AML / KYC POLICY
1. Introduction
1.1 The Anti-Money Laundering (AML) policy and Know Your Customer (KYC) procedure are designed to prevent the use of Exchangefor.me for illegal activities.
1.2 Exchangefor.me adheres to international standards of compliance:
1.2.1 money laundering prevention
1.2.2 counter-terrorism financing
1.3 The service applies a risk-based approach when analyzing user transactions.
2. Purpose of the AML / KYC Policy
2.1 The main objectives of the AML / KYC policy:
2.1.1 preventing illegal use of the service
2.1.2 detecting suspicious transactions
2.1.3 reducing financial and reputational risks
2.1.4 compliance with international AML standards
3. Prohibited Use of the Service
3.1 Use of the service is prohibited for the following purposes:
3.1.1 laundering proceeds from criminal activity
3.1.2 financing terrorism
3.1.3 fraudulent operations
3.1.4 buying or selling prohibited goods and services
3.1.5 circumventing sanctions
3.2 The service administration has the right to refuse service to users if suspicious activity is detected.
4. User Requirements
4.1 The sender and recipient of funds must be the same person.
4.2 Use of the service for transfers to third parties is prohibited.
4.3 Users must provide accurate and up-to-date information.
4.4 Use of anonymous connections is prohibited.
4.5 Anonymous connections include:
4.5.1 VPN
4.5.2 TOR
4.5.3 Proxy
5. Risk Assessment Model (Risk Score)
5.1 The service uses a risk assessment model (Risk Score) to analyze cryptocurrency transactions.
5.2 Risk Score is determined based on:
5.2.1 cryptocurrency address history
5.2.2 links to high-risk services
5.2.3 geographic factors
5.2.4 transaction activity analysis
5.2.5 user behavioral analysis
5.3 If the Risk Score exceeds acceptable thresholds, the transaction may be:
5.3.1 temporarily suspended
5.3.2 sent for additional review
5.3.3 blocked until KYC or SoF is completed
5.4 Risk Score thresholds are defined by the service’s internal risk assessment system.
5.5 If the acceptable risk level is exceeded, the transaction may be temporarily suspended until additional verification is completed.
5.6 Decisions on additional verification are made according to the AML internal policy and transaction analysis.
6. AML Transaction Analysis
6.1 The service uses specialized blockchain analytics tools to review transactions.
6.2 Transaction analysis identifies connections of funds with the following risk sources:
6.2.1 darknet services
6.2.2 fraudulent platforms
6.2.3 sanctioned addresses
6.2.4 stolen funds
6.2.5 high-risk cryptocurrency sources
7. KYC and SoF Procedures
7.1 During AML checks, the service may request user documents.
7.2 KYC procedure may require:
7.2.1 passport
7.2.2 ID card
7.2.3 selfie with document
7.2.4 proof of address
7.3 SoF procedure may require:
7.3.1 cryptocurrency wallet screenshots
7.3.2 transaction history
7.3.3 proof of cryptocurrency purchase
7.3.4 bank statements
7.3.5 other documents verifying the source of funds
8. AML Check Timing
8.1 AML and KYC checks usually take 1 to 10 business days.
8.2 In certain cases, the review period may be extended.
8.3 Reasons for extension may include:
8.3.1 complexity of investigation
8.3.2 need for additional verification
8.3.3 time required for the user to provide documents
8.4 Users are notified of the results via the email provided in the application.
8.5 Country and Territory Restrictions
8.5.1 Exchangefor.me does not provide services to citizens or residents of the following countries and territories:
Afghanistan, Belarus, Bosnia and Herzegovina, Burundi, Central African Republic, China, Democratic Republic of Congo, Eritrea, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Lebanon, Libya, Mali, Myanmar (Burma), Nicaragua, North Korea (DPRK), Russia, Somalia, South Sudan, Sudan, Syria, Tunisia, Venezuela, Yemen, Zimbabwe, Abkhazia, Cambodia, Crimea (region of Ukraine), Donetsk (region of Ukraine), Federative Republic of Ambazonia, Gabon, Honduras, Kosovo, Luhansk (region of Ukraine), Niger, Pakistan, South Ossetia, Tajikistan, Transnistria, Turkmenistan, Australia, Canada, Japan, New Zealand, United Kingdom, United States of America (USA).
8.5.2 In case of violation of this clause, the service reserves the right to suspend operations and block funds until the circumstances are clarified.
9. Preliminary AML Check
9.1 Before submitting an application, users can conduct a preliminary AML check of their cryptocurrency funds.
9.2 Preliminary checks allow assessment of fund risk before performing an exchange.
9.3 Users may use third-party analytics services to conduct this check.
10. AML Cryptocurrency Address Check
10.1 Users can verify a cryptocurrency address or wallet.
10.2 The check analyzes potential connections of funds with:
10.2.1 fraudulent operations
10.2.2 darknet services
10.2.3 sanctioned addresses
10.2.4 cryptocurrency mixers
10.2.5 stolen funds
10.2.6 other high-risk sources
11. Using External AML Services
11.1 Users may perform AML checks via third-party analytics services.
11.2 In particular, users may use the cryptocurrency address check tool on the BestChange monitoring site.
11.3 The check is available at:
11.3.1 https://www.bestchange.ru/report/
12. Submission of Check Results
12.1 After conducting an AML check, users may submit the results to the service operator.
12.2 Submission of results may speed up application processing.
12.3 The operator may use the results to assess transaction risks.
13. Refusal of Preliminary Check
13.1 Users may refuse to conduct a preliminary AML check.
13.2 In case of refusal, users acknowledge that they understand the potential risks.
13.3 The service reserves the right to:
13.3.1 perform additional checks
13.3.2 request KYC or SoF documents
13.3.3 temporarily suspend transaction processing
14. Transaction Monitoring
14.1 The service continuously monitors transactions.
14.2 Monitoring may include:
14.2.1 blockchain analysis
14.2.2 sanctions list checks
14.2.3 suspicious activity analysis
14.2.4 monitoring irregular transactions
15. Transaction Blocking
15.1 Upon detection of suspicious activity, the service has the right to:
15.1.1 suspend the transaction
15.1.2 request documents to identify the user
15.1.3 conduct additional AML checks
15.2 Users receive notifications detailing further actions.
16. Funds Return Policy
16.1 Returns are possible only after AML or KYC checks are completed.
16.2 Return requests must be sent from the email provided during application.
16.3 Requests must include the application number and return address.
17. AML Check Fees
17.1 In case of transaction blocking, the AML processing fee does not exceed 5% of the blocked amount and no more than 100 USD equivalent.
17.2 The fee covers:
17.2.1 AML analysis
17.2.2 verification procedures
17.2.3 manual transaction moderation
17.3 If users successfully complete KYC and SoF and no evidence of illegal origin of funds exists, the refund fee is limited to network fees only.
18. Appeals
18.1 Users have the right to appeal decisions regarding blocking or refusal of service.
18.2 Appeals can be submitted to customer support.
18.3 Appeals must include:
18.3.1 application number
18.3.2 additional information
18.3.3 required documents
19. Personal Data Processing and Protection
19.1 Users’ personal data is processed according to the service’s privacy policy.
19.2 Data is used exclusively for AML and KYC procedures.
19.3 Access is granted only to authorized service personnel.
20. Policy Updates
20.1 The AML and KYC policy may be updated.
20.2 Updates may occur due to:
20.2.1 changes in legislation
20.2.2 updated monitoring requirements
20.2.3 changes in internal procedures
21. Contacts
21.1 For any questions regarding AML and KYC policy, users may contact Exchangefor.me support.
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