AML/KYC service policy

AML (Anti-Money Laundering) — This is a set of measures and actions aimed at preventing and detecting illegal financial transactions related to money laundering and terrorist financing.

These procedures are implemented internally in accordance with the laws of the country of business, the laws of the countries of which the clients are citizens, as well as in accordance with generally accepted FATF standards, OFAC requirements and other regulatory authorities of different countries. The availability of documentation confirming these standards, as well as their actual practical application, is one of the mandatory aspects of compliance.

KYC (Know Your Customer), or "Know Your Customer", is a mandatory procedure aimed at identifying and verifying users of an exchange office. The process is necessary in order to verify the legality of the origin of funds and ensure the security of operations, preventing the use of the service for money laundering or other illegal activities.

The exchange office has the right to request KYC verification if it suspects:

• transactions related to money laundering;
• transactions involving income from terrorist and criminal activities;
• transactions involving income from as a result of illicit drug trafficking;
• transactions, related to trade operations with countries with which international trade is prohibited by applicable law;
• transactions involving income from any other illegal activity.

Verifying an AML address helps ensure the security of transactions and prevent the exchange office from being used for illegal activities. This allows you to confirm the accuracy of the information provided and reduce the risks of fraud.

Verification also gives the client the opportunity to learn in advance about possible risks or their absence before actually sending funds to our wallets. During the verification process, the client receives an analyzer report at his address, which gives a complete understanding of the security status of the transaction.

The procedure ensures compliance with legal requirements and anti-money laundering standards, protecting both customers and the service itself.

Our service uses comprehensive AML verification of incoming assets based on the Risk-Score model provided by our payment provider, namely the Rapira exchange and third-party analytical systems (such as CoinKYT, etc.).

The purpose of the check — exclude interaction with assets that may be related to illegal activities.

How the Risk-Score works

• Each transaction is automatically analyzed for the presence of risk tags.
• Based on the results of the analysis, the overall AML risk is formed.
• The total risk should not exceed 80%.
• If the acceptable risk level is exceeded, the transaction is automatically rejected, and the client is notified of the need for verification or a refund.

High-risk tags, leading to blocking

Transactions with certain high-risk tags can be blocked regardless of the total percentage of risk. These tags include, but are not limited to:

• Sanctions;
• Illegal Services;
• Scam / Fraud;
• Child Abuse Materials;
• Terrorism Financing;
• Darknet markets;
• Mixers, prohibited jurisdictions, and other high-risk categories.

When such tags are detected, the transaction is automatically rejected in accordance with the requirements of the provider`s AML policy.

If the risk is below 80%, but there are some suspicious tags

In case of detection of suspicious transactions, our service has the right:

• suspend financial transactions for up to 14 days;
• request from the user a video confirmation of the transfer from the user`s wallet, as well as a hash of the transaction;
• at the request of the regulator (exchange, crypto processing, government agency or another organization, having appropriate legal grounds) to request any additional information from the user in case of suspicious transactions;
• to refund digital assets only to those wallets from which they were sent to us;
• if the user refuses to provide the requested information (including KYC) funds may be frozen indefinitely and may be non-refundable.

We do not disclose the internal thresholds of automatic locks and do not disclose the parameters, used by our payment providers to prevent their use for illegal transactions, including money laundering. All transactions are automatically verified in accordance with the AML policy and international standards, and transactions that do not meet these requirements are automatically rejected.

To confirm the origin of the funds, we ask users to provide answers to the following questions:

1. Which platform did the funds come from? If possible, provide screenshots from the withdrawal history of the sender`s wallet/platform, as well as a link to the transaction in the browser.
2. For which service were the funds received?
3. Specify the amount, date, and time of the transaction.
4. Through which contact person did you communicate with the sender of the funds? If possible, provide screenshots of the correspondence with the sender, which confirms the sending of funds.
5. Provide screenshots of the withdrawal from the platform from where the counterparty transferred funds to you, with detailed information about the transaction.

If funds need to be refunded as a result of AML/KYC procedures, the service may deduct a processing fee of up to 5% of the refund amount, but not more than $100.

Refunds are only possible for verified users., who have successfully passed the KYC procedure and have no reasonable links to money laundering or other illegal activities.

For users who have not passed verification, or in the case of confirmed involvement in illegal activities, a refund is not guaranteed.

If a transaction receives a High Risk status during automatic AML verification, However, this category does not indicate a direct connection between the user and illegal activities (including certain service or aggregated risk tags), additional internal analysis is carried out.

After the analysis, if there are not sufficient grounds to assert that there is a stable or systemic connection with high-risk entities, and the data provided does not confirm participation in illegal activities, the transaction will not be executed., and the funds will be returned to the sender.

In such cases, the KYC procedure is not required for a refund.

Refunds are made within a reasonable time, usually within 7-14 business days from the date of the decision. Upon refund, the network commission provided by the cryptoprovider for making a refund may be deducted.

This process is applied in the absence of other risk factors, signs of intentional circumvention of compliance procedures, or other circumstances that require additional verification in accordance with AML`s internal standards.