AML

1. General Provisions

1.1. This Policy regulates measures to counteract the legalization (laundering) of income obtained through criminal means, the financing of terrorism (AML - Anti-Money Laundering), and the financing of the proliferation of weapons of mass destruction (CFT), applied by the cryptocurrency exchange Service (hereinafter referred to as the "Service"). 

1.2. The Service adheres to international standards and FATF recommendations, as well as the norms of applicable legislation in the field of financial monitoring. 

1.3. Creating an exchange request and using the services of the Service on the official website or through any official software interfaces (including integrated mobile and messenger applications) means the User's unconditional agreement with the terms of this Policy.

2. User Identification and Credential Control System

2.1. Verification of clients, payment cards, and personal data is carried out using the built-in verification software tools of the Service. 

2.2. The Service applies flexible user verification (KYC) rules depending on the direction of the exchange, transaction volumes, and established limits. 

2.3. In the event of triggering automatic protection systems (fraud monitoring systems, detection of suspicious frequency of request creation, mismatched credentials), the transaction is suspended. The status of the request in the User's Personal Account changes to "Verification Required" or "Under Review." 

2.4. To undergo the KYC procedure, the User agrees to provide: 

- An official document confirming identity (passport, ID card, driver's license). 

- A photograph of the User holding the document (selfie verification) and/or video verification. 

- Documents confirming the legality of the origin of funds (upon request from the compliance department).

3. Automated Monitoring and Risk Thresholds

3.1. The analysis of incoming blockchain transactions, monitoring of network statuses, and initial AML screening of assets are carried out in real-time by the Service's software module, integrated with accredited blockchain data analysis providers. 

3.2. The result of the verification is a comprehensive analytical report containing the percentage ratio of clean and suspicious assets (Risk Score) from 0% to 100%. 

3.3. The Service has established the following critical markers and overall transaction risk thresholds: 

- Critical risk threshold: Exceeding the overall risk indicator of 50% or higher. 

- Critical risk categories: Detection of direct links between assets and illegal marketplaces, anonymization services (mixers), sanctions lists, stolen funds, fraudulent schemes, or ransomware, regardless of the overall risk percentage. 

3.4. If the specified threshold is exceeded or a critical marker is detected, the Service's system instantly blocks the automatic payment for the request and changes its status to "Frozen / AML Check." The client receives an automatic notification through established communication channels.

4. Incident Review Procedures and Timelines

4.1. In accordance with the operational standards of specialized monitoring of cryptocurrency exchange services, the Service commits to reviewing incidents related to AML blocking as quickly as possible. 

4.2. The timeline for the initial verification of provided documents and conducting an internal compliance investigation is no more than 24 hours (up to 3 banking days if an official response from an external liquidity provider is required). 

4.3. The User is provided with detailed grounds for the blocking (officially generated AML report with a unique verification identifier or log output from the monitoring system indicating specific risk tags) upon their first request to customer support.

5. Conditions and Fees for Fund Returns

5.1. Funds blocked by the monitoring system are subject to return to the sender only after successful identity verification (KYC) in the Service interface in accordance with Section 2 of this Policy. 

5.2. When returning high-risk assets, the Service retains a fixed fee for technical processing, covering blockchain network fees (Gas/Fee) and costs for conducting manual investigations amounting to 10% of the transaction amount. 

5.3. Refunds are strictly made to the credentials (wallet) of the sender from which the original transaction was made, within 24 hours from the moment of successful identity confirmation of the User and approval of the request by the compliance department. 

5.4. Refunds are not possible if the assets are permanently seized by direct request from law enforcement authorities or international sanctions agencies. In this case, the Service provides the User with official documents confirming the fact of seizure.

6. Confidentiality and Data Storage

6.1. All data received from the User in the course of AML/KYC procedures is stored in encrypted form on secure servers for 5 years in accordance with international requirements for the storage of financial information. 

6.2. The Service commits not to disclose the received data to third parties, except in cases of official requests from law enforcement or judicial authorities, as well as reciprocal requests from specialized monitoring administrations to resolve disputed situations.