Blacklisting Policy

1. Purpose

1.1 The Issuer is committed to maintaining the integrity, security, and lawful use of all specified stablecoin(s) issued by it and to complying with all applicable Laws and regulations (including, but not limited to, anti-money laundering, counter-terrorist financing, counter-proliferation financing and/or economic sanctions laws).

1.2 This Policy details the circumstances in which the Issuer may:

(A) block a digital token address(es) (i.e. a Blocked Address) (the Blocked Address existing at any time constitute the “Blacklist”);
(B) temporarily or permanently freeze any specified stablecoin(s) issued by it including, but not limited to, blocking transfers of such stablecoin(s) to or from a Blocked Address(es); and/or
(C) terminate a Customer’s account(s) with it or a Customer’s account(s) on its Site.

2. Blacklisting & Freezing

2.1 The Issuer may, in its sole and absolute discretion, do all or any of the actions in paragraphs 1.2 (A), (B) or (C) of this Policy in the following circumstances:

(A) to comply with all applicable Laws and regulations (including, but not limited to, any anti-money laundering, counter-terrorist financing, counter-proliferation financing and economic sanctions laws), the Issuer’s contractual obligations or any compliance policies or procedures applicable to the Issuer;
(B) where it determines that any specified stablecoin(s) issued by it is obtained, held or used in violation of applicable Laws or the Coin Terms and Conditions (including, but not limited to, in connection with any Restricted Activity(ies) or Prohibited Transaction(s));
(C) in response to all lawful requests from law enforcement agencies, any guidance or direction of any Government or Government Official or any writ of attachment, lien, levy, subpoena, warrant or other legal order; and/or
(D) to protect the integrity and security of the Issuer’s network in respect of its issued specified stablecoin(s).

3. Effect of Blacklisting or Freezing Actions

3.1 A Blocked Address can no longer send or receive any specified stablecoin(s) issued by the Issuer.

3.2 Any specified stablecoin(s) issued by the Issuer that is associated with a Blocked Address will be frozen on-chain. Any such frozen specified stablecoin(s) cannot be transferred, redeemed or otherwise used.

3.3 The balance of such specified stablecoin(s) in the Blocked Address may remain visible on the blockchain but will be inaccessible to the holder.

3.4 In certain cases, and to the extent permitted by applicable Laws, the Issuer may revoke and reissue any specified stablecoin(s) issued by the it which were previously frozen.

4. Policy Exceptions

4.1 The Issuer may consider a request for an exception to this Policy where the Issuer determines, in its sole discretion, that failure to grant a request presents a threat to the security, integrity, or reliability of the Issuer’s stablecoin network or other critical networks.

4.2 The Issuer may revert the Blacklisting and/or freezing of an individual address upon receiving written confirmation from a duly authorised Hong Kong Government authority or Hong Kong Government Official that it may do so, or upon formal confirmation from a Hong Kong court (or other duly authorised Hong Kong Government authority) that the legal obligation or legal order (per above 2.1 (c)) is lifted or no longer applicable, or that a security incident no longer requires such intervention.

5. Policy Updates

The Issuer may amend this Policy at any time including, but not limited to, to reflect changes in applicable Laws, regulation and/or internal processes or procedures.