Anti-Money Laundering Statement

Effective Date: January 1, 2025

Jinnong Sui Capital strictly complies with applicable anti-money laundering (AML) and counter-terrorist financing (CFT) laws and regulations. We are committed to safeguarding the integrity of the financial system and preventing the inflow of illicit funds.

1. Regulatory Basis

This AML program is established in accordance with:
  • The Anti-Money Laundering Law of the People's Republic of China
  • The Administrative Regulations on Anti-Money Laundering for Financial Institutions
  • The Measures for the Administration of Financial Institutions' Reporting of Large-Value and Suspicious Transactions
  • Relevant Financial Action Task Force (FATF) Recommendations

2. Customer Due Diligence (CDD)

All investors must complete the following due diligence procedures before account opening:
  • Verification of identity documents (individuals: national ID / passport; entities: business license, ownership structure)
  • Identification of ultimate beneficial owners (UBOs), penetrating through to natural persons holding 25% or more of equity interests
  • Understanding of the source of funds and wealth background
  • Application of simplified or enhanced due diligence based on risk rating

3. Transaction Monitoring

  • Large-value reporting for single or aggregated cash transactions exceeding RMB 50,000
  • Suspicious transactions reported within 24 hours to the China Anti-Money Laundering Monitoring and Analysis Center
  • Enhanced scrutiny of transactions involving high-risk countries or regions
  • Monitoring of unusual patterns such as frequent subscriptions/redemptions and structured transactions

4. Sanctions Screening

Jinnong Sui Capital screens all investors and counterparties against major sanctions lists, including those maintained by the United Nations, China, U.S. OFAC, and the European Union. Matches are rejected and reported to regulators as required.

5. Record Keeping

All customer identity records, transaction records, and due diligence files are retained for a minimum of 5 years from the date of termination of the business relationship or the date of the transaction, to satisfy regulatory examination requirements.

6. Employee Training

All employees must complete annual AML training covering regulatory updates, red-flag indicators, and suspicious transaction reporting procedures. New hires must complete initial training within 30 days of onboarding.

7. Independent Audit

The AML program is subject to an independent external audit annually. Audit findings are reported to the Board of Directors and regulatory authorities.

8. Contact

For inquiries or to report suspicious activity, please contact the AML Compliance Officer:
Email: longvv810@gmail.com