Low

DATE & TIME FULL NAME ROLE RISK SCORE RISK LEVEL 3/6/2022 4:56:08 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:52:03 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:51:48 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:50:14 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:48:58 AM Auto (System) Auto (System) 30 Low 3/6/2022 4:48:16 AM Auto (System) Auto (System) 25 Low 3/6/2022 4:47:03 AM Auto (System) Auto (System) 25 Low

- Profile- Balances- Ledgers- Whitelisted IPs- Risk Score- Monitoring- Transaction Monitoring- Deposits- Deposit Addresses- Withdrawals- Withdrawal Addresses- Security Questions- Bank Accounts- Supporting Documents- Active Orders- Redemption Limits- Completed Orders- Trades- Tiers- API Keys- Internal Queue- Notifications- Activity- Error Log- Exploit Attempts- Referrals- Referral Bonuses

- Profile- Balances- Legal- Whitelisted IPs- Deposits- Risk Scoring- Deposits- Transaction Monitoring- Withdrawal- Security Questions- Withdrawal Addresses- Redemption Limits- Bank Accounts- Supporting Documents- Active- Orders- Completed Orders- Trades- Tiers- Mail Queue- Notifications- Activity- Error Log- Exploit Attempts- Referrals- Referral Bonuses

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Document 208-3 Filed 12/21/23 Page 30 of 50

Labels Values |---|---| Profile Balances Whitelisted IPs Ledger Risk Scoring Deposits Transaction Monitoring Deposit Addresses Security Ques Withdrawals Supporting Docum Redemption Limits ents Withdrawal Addresses Bank Accounts Completed Orders Active Queue Orders Notifications Trades Activity Tiers Error Log Notifications Exploit Attempts Activity Referrals Error Log Referral Bonuses Exploit Attempts Referrals Referral Bonuses

KYC Questionnaire 15/22022 3:0541 MA Risk Score Update History NUMBER OF ATTEMPT TO

SUH RISK LEVEL TOTAL RISK SCORE MANUALRISKSCORE INTERNAL ID

DATE & TIME 19298 Auto-Approved ComplyAdvantage Link Medium 57 5165 גפקאמצא QUESTION Alto (System) AULL NAME V Save & Inform User

COMPLIANCE ADVANTAGE LINK Compliance Advantage Link VERIFICATION APPLICATION STATUS Auto-Approved

COMPLYADVANTAGE LINK ComplyAdvantage Link VERIFICATION APPLICATION STATUS Auto-Approved

DATE & TIME FULL NAME ROLE RISK SCORE RISK LEVEL 7/14/2023 10:19:12 AM Auto (System) Auto (System) 15 Low

QUESTION SORT ORDER QUESTION ANSWER RISK RATING

11 Citizenship on the document China 9 12 Please tell us about your current employment status. Employed 0 13 Please tell us about your occupation or business activity. 小学教师 0 14 Please tell us about business you may conduct in other country(s) besides where you are registered for tax purposes? No 0 15 Is your individual activity or business registered or conducted in preferential tax zone (for instance, free economic zone, offshore jurisdiction)? No 0 16 Please tell us about your annual turnover, in individual or business activity, which is handled in cash. 0-10% (none or little of my turnover is in cash) 0

Screening QA is performed against the Customer. There are 100 hits against the searched Chinese name. All hits are discounted as NAME MISMATCH, DOB MISMATCH, OCCUPATIONAL BACKGROUND MISMATCH, ADVERSE MEDIA UNRELATED TO AML, CTF, or CORPORATES. Senior KYC Onboarding Analyst [REDACTED] emailed the Customer clarification regarding US funds via Zendesk #53673 on 18 May. The Customer cited travelling and investment as primary justification for transaction with US account. Senior KYC Onboarding Analyst [REDACTED] emailed the Customer notification regarding Chinese Residence via Zendesk #54006 on 18 May. Based on the KYC responses, the Customer is Medium Risk considering the following risk factors:

3. Selected services include Crypto Trading, Participate in Initial Exchange Offering, Crypto Payment 4. Funds received and/or transferred from Australia, Singapore, US

Screening is performed against the Customer. There are 100 hits against the searched English name. All hits are discounted as NAME MISMATCH, OCCUPATIONAL BACKGROUND MISMATCH, ADVERSE MEDIA UNRELATED TO AML, CTF, or CORPORATES.

