---
type: court_doc
id: "court_sdny_208_3"
court: "SDNY"
case_no: "23-cr-00118"
doc_number: 208
doc_type: "ORDER"
filed_date: "2023-12-21"
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_sdny_208_3"
json_url: "https://mubeitech.com/api/court/court_sdny_208_3"
---
# Guo Wengui / Miles Guo — criminal case · ORDER · ECF #208-3

**Court Filing —— United States v. Ho Wan Kwok (Guo Wengui / Miles Guo), SDNY 1:23-cr-00118 ECF #208-3 (December 21, 2023). A document relating to the Classified Information Procedures Act (CIPA); the original text is severely corrupted by OCR processing and cannot be reliably interpreted.**


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

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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

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

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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?
< 1 Year
Let us know what your level of experience is with cryptocurrency trading? Please select one:
Deginner
Please tell us which countries the funds will be received and or transferred from.
United States
Houg Kong
New Zealand
How much do you plan to deposit per year (USD and crypto combined)?
10 000 100 000
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.
60-90% (most of my turnover 15 In cash)
Is your individual schip or pushess registered or conducted in prefrential any 2014 (for instance, free economic zone, offshore jurisdical)
Hong Kong
13.8
BRESS TEll is about pushess you may conduct in other county(s) pesides where rogistered for tax purposes)
ON
Please tell us about your occupation or business activity.
Importer and wholesale
Please tell us about your current employment status.
Retired
United Kingdom
China
NOTESTION

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Save & inform USer

COMMENT　ROLE　FULL NAME　DATE & TIME

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

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

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

- Balances
- Ledger
- Deposits
- Deposit Addresses
- Withdrawals
- Redemption Limits
- Withdrawal Addresses
- Bank Accounts
- Active Orders
- Completed Orders
- Trades
- Tiers
- Withdrawal Queue
- Notifications
- Activity
- Error Log
- Login History
- Exploit Attempts
- Referrals
- Referral Earnings
- Security Question Setup

- 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

- Profile
- Balances
- Ledger
- Referral Bonuses
- Whitelist
- Trusted IPs
- Risk Scoring
- Deposits
- Deposit Addresses
- Withdrawals
- Withdrawal Addresses
- Redemption Limits
- Security Questions
- Transaction Monitoring
- Supporting Documents
- Bank Accounts
- Active Orders
- Completed Orders
- Trades
- Tiers
- Mail Queue
- Notifications
- Activity
- Error Log
- Explorer
- Login Attempts
- Referrals
- API Keys
- Settings

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...　...
...　...
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...　...
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Empirical comparison

Table S

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Index　Cars　Media　News　Reviews　Features　Financing　Interviews　Opinions　Photos　Videos　About Us　RSS

QUESTION　ANSWER

Place of birth　China
Citizenship on the document　China
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
United Kingdom
Taiwan
Singapore
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

INTERNAL ID　IQZZTFC

MANUAL RISK SCORE　0 Save
TOTAL RISK SCORE　30
RISK LEVEL　Low
COMPLYADVANTAGE HITS　0
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
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

- 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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Filed 12/21/23

Document 208-3

Case 1:23-cr-00118-AT

Case 1:23-cr-00118-AT

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

QUESTION SORT ORDER
KYC Questionnaire　15/22022 3:0541 MA　Risk Score Update History　NUMBER OF ATTEMPT TO
OIMUL　CATEGORY　APPLICATION STATUS
VERIFICATION　COMPLYADVANTAGE
דואא　COMPLYADVANTAGE
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
Auto (System)
ROLE
ANSWER
50　Expirat SCORE
RISK RATING　Medium　RISK LEVEL

INTERNAL ID　K64HVBN　Filed 12/21/23

MANUAL RISK SCORE　3 Save
TOTAL RISK SCORE　45
RISK LEVEL　Medium
COMPLIANCE ADVANTAGE　0
RISK LEVEL　Medium
COMPLIANCE ADVANTAGE LINK　Compliance Advantage Link
VERIFICATION APPLICATION STATUS　Auto-Approved

INTERNAL ID　P146C1D

MANUAL RISK SCORE　0　See
TOTAL RISK SCORE　15
RISK LEVEL　Low
COMPLYADVANTAGE HITS　0
COMPLYADVANTAGE LINK　ComplyAdvantage Link
VERIFICATION APPLICATION STATUS　Auto-Approved
CATEGORY　Save & Inform User
NUMBER OF ATTEMPT TO JUMIO　2　Reset
Risk Score Update History
DATE & TIME　FULL NAME　ROLE　RISK SCORE　RISK LEVEL
7/14/2023 10:19:12 AM　Auto (System)　Auto (System)　15　Low
KYC Questionnaire
QUESTION SORT ORDER　QUESTION　ANSWER　RISK RATING
10　Place of birth　China　0
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

