1. General Provisions
The exchange service complies with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) requirements.
All exchange transactions may be subject to automatic AML checks.
The verification is carried out on the side of the connected payment provider, which analyzes transactions and determines the transaction risk level.
The Service does not have access to risk assessment algorithms, data sources, or exact Risk Score values used by the payment provider.
2. AML Check and Temporary Suspension
If a transaction is identified as suspicious or requires additional verification, the exchange may be temporarily suspended.
Further processing is carried out by the payment provider, including:
- transaction analysis;
- risk assessment;
- requesting additional information if necessary;
- making a decision on proceeding with the exchange or refunding the funds.
3. Risk-Based Approach
A risk-based approach is applied when processing exchange transactions. Risk assessment is performed by the connected payment provider based on a combination of factors.
Transactions with an increased risk level may inсlude, but are not limited to:
- use of addresses associated with high-risk sources (including but not limited to: Child Exploitation, Dark Market, Dark Service, Enforcement Action, Fraudulent Exchange, Gambling, Illegal Service, Mixer, Ransom, Sanctions, Scam, Stolen Coins, Terrorism Financing);
- unusual transaction behavior or increased activity associated with an address;
- inconsistencies in user data or exchange parameters;
- other factors identified during analysis by the payment provider.
In case of elevated risk, the following actions may be taken:
- temporary suspension of the exchange;
- request for additional data or completion of KYC/SoF procedures;
- additional verification;
- refusal to process the exchange.
In case of suspension, the user interacts with the payment provider during the verification process. The Service informs the user and provides assistance if necessary.
4. KYC / SoF Procedures
If required, the user may be directed to complete identity verification (KYC) and source of funds (SoF) procedures.
All checks are carried out exclusively on the side of the payment provider.
The Service does not request or store user documents directly.
The list of requested data is determined by the payment provider and may inсlude:
- identity document (passport, ID card, or other document);
- selfie, video identification, or photo with a document;
- proof of source of funds;
- other information and materials requested by the provider.
5. Verification Timeframes
The duration of AML / KYC / SoF checks depends on the payment provider and may vary in each case.
Verification is carried out within a reasonable timeframe required to complete all necessary procedures.
6. Refunds
In case of temporary suspension and a subsequent decision to return funds, the refund is carried out by the payment provider after completion of the verification or in another manner depending on the technical processing scheme.
Refund conditions:
- The Service does not charge a refund fee;
- blockchain network fees, bank fees, payment systеm fees, or other third-party fees may apply and are not controlled by the Service;
- refund timeframes depend on the procedures and technical capabilities of the payment provider.
The final decision based on the verification results, including refunds, is made by the payment provider in accordance with its internal procedures and compliance requirements.
7. AML Analyzer
AML checks are performed using tools integrated into the payment provider.
Specific Risk Score parameters, analyzer names, data sources, and risk assessment methodology may not be disclosed to the Service or the user.
8. User Interaction
In case of AML / KYC checks, the user interacts directly with the payment provider.
The Service does not participate in the verification process and does not influence decisions regarding blocking, verification, refusal to process the exchange, or refunds.
9. Preliminary Address Check
Before creating a request, the user may independently perform a preliminary AML check of a crypto address using an external service:
https://www.bestchange.ru/report/
The user has the right to:
- independently perform a preliminary address check;
- use the results to assess risks before making an exchange;
- refuse the preliminary check and accept the associated risks.
10. User Consent
By creating a request, the user confirms that:
- they have read this AML policy;
- they understand the possibility of AML / KYC / SoF checks;
- they agree to interact with the payment provider in case of such checks;
- they are aware of the risks associated with the use of cryptocurrency assets.
11. Final Provisions
The Service reserves the right to amend this AML policy at any time. The current version is published on the website and comes into force upon publication.