Overall, Senior KYC Onboarding Analyst [REDACTED] is of the view that the initial AML/CTF assessment result is consistent with the Customer's profile and does not oppose the decision to onboard the Customer with Medium Risk [56].

6 23 2021 10:50:39 AM There is 3 hit against the searched both for English and Chinese name. All discount as name mismatch Based on the KYC responses, the Customer is Medium Risk considering the following risk factors: 1.Chinese citizenship per PRC passport [31] 2.Selected services include Crypto Trading, Long Term investment, Participate in Initial Exchange Offering, Crypto payment [5] 4.Funds received and or transferred from Russia [15] 5 20 2021 4:23:18 PM Screening is performed against the Customer. There is 0 hit against the searched both for English and Chinese name. Overall, KYC Onboarding Analyst is of the view that the Initial AML CTF assessment result is consistent with the Customer oppose the decision to onboard the Customer with Medium Risk [51].

COMPLYADVANTAGE LINK Complyadvantage Link

QUESTION SORT ORDER QUESTION ANSWER RISK RATING

11 Citizenship on the document Australia 0 12 Please tell us about your current employment status. Owner of legal entity 0 13 Please tell us about your occupation or business activity. Technology and communications - Information technology 0 14 Please tell us about business you may conduct in other country(s) besides where you are registered for tax purposes? No 0 15 Is your individual activity or business registered or conducted in preferential tax zone (for instance, free economic zone, offshore jurisdiction)? No 0 16 Please tell us about your annual turnover, in individual or business activity, which is handled in cash. 0-10% (none or little of my turnover is in cash) 5 17 Please tell us about your annual turnover, in individual or business activity, which is handled in cryptocurrency. 0-10% (none or little of my turnover is in cryptocurrency) 5 18 Please tell us about your source(s) of income funds. Select more than one box if necessary. Salary / Business income 0 19 Please tell us about your source(s) of wealth? Select more than one box if necessary. Employment income, Business profits 0 20 Please select the service(s) you plan to use. Select more than one box if necessary. Crypto Trading, Participate in Initial Exchange Offering, Crypto payment 0 21 How much do you plan to deposit per year (USD and crypto combined)? 10 000 100 000 0 22 Please tell us which countries the funds will be received and or transferred from. Australia 0 23 Let us know what your level of experience is with cryptocurrency trading? Please select one Beginner 5 24 How many years of experience do you have in crypto trading? < 1 Year 0 25 Are you, an immediate family member or a close associate, entrusted, or have been entrusted, with prominent public functions in any country or international institution? This could be a public office, a government role, a regulatory role or a senior military position, at home or overseas. No 0

COMPLY ADVANTAGE LINK ComplyAdvantage Link

QUESTION SORT ORDER QUESTION ANSWER RISK RATING

11 Citizenship on the document. China 0 12 Please tell us about your current employment status. Self-employed 5 13 Please tell us about your occupation or business activity. Services - Tourism and travel agencies activities 5 14 Please tell us about business you may conduct in other country(s) besides where you are registered for tax purposes? No 0 15 Is your individual activity or business registered or conducted in a preferential tax zone (for instance, free economic zone, offshore jurisdiction)? No 0 16 Please tell us about your annual turnover, in individual or business activity, which is handled in cash. 0 - 10% (none or little of my turnover is in cash) 0 17 Please tell us about your annual turnover, in individual or business activity, which is handled in cryptocurrency. 0 - 10% (none or little of my turnover is in cryptocurrency) 0 18 Please tell us about your source(s) of income funds. Select more than one box if necessary. Salary / Business income 0 19 Please tell us about your source(s) of wealth? Select more than one box if necessary. Business profits 0 20 Please select the service(s) you plan to use. Select more than one box if necessary. Long term investment 0 21 How much do you plan to deposit per year (USD and crypto combined)? 10 000 - 100 000 5 22 Please tell us which countries the funds will be received and or transferred from. Australia 0 23 Let us know what your level of experience is with cryptocurrency trading? Please select one. Beginner 5 24 How many years of experience do you have in crypto trading? < 1 Year 0 25 Are you an immediate family member or a close associate, entrusted, or have been entrusted, with prominent public functions in any country or international institution? This could be a public office, a government role, a regulatory job or a senior military position, at home or overseas. No 0

9-9-2023 10:45:44 AM Based on the KYC responses, the Customer is Medium Risk considering the following risk factors: 1. Chinese Citizenship as per inputed by the customer [11]

3. Business activity is Services - Tourism and travel agencies activities [5] Screening is performed against the Customer. There are 3 hits against the searched names. All hits can be discounted due to the Name Mismatch. Overall, KYC Onboarding Analyst is of the view that the initial AML/CTF assessment result is consistent with the Customer's profile and does not oppose the decision to onboard the Customer with Medium Risk (Risk Score 41).

