This Risk and Compliance Disclosure should be read in conjunction with the Aleo Terms of Service (“Terms"). Unless otherwise defined herein, all capitalised terms used shall have the same meanings ascribed to them in the Terms. In plain English, we want you to understand the important risks and compliance matters while you trade on Aleo Platform.
1. PURPOSE OF OUR PROGRAM
We have established and implemented an Anti-Money Laundering, Anti-Terrorist Financing, and Trade & Economic Sanctions Program (“AML/ATF/Sanctions Program” or “Program”) to ensure a robust and compliant digital asset trading platform. We want to promote legal, transparent business activities and maintain a strong reputation among our customers, regulators, and the digital asset industry.
2. OUR ROLE AND ACTIVITIES
Aleo Platform is a global digital asset trading platform or marketplace, where traders come as buyers and sellers (commonly referred as market-makers and market-takers). In general, our Services facilitate transactions that match users with other users, but in certain circumstances as set out in the Terms, Aleo’s Related Parties may be a counterparty to the trades on Aleo Platform. Our Services are available through Aleo Platform which is operated by Aleo.
Disclosure: Trading is risky. The risk of loss in trading or holding Digital Assets can be substantial. You should therefore carefully consider whether trading is suitable for you in light of your financial condition.
3. REGULATORY LANDSCAPE
We understand that regulatory bodies have taken a diverse approach to the laws and regulations regarding Digital Assets, including some characterizing or defining Digital Assets as convertible virtual currency (by USA FinCEN) or virtual commodity (by Hong Kong). As a trading platform, we believe that all Digital Assets available on Aleo Platform are an innovative alternative asset class; and therefore, Digital Assets should not be called currency or money.
Disclosure: Digital Assets are not fiat money nor fiat currency. Digital Assets are NOT backed by any government or central bank. We may at times have opinions of the different regulatory approaches taken by various government bodies; however, at all times, we will fully abide by rules and regulations of the respective countries we operate in. We regularly communicate with regulators and industry on the best approach to regulating digital asset businesses. Furthermore, Aleo does not accept certain customers. We may not make all of the Services available in all markets and jurisdictions, and may restrict or prohibit use of all or a portion of the Services from Restricted Locations, which at this time include Afghanistan, Algeria, Bangladesh, Bolivia, Canada, Cuba, El Salvador, France and its overseas territories, Hong Kong, Iran, India, Japan, Malaysia, Nepal, Nigeria, North Korea, Syria, the Crimea, Donetsk and Luhansk regions of Ukraine, the United States of America including all U.S. territories like Puerto Rico, American Samoa, Guam, Northern Mariana Island, and the U.S. Virgin Islands (St. Croix, St. John and St. Thomas), and Uzbekistan. Aleo may restrict services in other jurisdictions including but not limited to Australia (specifically regarding our derivatives-related and cefi-related services), Bahamas (specifically regarding our retail products), Brazil (specifically regarding our derivatives-related and P2P services), Eritrea (specifically regarding our P2P services), Russia (specifically regarding our fiat payment services), Singapore (specifically regarding our cefi-related services), South Korea (specifically regarding our derivatives-related and P2P services), the United Kingdom (specifically regarding our derivatives-related, cefi-related, and P2P services).
We cooperate with governments and respect regulations and comply with applicable regulations. As good corporate citizens, we may be asked for information from law enforcement authorities and will assist if permissible by law as law enforcement conduct investigations to pursue and thwart illicit activity. What this also means is that Aleo Platform is intended for law abiding customers. We welcome the opportunity to earn your business, and in return we require that you act legally and properly on Aleo Platform.
4. OUR AML/ATF PROGRAM
We have designed our Program to reasonably prevent money laundering and terrorist financing through a risk-based, multi-layer control system.
The first layer includes a stringent customer identification program, including verifying the identity of our customers, whether individuals or entities. In addition to obtaining identification documents, we obtain for non-natural persons their entities’ beneficial owners/natural persons consistent to international standards such as the Financial Action Task Force (FATF).
The second layer includes a risk-based system to warrant additional customer due diligence. To accomplish this, we screen our customers (including beneficial owners) against the entities/persons on The Government of the Hong Kong SAR Gazette, United States Office of Foreign Assets Control (OFAC) Sanctions Lists, and the United Nation Security Council Sanctions List, among other government-provided lists of sanctioned individuals and entities. We also may screen against other lists on a discretionary basis to protect our reputation and customers.
