AML/KYC - Policy

KYC (Know Your Customer) — This is a customer identification and verification process that allows financial institutions to ensure that they know their users and are able to identify potentially risky activities.

• Criminal activity (drug trafficking, fraud, corruption, etc.).
• Financing of terrorism.
• Tax evasion.

KYC includes:

1. Identification of the client
   • Request identification documents from the client (passport, driver`s license, etc.).
2. Verification of information
   • Check the submitted documents for authenticity.
   • Use electronic databases and resources to verify information.
3. Collecting additional data
   • Requesting information about the client`s sources of income.
   • Get information about the purpose and nature of the business relationship.
4. Risk assessment
   • Determine the client`s risk level (high, medium, low) based on the information collected.
   • A high degree of risk may require additional verification and confirmation of income sources.

AML (Anti-Money Laundering) is a set of measures, rules and procedures aimed at preventing money laundering and terrorist financing. The main task of AML is to identify, prevent and punish individuals and organizations that attempt to legalize illegally obtained funds.

The AML procedure includes

Customer Identification (KYC)

The KYC procedure is part of the AML and includes verification of the identity of customers, their financial activities and sources of income.

Transaction monitoring

Regular analysis of financial transactions for suspicious activity, including large amounts, frequent transfers and unusual routes.

Report of suspicious activity

The Service is obliged and has every right to report any suspicious transactions to the relevant authorities, such as financial control services.

Studying the sanctions lists

Checking clients for compliance with international and local sanctions lists to avoid interaction with individuals and organizations involved in criminal activities.

Risk assessment

Conducting a regular assessment of money laundering risks, to identify vulnerabilities and strengthen control in these areas.

All incoming/outgoing transactions are subject to comprehensive Risk-based AML verification.- The Score Model provided by our payment systems and third-party analytical systems.

Risk Categories:

High Risk:

• Stolen Coins
• Ransom
• Child Exploitation
• Terrorism Financing
• Dark Market
• Dark Service
• Enforcement Action
• Scam

Medium Risk:

• Illegal Service
• Mixer
• Fraudulent Exchange
• Sanctions
• Gambling

Threshold values:

• The share of assets of the High Risk category is no more than 5%;
• The share of assets of the Medium Risk category is no more than 10%;
• The Overall Risk Score — not more than 75%.

If the specified values are exceeded, the transaction may be temporarily suspended for additional verification.

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

For identification purposes:

• photo or scan of the passport / ID;
• selfie with the document;
• video verification.

And also 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. Screenshots of the withdrawal from the platform from where the counterparty transferred funds to you, with detailed information about the transaction.
6. If funds need to be refunded as a result of AML/KYC procedures, the service may deduct the network`s commission.

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

For users, failed verification, the refund is made within 10 days after the internal analysis of the transaction. In this case, the refund fee is charged up to 5%, but not more than $100

If during the automatic verification An AML transaction receives a High Risk status, but this category does not indicate a direct connection between the user and illegal activity, and additional internal analysis is being conducted.

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 10 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., which require additional verification in accordance with internal AML standards.

KYT (Know Your Transactions) — This is the process of verifying and analyzing transactions to identify suspicious transactions related to money laundering or terrorist financing. This approach complements traditional KYC (Know Your Customer) procedures by focusing on monitoring and evaluating the activity of the transactions themselves.

The components of KYT:

1. Transaction analysis

   Evaluation of all incoming and outgoing financial transactions for anomalies, unusual patterns, and large amounts.

2. Defining patterns of behavior

   Developing a model of normal transaction behavior for each category of customers, to easily identify anomalies.

3. Real-time monitoring

   Continuous real-time transaction tracking to quickly identify and respond to suspicious activity.

4. Compliance with regulatory requirements

   Compliance with local and international AML and KYT standards, including regular reports and internal audits.

5. Reporting

   Preparation of reports on identified suspicious transactions for transmission to the relevant regulatory authorities.