Profile Balances 2M7P4EX Security Questions Deposit Addresses Supporting Documents Withdrawals Manual Adjustments Redemption Score Limits Addresses Referrals Bonuses Whitelisted IPs Risk Scoring

1. Citizenship on the document. China 0

3. Please tell us about your current employment status. Employed 0 4. Please tell us about your occupation or business activity. Editor 0 5. Please tell us about your annual turnover, in individual or business activity, which is handled in cash. No 0 6. Please tell us about your annual turnover, in individual or business activity, which is handled in cryptocurrency. No 0 7. Please tell us about your annual turnover, in individual or business activity, which is handled in fiat. 0-10% (None or little of my turnover is in cash) 5 8. Please select your primary source(s) of income/funds. Select more than one box if necessary. Salary, Business Income, Investments, Savings 5 9. Please select the purpose(s) you plan to use. Select more than one box if necessary. Crypto Trading, Long term investment, Arbitrage Trading, Participate in Initial Exchange Offering, Crypto payment 15 10. Please tell us which countries the funds will be received and or transferred from. China 0 11. How much do you plan to deposit per year (USD and crypto equivalent)? 10 000-100 000 0 12. Please select one Property sale, Employment income, Business profits 0 13. How many years of experience do you have in crypto trading? Please select one Beginner 0 14. Please tell us about your business registered or conducted in preferential tax zone (for instance, free economic zone, offshore jurisdiction)? No 0 15. Please tell us about your business registered or conducted in preferential tax zone (for instance, free economic zone, offshore jurisdiction)? No 0 16. Are you an immediate family member or a close associate, entrusted, or have been entrusted, with prominent public functions in any country or international institution? This means a political office, a government role, a regulatory role or a senior military position, at home or overseas. No 0

Based on the KYC responses, the Customer is Medium Risk considering the following risk factors:

[31] Screening: Screening is performed against 2 bits are discounted because there were no related result by using name and DOB search in the database provided in the link. [5] Funds will be received and or transferred from China. [9] Purpose: Crypto Trading, Long term investment, Arbitrage Trading, Participate in Initial Exchange Offering, Crypto payment

Notification email has been sent to the Customer due to his country of residency in China.

Overall, KYC Onboarding Analyst is of the view that the initial AML/CTF assessment result is consistent with the Customer's profile and does not oppose the decision to onboard the Customer with Medium Risk 51.

Profile Balances Ledger Deposits Deposit Addresses Withdrawals Redemption Limits Withdrawal Addresses Bank Accounts Active Orders Completed Orders Trades Tiers Mail Queue Notifications Activity Error Log Exploit Attempts Referrals Referral Bonuses Whitelisted IPs Risk Scoring

Transaction Monitoring Security Question Supporting Documents

Plasse tell us about your source(s) of weath? Select more than one pox if necessary. Please tell us about your source(s) of income funds. Select more than one box if nece ssary. Flease tell us about your occupation or business activity. Please tell us about your current employment status.

ASK RATING 109000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000 Presse select the service(s) you plan to use: Select more than one box if necessary. 20

Profile Balances Ledger Deposits Deposit Addresses Withdrawals Redemption Limits Withdrawal Addresses Bank Accounts Active Orders Completed Orders Trades Tiers Mail Queue Notifications Activity Error Log Exploit Attempts Referrals Referral Bonuses Whitelisted IPs Risk Scoring

Transaction Monitoring Security Question Supporting Documents

- Profile- Balances- Transferable Balances- API Keys- Deposits- Deposit Addresses- Withdrawals- Withdrawal Addresses- Reclamation Limits- Funding- Fiat Addresses- Bank Accounts- Active Orders- Counts- Completed Orders- Trades- Ticks- MWI Queue- K- Notifications- Activity- Logs- Login Attempts- Explicit Attempts- Referrals- Referral Balance- Whitelisted IPs