9.1 Key Areas of Regulatory Compliance

Anti-Money Laundering (AML) & Combating the Financing of Terrorism (CFT)

• CPT tokens implement AML/CFT systems in line with FATF guidelines and key national regulations through tiered KYC systems and FATF-compliant travel rule solutions.

Child and Youth Protection

• Age Verification and Parental Consent: Users under 13 must have their accounts linked with parental profiles.

• Data Minimization: Only essential personal data is collected, in compliance with global child protection regulations such as COPPA.

• Content Monitoring: All educational and user-generated content is rigorously reviewed using both AI and manual oversight to ensure appropriateness.

Legal Status of Tokens

• CPT tokens and Edu Passport NFTs are designed solely for utility. The dual-track regulatory strategy is implemented to address differing cryptocurrency regulations across countries:

  • Regulation-Friendly Regions: Full functionality is provided.

  • Strictly Regulated Regions: The “ChiChi Credit” points system is used.

  • Hybrid Models: Edu Passport NFTs are fully provided while token functionalities are limited.

9.1.1 Differentiated Regulatory Strategies by Country

The network adopts a three-phase approach based on the local regulatory environment:

• Full-Service Regions (Regulation-Friendly): In countries like Singapore, Dubai, and Switzerland, full token functionalities and RWA swaps are offered, with proper local licenses.

• Utility-Focused Regions (Moderate Regulation): In regions like the USA and UK, only the utility aspects of CPT are emphasized, with full Edu Passport NFT provision and limited RWA token functions.

• Points System Regions (Strict Regulation): In countries such as Korea and China, a “ChiChi Credit” points system is implemented to limit token usage to the platform, maintaining educational incentives while minimizing regulatory risk.

9.1.2 Ensuring Regulatory Compliance for Tokens

• Strengthening the Utility Aspect of CPT: Focus on utility functions such as service access and staking, excluding mechanisms that might imply investment returns.

• Clear Definition of RWA Tokens: Each RWA token is clearly linked to a specific IP sector and associated revenue rights, ensuring transparency and adherence to securities regulations where applicable.

• Leveraging Exemptions for Educational Content: Emphasizing the educational purpose and motivational design of the token system to take advantage of regulatory exemptions available for educational content.