Platform Refund & Fund Security Compliance Policy

Effective Date: 2026-06-01 | Scope of Application: All services and affiliated ecosystems on

This Platform Refund & Fund Security Compliance Policy (hereinafter referred to as the "Policy") builds upon standard refund protocols by further detailing proactive early-warning mechanisms and contingency plans targeting money laundering, embezzlement by public officials, cash-out schemes, and emerging financial crimes. The Platform is committed to establishing a full-chain fund security defense system encompassing "pre-transaction interception, in-transaction monitoring, and post-transaction tracing." Clauses involving mandatory freezing, data reporting, and judicial referral are highlighted in bold or underlined. Please read them carefully.

I. Refund Anomaly Early-Warning Matrix & Trigger Thresholds

To accurately identify potential risks, the Platform has established a multi-dimensional refund risk control model. When user behavior triggers any of the following warning lines, the system will automatically suspend the refund and escalate it for manual compliance review:

⚠️ Important Notice: The above thresholds are not fixed. The Platform will dynamically adjust them based on regulatory bulletins, industry risk trends, and historical false positive rates. Users shall not claim refund rights on the grounds of "not reaching published thresholds." The Platform reserves final discretion to take control measures based on reasonable suspicion.

II. In-Depth Prevention Rules Against Embezzlement by Public Officials

To address acts of corruption, misappropriation of public funds, and bribery laundering via the Platform's refund mechanism, the following special prevention clauses are added in addition to basic prohibitions:

1. Budget Approval Document Verification Obligation: For refund requests on corporate-paid orders where a single transaction exceeds CNY 50,000, a "Refund Reason Explanation and Budget Write-off Voucher" signed by the entity's financial officer and stamped with the official seal must be uploaded simultaneously. The Platform has the right to cross-verify document authenticity through public government information platforms and the National Enterprise Credit Information Publicity System. Forgery or alteration of official documents or seals of state organs, enterprises, or institutions will be directly referred to public security authorities for criminal investigation.
2. Related-Party Transaction Penetration Review: When the refund applicant has equity overlap, executive overlap, kinship, or other interest affiliations with Platform merchants/service providers, the Platform will initiate a penetration review requiring disclosure of the ultimate beneficial owner and actual use of funds. Concealing related-party relationships or using affiliated accounts to transit public funds constitutes malicious evasion of supervision. The Platform has the right to permanently ban all affiliated accounts and report to supervisory authorities.
3. Historical Transaction Retrospective Audit: For accounts flagged as "suspected public officials," the Platform has the right to conduct retrospective audits of all transaction records over the past 24 months, focusing on typical corrupt fund flow patterns such as "small-amount testing – large-amount cash-out – batch refunds." During the audit period, all fund operations on the account will be temporarily locked. Users may not raise objections on the grounds of affecting normal business operations.
4. Whistleblower Rewards & Witness Protection: Internal employees, partners, and the public are encouraged to report clues of embezzlement committed via the Platform. Upon verification and case filing, rewards will be granted pursuant to the Measures for Rewarding Reports on Money Laundering and internal compliance incentive policies, with strict confidentiality maintained for whistleblowers. Any retaliation against whistleblowers will be subject to aggravated legal liability.

III. Emerging Crime Modus Operandi Early Warning & Emergency Response

Given the continuous evolution of financial crime methods, the Platform has formulated special contingency plans for the following high-risk scenarios in :

• Virtual Currency OTC Refund Arbitrage: Users exchange fiat currency via OTC trading of stablecoins like USDT, make payments, then request refunds to bank cards under the pretext of "operational error" to anonymously monetize virtual assets.
  Response: Integrate on-chain data analysis tools to elevate refund review levels for accounts with cryptocurrency exchange deposit/withdrawal records within 72 hours prior to payment. Suspected OTC refund arbitrage will result in immediate fund freezing and clue reporting to cyberspace administration departments and public security cyber investigation units.
• AI Face-Swap/Voice Forgery Authorization: Criminals use deepfake technology to impersonate corporate legal representatives or financial officers, deceiving video authentication to obtain corporate refund authorization.
  Response: Upgrade biometric recognition systems with liveness detection, voiceprint comparison, and multi-modal anti-spoofing verification. Corporate refund video authentication mandatorily requires real-time timestamps and designated gestures in the background. Failures will be redirected to offline counter verification.
• Cross-Border Refund Exchange Rate Manipulation: Exploiting domestic-foreign exchange rate differences and refund time windows to extract exchange gains through fictitious cross-border transactions.
  Response: Cross-border refunds are uniformly settled at the exchange rate on the payment date; the Platform bears no exchange rate fluctuation losses. Accounts frequently initiating cross-border refunds without genuine trade backgrounds will be placed on the State Administration of Foreign Exchange "Watch List" with cross-border payment functions restricted.
• Supply Chain Finance Refund Fraud: Fabricating accounts receivable or warehouse receipt pledges, completing formal transactions via the Platform, then requesting refunds to fraudulently obtain credit funds from financial institutions.
  Response: Connect to the PBOC Credit Reference System and the Unified Registration System for Movable Property Financing to verify underlying asset authenticity. Suspected supply chain finance fraud will be simultaneously notified to partner banks and local financial regulatory authorities.

