Guidelines for Managing Abnormal Trading Behavior

Dear XTers,

XTrust has upgraded its risk control system in order to better regulate market trading and protect the interests of its users. If we detect any abnormal trading behavior among our users, we may take appropriate measures against the users involved according to the regulations as follows:

I. Rules for Identifying Abnormal Trading Behavior

Any of the following behavior that occur during trading will be deemed as abnormal trading behavior:

(i) Self-trading

• Making transactions in which the same entity takes both sides of the trade, whether it is conducted by accounts registered on the same device or under one person’s name, to obtain airdrop rewards and/or other rewards;
• Placing matched orders via one or more associated accounts to make swaps between accounts and manipulate market prices of tokens;
• Exceeding the exchange's position limit via the combined position of associated accounts under actual control.
• Unauthorized code trading and wash trading.

Note:

1. Rules for identification: Multiple accounts will be considered related if they have the same funding sources, share the same IP address, exhibit synchronized trading behavior, have similar order placement times, conduct internal fund transfers, and trade at similar opening and closing prices.
2. Matched orders under associated accounts refers to the act of using two or more related accounts to premeditate or arrange with others to place orders at the same price and time. One account buys high and sells low, while the other account buys low and sells high to obtain an obvious profit or loss. This allows the trader to transfer funds from their XTrust trading account to their personal account.
3. Unauthorized Code Trading is trading that involves using stolen trading passwords to act as counterparties and disrupt trading order to transfer funds.
4. Related Account Wash Trading is trading within two or more linked accounts, where premeditated or pre-arranged trades are executed simultaneously at the same price, with one account buying high and selling low, incurring obvious losses, and the other selling high and buying low, making obvious gains, to transfer funds from the trader's account to their independent account.

(ii) High-frequency Trading

• Placing or cancelling orders frequently during the day, which may affect the trading price or mislead other users.
• Placing or cancelling multiple large orders during the day, which may affect the trading price or mislead other users.
• Failure to stop trading after multiple warnings when the daily trading volume exceeds the system limit.

(iii) Using programmed trading methods to issue trading instructions, which may affect the security of the XTrust system or the order of normal trading.

(iv) Taking advantage of service loopholes or other unreasonable means to violate the rights and interests of other users or XTrust Exchange.

(v) Opening transactions on certain products (including but not limited to spot trading, futures trading, and margin trading) within one day exceeding the limited amount transaction volume set by the Exchange. The number of open trades in a single day on a particular trading product (including but not limited to XTrust Futures trade, Spot trade, Margin trade, leveraged ETF) exceeds the daily open trade volume established by the exchange. XTrust will take measures such as raising transaction fees or banning accounts for suspicious behavior including but not limited to wash trades, malicious opening of positions, and inducing others to place orders.

(vi) Washing futures trades frequently or providing rebates to associated accounts or other accounts via proxy accounts for the purpose of washing trades.

(vii) Engage in A/B book trading via one's own account or multiple accounts.

(viii) Engage in abnormal convergence trading via actually associated accounts.

(ix) Hacking into other users' accounts, using other users' accounts or associated accounts for trading, transferring funds, and/or related illegal acts.

(x) Making frequent deposits and withdrawals: frequently depositing a particular token within a day in exchange for withdrawals of other tokens.

(xi) OTC transactions are suspected of involving irregular trading behavior such as money laundering, fraud, and malicious trading. Examples of these behavior include:

• Selling, lending, or renting your account for others, or conducting transactions on behalf of others, which raises suspicion of money laundering and violates our platform rules and regulations.
• Receiving or introducing digital assets or funds from illegitimate sources. If a user knowingly or reasonably suspects that coins or funds received from other platforms or chat groups are involved in black coins or illegal funds but ignores the risks and directly deposits these funds into our platform, which constitutes suspected money laundering behavior.
• Non-compliant risk transactions, such as failing to bind valid payment information that matches the user's real name or providing buyers with payment channels that do not match the user's real name registered on our platform.
• Fraudulent behavior, such as clicking "paid" without actually making payment, fabricating false payment records, or claiming not to have received payment and providing false evidence after payment has already been received.
• Malicious trading behavior, such as frequent order cancellations, adding risky remarks during payment, and maliciously snatching low-priced orders.
• Other illegal and non-compliant trading behavior.

(xii) Any other trading behavior that are deemed abnormal by the XTrust Exchange may also be subject to review and potential enforcement actions.

II. Types and features of wash trading, A/B book trading, and high-frequency illegal trading:

(i) Multiple associated accounts place trading orders for the same variety and direction within the same time period, with similar lot sizes and prices for opening and closing positions.

(ii) Use the same or associated accounts to manually or automatically execute trades for the same variety with opposite directions and comparable lot sizes within the same time period.

(iii) Rapidly open or close positions within a very short time, typically less than 5 minutes.

(iv) Unauthorized quantitative trading and arbitrage trading.

(v) Involvement in price manipulation or any other malicious market behavior.

III. Regulations on Abnormal Trading Behavior

If a user engages in abnormal trading behavior, the XTrust Exchange may take the following measures:

(i) Require the user to submit advanced KYC verification and a video for verification purposes.

(ii) Require the user to submit transaction records.

(iii) Restrict, suspend, or terminate the user's access to the official website of the XTrust Exchange.

(iv) Restrict the user from opening new positions, require the user to close positions within a certain period of time, and/or force the user into liquidation.

(v) Restrict the user from transferring assets in and out.

(vi) Disable the user's account and confiscate any remaining assets.

(vii) Roll back abnormal transaction records.

(viii) Take other measures in accordance with the business rules of the XTrust Exchange.

IV. Disclaimer

1. Users participating in trading on XTrust shall comply with laws and regulations and the business rules of XTrust Exchange. They shall also accept the reasonable management and monitoring of their trading behavior by XTrust Exchange, and follow the norms of trading behavior.
2. XTrust reserves the right to seek all remedial measures that are fair and permitted within the law for abnormal trading behavior, including but not limited to restricting all trading activities of the account that commits abnormal trading. XTrust will not be responsible for any economic loss caused by suspected violation of these rules.

Risk Warning：

• All information displayed on XTrust does not constitute investment advice. XTrust does not take responsibility for any direct or indirect losses resulted. XTrust does not assume responsibility for guarantees or compensation for depositing or locking positions.
• XTrust reserves the right, at its discretion, to change, modify, or remove portions of the announcement at any time by posting the amended version on the website with or without notice.