Disclaimer

This disclaimer should be read together with the platform’s Terms of Service. Simply put, we aim for you to understand the important compliance matters and liability provisions when trading on our platform.

1. Purpose

To maintain a sound and compliant digital asset trading platform, we have established and implemented a series of Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), and trade and economic sanctions programs, along with related liability statements.

We are committed to promoting lawful and transparent business activities and maintaining a good reputation among users, regulators, and the digital asset industry.

2. Regulatory Environment

We understand that regulators take various approaches to regulating digital assets, including:

Defining or classifying digital assets as virtual financial assets (Malta) Convertible virtual currencies (U.S. FinCEN) Virtual commodities (Hong Kong)

As a trading platform, we consider all digital assets offered on the platform as innovative alternative assets. Therefore, digital assets should not be regarded as money or legal tender.

3. Disclosure

Digital assets are not money or legal tender. Digital assets such as Bitcoin and Litecoin are not backed by any government or central bank.

While we may express opinions regarding the regulatory approaches of different governments at times, we always fully comply with the laws and regulations of the countries in which we operate. We regularly discuss with regulators and industry peers the best practices for supervising digital asset businesses.

We cooperate with government authorities and comply with applicable regulations. As a responsible corporate citizen, we may be required to provide information to law enforcement, and we will assist in lawful investigations to detect and prevent illegal activities. This also means our platform is available only to lawful customers. We aim to provide services to you while expecting that you act lawfully on our platform.

Furthermore, SunX Exchange complies with all laws and regulations regarding blockchain and cryptocurrency assets in all applicable countries or regions. Our services are not available to residents of the following countries or regions:

Afghanistan, Burundi, Belarus, Central African Republic, Congo, Mainland China, Hong Kong SAR, Macau SAR, Singapore, Malaysia, Ethiopia, Guinea, Guinea-Bissau, Iraq, Iran, North Korea, Lebanon, Sri Lanka, Libya, Serbia, Sudan, Somalia, South Sudan, Syrian Arab Republic, Thailand, Tunisia, Trinidad and Tobago, Ukraine, Uganda, USA, Venezuela, Yemen, Zimbabwe, Cuba, and all US territories (including Puerto Rico, American Samoa, and Guam).

This exclusion list may change depending on the service or applicable legal requirements.

4. Our AML / CFT Program

Through a risk-based multi-layer control system, we have designed our AML and CFT program to reasonably prevent money laundering and terrorist financing.

Layer 1 – Identity Verification

Strict procedures to verify the identities of individual and corporate users For non-natural person users, information on the beneficial owners is collected, in accordance with international standards such as FATF

Layer 2 – Risk-Based Screening

Users, including beneficial owners, are screened against the Hong Kong Government Gazette, OFAC sanctions lists, UN Security Council sanctions lists, and other applicable sanction lists Additional lists may be screened at our discretion to protect our reputation and our customers

Layer 3 – Continuous Monitoring

Suspicious activities are monitored continuously If we suspect or have reasonable grounds to suspect suspicious activity, we may submit a suspicious transaction report to local regulators Suspicious transactions are generally inconsistent with the user’s known legitimate business or personal activities

5. Risks

Trading digital assets is considered high-risk. Digital assets are not backed by any government or central bank.

You should carefully consider whether interacting with, holding, or trading digital assets is suitable for you based on your financial situation.

6. Liability

6.1 Warranty Disclaimer

To the maximum extent permitted by applicable law, all services, SunX Exchange materials, and any products, services, or other items provided by or on behalf of SunX Exchange are provided “as is” and “as available.”

SunX Exchange explicitly disclaims, and you waive, all other warranties, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, ownership or non-infringement, or warranties arising from course of performance, dealing, or usage of trade.

Without limiting the foregoing, SunX Exchange makes no representation or warranty regarding the accuracy, completeness, reliability, validity, freedom from error, virus, or other harmful components of the website, services, or SunX Exchange materials. SunX Exchange does not guarantee that any orders will be executed, accepted, recorded, or remain pending. Except as expressly stated in this agreement, you acknowledge and agree that you do not rely on any other written or oral statement or agreement in using or accessing the services.

Without limiting the foregoing, you understand and agree that SunX Exchange is not responsible for any losses or damages arising from or related to:

(A) inaccuracies, defects, or omissions in investment price data;

(B) errors or delays in data transmission;

(C) interruptions of such data;

(D) damages caused by other users’ actions, inactions, or violations of this agreement.

6.2 Limitation of Liability

To the maximum extent permitted by law, SunX Exchange, its affiliates, and their respective shareholders, members, directors, officers, employees, lawyers, agents, representatives, suppliers, or contractors shall not be liable for any incidental, indirect, special, punitive, consequential, or similar damages or liabilities, including but not limited to loss of data, information, revenue, profits, or other business or financial benefits, whether under contract, statute, strict liability, or other theory, even if SunX Exchange has been advised of the possibility of such damages, except where such damages are finally determined to result from SunX Exchange’s gross negligence, fraud, willful misconduct, or intentional violation of law. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitations may not apply to you.

Notwithstanding the foregoing, in no event shall SunX Exchange, its affiliates, or their respective shareholders, members, directors, officers, employees, lawyers, agents, representatives, suppliers, or contractors be liable for any amount exceeding the fees paid by you to SunX Exchange under this agreement prior to the event giving rise to the claim.

📅 SunX Global Operations Team

October 18, 2025, 20:38:03 CST