- SECURITY SETTINGS
- API KEYS
- KYC & DOCUMENTS
- ADDRESSES
- STANDARDS
- TRANSACTION HISTORY
- Mobile Balances
- Deposit
- Deposit Addresses
- Withdrawal Limits
- Withdrawal
- 4 Addresses
- Link Account
- Active Orders
- Completed Orders
- Filled Orders
- Trades
- Sell Order
- Market Maker
- Activity
- Referral Log
- Supported Assets
- Withdrawals
- Referral Bonus
- Risk Scoring

Profile

Balances
Ledger
Transaction Monitoring
Security Configuration
Documents
Addresses
Withdrawals
Deposit Addresses
Deposit Accounts
Redemption Limits
Withdrawal Addresses
Bank Accounts
Active Orders
Completed Orders
Trades
Transfers
Wall Clock Time
Notifications
Activity
Error Log
Exploit Attempts
Referrals
Referral Bonuses
Whitelisted IPs
Risk Scoring

COMMENT

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:
1. Chinese citizenship per PRC Passport
2. Occupation of Information Technology
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].

- Monitoring
- Security
- Ledger
- Deposits
- Deposit Addresses
- Supported Documents
- Withdrawals
- Redemption
- Limits
- Withdrawal Addresses
- Bank Accounts
- Active Orders
- Completed Orders
- Trades
- Time in Force
- Kill Queue
- Source
- Notifications
- Activity
- Error Log
- Exploit Attempts
- Referrals
- Referral Bonus
- Whitelisted IPs
- RIS

DATE & TIME　FULL NAME　ROLE　COMMENT

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].

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

INTERNAL ID　PHIJ8Z0

MANUAL RISKSCORE　0
TOTAL RISK SCORE　15
RISK LEVEL　Low
COMPLYADVANTAGE HITS　0
COMPLYADVANTAGE LINK　Complyadvantage Link
VERIFICATION STATUS　Auto-Approved
CATEGORY　JUMIO
NUMBER OF ATTEMPT TO　2

Reset

KYC Questionnaire

✓ Save & Inform User

QUESTION SORT ORDER　QUESTION　ANSWER　RISK RATING

10　Place of birth　China　0
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

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

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

KYC Questionnaire

INTERNAL ID　KYCDSYCL

TOTAL RISK SCORE　41
MANUAL RISK SCORE　Medium
APPLICATION STATUS　Approved
COMPLY ADVANTAGE HITS　0
COMPLY ADVANTAGE LINK　ComplyAdvantage Link
VERIFICATION STATUS　Approved
NUMBER OF ATTEMPT TO JUMO　7

Reset

Save & Return Later

QUESTION SORT ORDER　QUESTION　ANSWER　RISK RATING

10　Place of birth　China　0
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

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Comment

DATE & TIME　FULL NAME　TITLE　COMMENT

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]
 2. Self-employed status [5]
 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

RISK SCORING

TOTAL RISK SCORE　51

REDEMPTION　Medium
COMPLIANCE TAG　N/A
VERIFICATION　Verified
APPLICATION STATUS　Approved
COMPLIANCE LEVEL　100
RISK RATING　Medium-high risk

KYC QUESTIONNAIRE

QUESTION　ANSWER　RISK RATING

1. Citizenship on the document.　China　0
2. Place of Birth　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

COMMENT

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

Citizenship: China

[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
[13] Experience: Beginner

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

ge 46 of 5

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

KYC Questionnaire
Risk Score Update History

811 2023 4:37:45 PM
311 12023 4:38:28 PM
3 1 2023 4:40:08 PM
El

NUMBER OF ATTEMPT TO
QUESTION SONT ORDER
APPLICATION STATUS
COMPLYADVANTAGE
COMPLYADVANTAGE
MANUALRISKSCORE
TOTAL RISK SCORE
VERFICATION
INTERNAL ID
CATEGORY
RISK LEVEL
Olwint
LINK
HITS
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.
Auto-Approved

MOT
MZDB631
STATE REPRENTIAL CARRETT CHARR

DATE & TIME

A
Stree & informa 2441
Auto (System)
Alito (System)
Auto (System)
FULL NAME
OLESTION
Auto (System)
Auto (SWS481)
AU10 (System)
Employment income
Self-employed
Salary business Income
24/02/
ROLE
ASSASSAN
RECORD ACDAR
רמא
For
רמא
1.62 / 1
ASK LEVEL
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