This regulation is aimed at reducing the risks of the online platform associated with the process of laundering financial assets. The user is presented with the legal provisions and conditions from the internal policy of the site. For any questions or unclear questions, the user can contact the support service to clarify specific points and details of interest.

1. Basic provisions

1.1. Online platform/website - a party providing services for the exchange of digital and electronic currencies.

1.2. User/client - a party using the services of the site. Is a private or legal entity.

1.3. Service policy / regulation / regulation - the conditions and set of rules for combating illegal financial transactions when using the services of the site by the client.

1.4. Money laundering is the concealment or concealment of the actual purpose of funds, the veracity of their receipt, location, purpose of transfers and other violations in the process of fraudulent activity. The definition also includes investing in terrorism, distribution of narcotic substances and weapons, corrupt manipulations, and human trafficking.

1.4.1. Appropriate action is taken when user activity is suspicious.

1.5. The document is required for review.

1.6. The processes of implementation of financial sanctions are carried out at the international level.

1.6.1. Sanctions are accompanied by fines and restrictions determined by the EU, the UN and other organizations.

1.7. Prevention and control measures within the state contribute to the integration of AML provisions, which are rules that recognize the illegality of income certificates.

2. Rights of the online platform under the AML/KYC policy

2.1. Assign employees to detect, record and comply with measures aimed at countering illegal and suspicious financial transactions.

2.1.1. The employees of the online platform are personally responsible for all compliance with the law in their activities.

2.2. Provide information to the site management about the risks of laundering financial assets.

2.3. Implement methods related to combating fraudulent activities in relation to funds.

2.4. Maintain documentation and update policy on how to deal with illegal financial activity.

2.5. Create conditions for fixing risks and actions with violations.

2.6. Notify the authorities of law and order in case of suspicion and detection of threats, as well as quickly respond to the response of the relevant structures.

3. AML/KYC Policy Verification Principles and Customer Identification

3.1. The administration of the online platform in relation to the client is guided by a set of rules.

3.1.1. AML confirms its responsibility for the fact that the site will comply with all regulations regarding KYC.

3.1.2. You can contact the employee representing AML through the email address indicated on the online platform page.

3.2. Control and tracking of operations, as well as accounting of transactions is carried out on an ongoing basis and continuously.

3.3. The user must pass the identification of the person according to the KYC procedure.

3.4. Identification is carried out in the following order:

3.4.1. The user needs to present an identity document and a copy of it with a photo and all the data: state and / or foreign passport; driver license.

3.4.2. The following information is additionally submitted: full name; Date and place of birth; tax number; address of registration and actual place of residence; any contact details; personal or indirect (through family members) belonging to the PEP.

3.4.3. The following additional documentation is also required for personal identification: paid utility bills; bank statements and other official papers containing user details.

3.5. The identification of the client, if it is a legal entity, occurs as follows:

3.5.1. It is required to provide an extract from the commercial register with an expiration date no later than 3 months from the date of the request with an apostille.

3.5.2. The following information is additionally provided: name; registration number; actual and legal address; information about the representative, co-founders and / or beneficiaries and their passport information; any contact details.

3.6. The test results must be satisfactory.

3.7. Information that identifies the user is collected, stored, transmitted and protected in accordance with the privacy policy applicable to the online platform and in accordance with the provisions of the GDPR.

3.7.1. For five years, the online platform stores the following documentation after the end of the business relationship: verification and identification data; correspondence with the user; financial monitoring information; information about the presence of suspicious and non-standard transactions; accounting of all documentation related to monetary transactions.

4. Procedure for assessing possible risks and their prevention

4.1. The online platform, in cooperation with the client, calculates the risks of possible money laundering and illegal transactions.

4.2. The check takes into account the following items: user location; risk from the client; alleged transactions.

4.3. Risks with a high probability include data on the geography of the following areas: where there is a direct effect of UN or EU sanctions; territories that do not take measures to combat money laundering or support terrorism; with high levels of corruption.

4.4. The risk from the client himself is considered significant in the following cases: the user or members of his family are PEP persons (the fact must be revealed before the start of cooperation); the client is on the list of the UN and the EU as unreliable and subject to sanctions measures (information is monitored); participation in transactions related to illegal circulation of monetary assets.

4.5. A high level of risk from alleged transactions is determined in the following cases: payment on the application is carried out by a third party; the transaction being carried out has no justification; the list of actual participants in operations is hidden; assets come from different accounts; the amounts of the accrued amounts are non-standard for the user; in the course of operations, currencies of different denominations are used.