The third layer includes ongoing monitoring for suspicious activity. If our Program suspects or has reason to suspect suspicious activities have occurred, we will file suspicious activities reports with local regulators. A suspicious transaction is often inconsistent with a customer’s known and legitimate business, or personal activities.
These are the primary components of our compliance program; however, the most important glue or connection to these layers are our leadership team and staff, including AML/Risk personnel that execute training, oversight and a sound compliance culture.
5. RISKS AND SPECIFIC DISCLOSURES
Trading in Digital Assets is considered high risk. Digital Assets are NOT backed by any government or central bank. The risk of loss in trading or holding Digital Assets can be substantial. You should carefully consider whether interacting, holding, or trading Digital Assets is suitable for you in light of your financial condition.
5.1 FX Conversion Risk: You agree and understand that any credit card payments you make using your local currency undergoes a standardized FX conversion process. This FX conversion process may in some circumstances be subject to systemic errors and unexpected failures. In the event of such errors and/or systemic failures, as determined by us in our sole discretion, you may receive a balance in USD or USDT which may be different from the local currency balance you started with at the outset of your payment transaction. This might result in a risk of loss and you agree that you shall bear all costs related to any FX conversion risk resulting from such system errors and/or failure.
5.2 Risk Warning on Digital Payment Tokens (applicable to users of Aleo SG Pte. Ltd. only)
The Monetary Authority of Singapore (MAS) requires us to provide this risk warning to You if you are a customer of a digital payment token (DPT) service provider. The MAS states that before you:
(a) pay or transfer your DPT service provider any money or DPT;
(b) enter into an agreement with a third party to buy or sell DPTs upon inducement by your DPT service provider;
(c) enter into an agreement with a third party under an arrangement by your DPT service provider for the transmission of DPTs;
(d) pay a third party any money or DPT under and arrangement by your DPT service provider for the transmission of DPTs; or
(e) transfer any digital payment token instrument to your DPT service provider.
You should be aware of the following:
(i) Your DPT service provider is exempted by MAS from holding a license to provide DPT services. Please note that you may not be able to recover all the money or DPTs you paid to your DPT service provider, or any other third party referred to above, if your DPT service provider’s or the third party’s business fails.
(ii) You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.
(iii) You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.
(iv) You should be aware that your DPT service provider, as part of its license to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin."
5.3 Disclosure on Maintenance of Custody Account for Fiat and Digital Payment Tokens (applicable to users of Aleo SG Pte. Ltd. Only)
The MAS requires us to disclose to you how your custody accounts for fiat and DPTs are maintained with Aleo. The fiat funds of Aleo Singapore users are directly deposited and held on trust for the benefit of Aleo Singapore users in one or more segregated custodial accounts at one or more duly-registered and licensed third-party banking institutions in accordance to the banking institutions’ terms of service. The DPTs of Aleo Singapore users are held on trust for the benefit of Aleo Singapore users in secure and segregated hot and cold wallets systems (with no more than 5% of DPTs kept in hot wallets) with Aleo Singapore’s affiliates in accordance to safeguarding agreements that gives Aleo Singapore strict supervision and control over the hot and cold wallets systems.
Aleo Singapore does not do anything with your fiat and DPTs unless explicitly authorized and directed to do so by you. In the event of Aleo Singapore’s bankruptcy, current law and practice suggests that your fiat and DPTs will not be subject to claims from Aleo Singapore’s creditors.
6. FEES
6.1 Trading Fees: Your trading fees are determined by trailing 30-day volume. All volume is converted to USD using the exchange rate of the digital asset at the time of the transaction. Transactions in non-USD base pair markets are also converted. Your 30-day trading volume is calculated every day at 00:00 (UTC+8).
Fees are charged in the asset you purchase. For example, if you buy BTC/USD the fee is charged in BTC. Rebates are paid in the asset you sold. For example, if you buy BTC/USD the rebate is paid in USD.
Current Fee information is available here.
6.2 Additional Fees and Charges: Aleo offers a variety of deposit and withdrawal channels. Deposit and withdrawal fee information can be viewed here.
If you selected Aleo as your third-party provider, a fee is assessed on Credit/Debit card transactions (Visa only).
6.3 Regional or country specific pricing: regional or country-specific pricing may vary, which is determined based on a user’s residence or location.
7. COMMUNICATION
If you have questions or require assistance with our customer due diligence controls, please reach out to our 24/7 customer service representatives by chat or email at Support Center.
For any law enforcement requests, please see our law enforcement request guide here.
8. DIFFERENT VERSIONS
This "Risk and Compliance Disclosure" may be posted in different languages. If there are any discrepancies, the English version shall prevail.