IV. Enhanced Data Retention, Reporting & Judicial Cooperation

1. Full Lifecycle Data Evidence Preservation: All refund applications, review records, communication logs, device fingerprints, IP addresses, raw biometric data, and risk control decision logs shall be retained for no less than 5 years from refund completion. For cases involving suspicious transactions or judicial investigations, retention extends to 10 years after investigation conclusion. Data storage employs dual protection of blockchain hash anchoring + encrypted cold backup to ensure immutability and traceability.
2. Automated Suspicious Transaction Report (STR) Filing: The Platform's risk control system is directly connected to the China Anti-Money Laundering Monitoring and Analysis Center. Refund transactions hitting high-risk models will automatically generate and submit STR reports within 24 hours. Users have no right to demand notification of STR submission, nor may they interfere with the reporting process on the grounds of "refund not received."
3. Judicial Assistance Green Channel: A 24/7 judicial assistance hotline is established. Emergency stop-payment and freezing documents issued by public security organs, supervisory commissions, and courts will be responded to and executed within 30 minutes. Routine inquiry documents will be answered within 2 business days. The Platform assumes corresponding legal liability for losses caused by delays due to its own faults; however, the Platform is exempt from liability for delays caused by document defects, insufficient authority, or force majeure.
4. Cross-Border Data Compliant Transfer: Cross-border transfer of refund data involving overseas users strictly complies with the Measures for Security Assessment of Cross-Border Data Transfers and the latest Standard Contractual Clauses for Personal Information Export in . The Platform has the right to refuse processing cross-border refund requests without completed security assessments or signed standard contracts.

V. User Remedies & Appeal Mechanism

1. Appeal Acceptance Scope: Only appeals arising from system misjudgment, missing materials, or identity theft leading to refund controls are accepted. No appeal channel is provided for compliance measures taken based on reasonable suspicion.
2. Appeal Material Requirements: Identity proof, transaction background proof, fund source proof, and a written appeal letter must be submitted. For corporate business, a situation explanation stamped with the entity's seal and an authorization letter from the handler are also required.
3. Appeal Processing Timeline: With complete materials, the Platform will make a review decision within 5 business days. If supplementary materials are needed, the timeline restarts from the date of completion. Original control measures remain effective during the appeal period and will not be automatically lifted due to the appeal.
4. Finality Statement: The Platform's review decision is final. Users who still object to the result should seek resolution through judicial channels. Repeated appeals, petitions, or public opinion pressure to interfere with normal Platform operations are prohibited.

Appendix: Implementation Execution & Technical Support Checklist

Disclaimer & Compliance Confirmation: This Enhanced Edition Policy integrates the Draft Amendment to the Anti-Money Laundering Law, Implementation Regulations of the Supervision Law, Regulations on Supervision and Administration of Non-Bank Payment Institutions, Measures for Security Assessment of Cross-Border Data Transfers, and key points of the Ministry of Public Security "Net Clean " Special Action issued before June . However, enforcement standards, regulatory calibers, and technical specifications may vary by region. The following actions must be completed before official launch: ① Submit risk control model filing and STR reporting test report to the local PBOC AML Division; ② Reach written consensus with the Case Adjudication Office of the local Supervisory Commission on embezzlement clue referral standards; ③ Engage a third-party law firm to issue a Legal Opinion on Refund Policy Compliance; ④ Organize AML and anti-corruption training for all staff (including customer service, finance, and technology) and pass assessments; ⑤ Embed policy confirmation pop-ups at three critical nodes: user registration, payment, and refund, with check records included in judicial evidence preservation. This Policy is strictly prohibited from being deployed in production environments until all above actions are fully completed.