4.6. The client is considered unreliable in case of detection of risk facts from the listed grounds in clauses 4.3. 4.4. 4.5.

4.7. The online platform does not provide services in the event of: direct relationship of the client to the state with high risk indicators; sanctioned position in the field of financial activity; direct or indirect relation to PEP; there is suspicion or evidence of illegal financial transactions or participation in the past in investing assets in terrorism.

4.7.1. The discovery of the above facts gives grounds for the site to take enhanced verification measures regarding the reliability of the client.

4.8. Risks with a high probability include activities in the field of IT technologies: information transfer; entering incorrect/false data; implementation of hacker, virus attacks.

4.9. To prevent risks, site employees use only internal servers. Legal software with registered content is used. The integration of external media into technical equipment is prohibited.

4.10. To reduce the risk of receiving false data from the client, confirmation of personal information is required by the method selected by the online platform (video, live meeting).

4.11. To reduce the risks of cyberattacks, the site is constantly checked for security and suspiciousness of transactions. The software carries out a frequent update procedure and work to combat viruses.

4.12. To avoid risks when working with data, the online platform uses network fuses. The main site server is centralized and backed up.

4.13. The system is PCI/DSS certified.

4.14. The risk assessment methods used by the online platform contain such analysis methods that are the most effective for detecting the likelihood of any operations related to the laundering of financial assets and the development of terrorist groups.

5. Cases and procedure for due diligence

5.1. The Regulation applies to transactions of a non-standard nature, complex schemes of operations without economic overtones.

5.2. As a check, the user is identified on the basis of documentation, video communication, personal presence. Beneficiaries and co-founders are being verified. Business relations are being investigated. In certain cases, the client will be required to confirm the source of receipt of monetary assets. Data can be taken from registers.

5.3. Checks are carried out before the start of cooperation within the framework of compliance with the AML / KYC policy.

5.4. Where possible, transactions should be secured with a signature certifying the authenticity of the information received and the veracity of the relevant documentation.

6. Cases and procedure for extended due diligence

6.1. An extended version of the legal check is carried out on the user in the following cases: when the actual location does not match the information on the details; in case of doubt during the verification and impossibility of identifying the client or beneficiaries; when risks are identified with a high probability.

6.2. The site uses one of the following verification methods:

6.2.1. With the help of the register of a credit institution operating in the territory using AML rules.

6.2.2. The use of virtual data delivery, which will serve as proof of identity.

6.2.3. By conducting a transaction with the account of the participant in the transaction using a credit institution that interacts with the client in a country with an active AML / KYC protocol.

7. Principles of PEP verification

7.1. A user who is a PEP or who is directly or indirectly related to a PEP representative is required to enter information about this in the appropriate fields of the registration form. The data will be verified against publicly available sources.

8. Principles of Verification of Persons Subject to International Sanctions

8.1. When concluding a transaction, the user enters personal data that is used to identify the person. The information serves as the basis for checking for the existence of existing international sanctions.

9. Reasons for checking the user and his financial assets

9.1. An investigation is carried out in case of any suspicion.

9.2. Suspicious signs include:

  • inconsistency of the client"s appearance with his behavior;
  • inability to conduct transactions without outside help;
  • suspicion of illegal activity;
  • unreasonably high rates;
  • non-standard use of assets;
  • carrying out operations unrelated to the user"s activities;
  • the impossibility of explaining actions with finances;
  • transfer of funds to other accounts and to different countries;
  • impossibility of identification of the person;
  • an attempt to implement an illegal transaction;
  • the requirement to pay only in cash;
  • conducting cash transactions in excess of EUR 10,000;
  • operations carried out in banks located in a tax-free territory.
  • links with the following definitions:

- Darknet Marketplace;

- Darknet Service;

- Fraudulent Exchange;

- Illegal Service;

- Mixing Service;

- ransom; - Scam;

- Stolen Coins.

If connections are identified, then after verification, the funds will be returned to the sender"s details (minus a commission of 10%).

10. Cases of refusal of the site to cooperate

10.1. The online platform does not cooperate with the client if:

  • under 18 years of age;
  • representative offices of an individual;
  • refusal to provide documents;
  • provocative content of requests;
  • documentation confirming suspicions of illegal activities;
  • interaction with a user who is in a sanctioned position;
  • direct or indirect involvement in PEP;
  • ties in a high-risk country.



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