General Provisions
The AML verification policy is aimed at identifying transactions related to terrorist financing, money laundering, and other illegal activities. Money laundering is the concealment of the illegal source of funds by converting them into funds or investments that appear legitimate.
To prevent illegal transactions, the Service establishes certain requirements for all Requests created by the User:
1. The sender of funds and the request author must be the same person. Payment by third parties, as well as the transfer of payment details issued for the request to third parties, is prohibited.
2. The user’s personal data must be current and completely accurate.
3. Submitting requests through anonymous proxy servers or any other anonymous internet connections is prohibited.
Monitoring the User’s transactions and analyzing the resulting data also serves as a risk assessment tool and helps detect suspicious transactions. If money laundering is suspected, our Service monitors all transactions and reserves the right to:
— report suspicious transactions to the appropriate law enforcement agencies;
— suspend or terminate the User’s account;
— hold the User’s funds until the incident is fully investigated;
Before creating an exchange request, the User is obligated to independently assess the risks associated with the origin of the funds being sent, including a preliminary check of the cryptocurrency address and/or transaction for compliance with AML requirements, as well as verifying the absence of connections to prohibited platforms/services specified in this Policy.
The Service strongly recommends that Users conduct independent AML checks 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 request, the User acknowledges and agrees that:
– they have independently assessed the admissibility and risks of using the funds being sent;
– the User has verified (and is responsible for verifying) that there is no connection to the prohibited platforms/services specified in this Policy;
– the User understands that transactions may subsequently be deemed high-risk or associated with illegitimate activity;
– the User assumes the risk of possible transaction suspension, AML/KYC/SoF/EDD verification, denial of service, or refund of funds in cases provided for in this AML Policy;
The Service is not responsible for any consequences arising from the User’s use of funds with increased AML risk, if such risks could have been identified through prior independent verification.
The creation of an exchange request is considered by the Service as the User’s explicit confirmation of agreement with this AML Policy, the terms of verification, and the distribution of risks associated with AML control.
Risk-Score Model and Thresholds
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 resulting Risk-Score percentage, the transaction may also be frozen.
High-risk labels inсlude, but are not limited to:
— Sanctions lists and individuals subject to restrictive measures;
— Terrorist financing;
— Darknet marketplaces;
— Mixers;
— Stolen funds;
— Scams/fraud;
— Ransomware;
— Other sources classified as High Risk by the AML analyzer.
We use solutions similar to those used internationally (including tools like Crystal Intelligence, Chainalysis, Elliptic, and similar analytical systems) during monitoring.
For security and internal policy reasons, we do not disclose the full list of tools used or the technical details of their integration.
We do not work with sanctioned platforms. A list of the most popular ones is provided below, but is not limited to:
Tornado Cash;
Hydra;
rapira.net;
Blender.io;
Lazarus Group;
Genesis Market;
ChipMixer;
CommEx.com;
Shinbad.io;
capitalist.net;
Bitpapa.com;
NetEx24.net;
Any Iranian or sanctioned platforms. Platforms that have ceased operations but retain historical ties to past transaction activity are also considered prohibited.
AML Incident Procedure
If a transaction has been frozen, you must provide the following information to unblock it:
— What is your employment status?
— What are your sources of income?
— How did you receive funds before you deposited from your wallet/platform? Please provide us with evidence of your deposit and withdrawal history from the sending platform to your wallet, from which you subsequently deposited to our platform;
— What was the purpose of receiving funds deposited to your wallet/platform? Please provide evidence of withdrawals from the sending platform to your wallet;
— If you were not the sender of the funds, but a third party, please provide us with evidence of communication/correspondence confirming receipt of the funds/payment.
You must also provide the following documents:
1. A high-quality photograph of your identity document (passport or national ID), showing all sides;
2. A high-quality photograph of you holding this document;
3. Proof of origin of funds (SoF);
4. Transaction screenshots;
5. Confirmation of address ownership.
After all the above information is provided and the application is reviewed, the funds will be refunded minus the network fee for the returned cryptocurrency. The AML incident review period may take up to one month. In some cases, the review period may be extended while the incident is investigated.
Refund
– Refunds are available only to clients who have passed KYC and are not involved in money laundering or other violations of the law.
– Refunds are made to the same address (details) from which the funds were sent.
– The service reserves the right to withhold actual expenses incurred, if any, including network fees and transaction costs. The withholding amount may be up to 5% of the refund amount, but not more than USD 100. – In the event that high-risk labels are detected and the client refuses to undergo the KYC procedure, as well as for users who have not confirmed their identity or are found to be involved in illegal activity, refunds may not be possible.
