AML / KYC Policy and Risk Management

1. General Provisions

The AML (Anti-Money Laundering) verification policy is aimed at identifying transactions related to terrorist financing, money laundering, and other illegal activities. Legalization of funds obtained through crime is the concealment of the illegal source of funds by transferring them into cash or investments that appear legitimate.

To prevent operations of an illegal nature, the Service establishes certain requirements for all Applications created by the User:

The sender of the funds and the creator of the application must be the same person. Payment by third parties is prohibited, as well as the transfer of payment details issued for the application to third parties.
The user’s personal data must be up-to-date and completely accurate.
It is prohibited to create applications through anonymous proxy servers or any other anonymous connections to the Internet.

Monitoring the User’s transactions and analyzing the data obtained is also a tool for risk assessment and detection of suspicious operations. If money laundering is suspected, our Service monitors all transactions and reserves the right to:

report suspicious operations to the relevant law enforcement agencies;
suspend or terminate the User’s account;
withhold the user’s funds until a full investigation of the incident is completed;

2. Risk Assessment and Liability of the Parties

Before creating an exchange application, the User is obliged to independently assess the risks associated with the origin of the funds being sent, including preliminary verification of the cryptocurrency address and/or transaction used for compliance with AML requirements, as well as to verify the absence of links to prohibited platforms/services specified in this Policy.

The Service strongly recommends that Users conduct their own AML verification of addresses and transactions in advance using publicly available specialized services, including, but not limited to: https://www.bestchange.ru/report/, as well as other public AML services and blockchain explorers.

By creating an exchange application, the User confirms and agrees that:

they have independently assessed the admissibility and risks of using the funds being sent;
they have verified (and bear responsibility for verifying) the absence of links to prohibited platforms/services specified in this Policy;
they understand that transactions may subsequently be recognized as high-risk or associated with illegitimate activities;
they assume the risk of possible suspension of the operation, conducting an AML/KYC/SoF/EDD check, refusal of service, or refund of funds in cases provided for by this AML policy;

The Service is not liable for any consequences arising from the User’s use of funds with an increased AML risk, if such risks could have been identified through preliminary self-verification.

The creation of an exchange application is considered by the Service as clear confirmation of the User’s agreement with this AML policy, the conditions for conducting verifications, and the distribution of risks associated with AML control.

3. Risk-Score Model and Thresholds

In order to ensure financial security and prevent risks, some transactions may be temporarily frozen if the risk level exceeds 60%.

If a transaction contains High-Risk Labels, regardless of the final percentage value of the Risk-Score, the transaction may also be frozen.

High-risk labels inсlude, but are not limited to:

sanctions lists and persons under restrictive measures;
terrorist financing;
darknet marketplaces;
mixing services (mixers);
stolen funds;
fraudulent schemes (scam/fraud);
extortion (ransomware);
other sources classified by the AML analyzer as High Risk.

In the monitoring process, solutions similar to those used in international practice are applied (including tools such as Crystal Intelligence, Chainalysis, Elliptic, and similar analytical systems). For security and internal policy reasons, we do not disclose the full list of tools used and the technical details of their integration.

We also do not work with Iranian and any sanctioned platforms. Platforms that have ceased operations but retain a historical link to past transactional activity are also considered prohibited. Below is an incomplete list provided as an example:

Tornado Cash; Hydra; rapira.net; Blender.io; Lazarus Group; Genesis Market; ChipMixer; CommEx.com; Shinbad.io; capitalist.net; Bitpapa.com; NetEx24.net; HTX.com; Exmo.com; Aifory.pro; USDKG.com; Arvix.pro; ABCEX.io

4. Procedure for an AML Incident

If a transaction has been frozen, the following information must be provided for its unblocking:

What is your employment status?
What are your sources of income?
Through which source did the funds come to you before you made a deposit to us from your wallet/platform? Please provide us with proof from the history of deposits and withdrawals from the sending platform to your wallet, from where you subsequently made a deposit to our platform;
What was the purpose of receiving funds from the deposit to your wallet/platform? Please provide proof of withdrawal of funds from the sending platform to your wallet;
If you were not the sender of the funds, but a third party, please provide us with proof of communication/correspondence confirming receipt of the funds/payment.

The following materials must also be provided:

A photograph of the document confirming your identity (passport or national ID card), with all sides in good quality;
A photograph of you holding this document in your hands in good quality;
Proof of Source of Funds (SoF);
Screenshots of the transaction;
Confirmation of address ownership.

After providing all the above data and reviewing the application, a refund of funds is carried out minus the network fee of the cryptocurrency being returned. The period for reviewing an AML incident can be up to one month. In some cases, the review period may be extended for the duration of the investigation into the incident.

5. Refund

A refund is possible exclusively for clients who have passed KYC and are not associated with money laundering or other violations of the law.
The refund is made to the same address (details) from which the funds were sent.
The Service has the right to withhold actually incurred expenses, if any, including network fees and operational costs. The amount of withholding can be up to 5% of the refund amount, but not more than 100 USD.
In case of detection of High-Risk Labels and the client’s refusal to undergo the KYC procedure, as well as for users who have not confirmed their identity or have been found to be involved in illegal activities, a refund of funds may be impossible.

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