AML / KYC POLICY
The Anti-Money Laundering and Know Your Customer Policy (hereinafter - AML / KYC Policy) is designed to prevent and mitigate potential risks of ExchangeFor.me being involved in any illegal activity.
2. Purpose of internal regulation
The ExchangeFor.me service adheres to the practices and measures in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism (AML). The purpose of these measures is to demonstrate that ExchangeFor.me takes seriously any attempt to use its service for illegal purposes.
The ExchangeFor.me service warns users against attempts to use the ExchangeFor.me service for money laundering, terrorist financing, fraud of any kind, as well as against using the service to buy prohibited goods and services.
The ExchangeFor.me service, its administration, employees and domain owners are not responsible for the misuse of the service by third parties, the actions of intruders and possible damage associated with the use of the ExchangeFor.me service.
To prevent illegal operations, the ExchangeFor.me service sets certain requirements for all Applications created by the User:
4.1. The sender and the recipient of the Payment under the Application must be the same person. Using the services of the Service, transfers in favor of third parties are strictly prohibited.
4.2. All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.
4.3. It is strictly forbidden to create Applications by the User using anonymous proxy servers, VPN, Tor or any other anonymous Internet connections.
5. Verification procedures
One of the international standards for the prevention of illegal activities is customer due diligence (hereinafter - Verification). To this end, ExchangeFor.me implements its own verification procedures in strict anti-money laundering standards and the “Know Your Customer” procedure.
5.1. The ExchangeFor.me Service may require the User to provide the ExchangeFor.me Service with reliable, independent source documents, data or information (for example, national ID card, international passport, bank statement). For such purposes, the ExchangeFor.me Service reserves the right to collect the User's identification information in order to comply with the AML / KYC Policy.
5.2. The ExchangeFor.me service will take steps to confirm the authenticity of documents and information provided by Users. All legal methods for double verification of identification information will be used, and the ExchangeFor.me Service reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious.
5.3. The ExchangeFor.me service reserves the right to verify the identity of the User on an ongoing basis, especially when his identification information has been changed or his activity seemed suspicious (unusual for a particular User). In addition, the ExchangeFor.me Service reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.
5.5. After confirming the identity of the user, the ExchangeFor.me Service may refuse to provide services to the User in a situation where the services of the ExchangeFor.me Service are used to conduct illegal activities.
5.6. Users who intend to use payment cards for the purpose of consuming services must undergo card verification in accordance with the instructions available on the ExchangeFor.me website.
5.7. The ExchangeFor.me service has regulatory requirements to verify the source of funds or cryptocurrencies in order to know that the sources of funds that Users use to trade are legal.
6. Responsible Official
The person in charge of AML compliance is the person duly authorized by the ExchangeFor.me Service, whose responsibility is to ensure the effective implementation and enforcement of the AML / KYC policy.
6.1. The duty of such an official is to monitor all aspects of ExchangeFor.me's activities in combating the legalization of proceeds from crime, including money laundering and terrorist financing, including but not limited to the following methods:
- collection of user identification information;
- creating and updating internal policies and procedures for the completion, review, submission and storage of all reports and records required by applicable laws and regulations;
- monitoring transactions and investigating any significant deviations from normal activities;
- implementation of a records management system for appropriate storage and retrieval of documents, files, forms and logs;
- regular updating of the risk assessment;
- providing law enforcement agencies with the information required in accordance with applicable laws and regulations.
6.2. The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in preventing money laundering, terrorist financing and other illegal activities.
7. System functions
ExchangeFor.me performs a variety of compliance tasks, including data collection, filtering, record keeping, investigation management and reporting. System features include:
- daily verification of Users for the existence of recognized blacklists (for example, OFAC), aggregating transmissions across multiple data points, placing users on watchlists and denials of services, opening cases for investigation where necessary, sending internal messages and filling mandatory reports, if applicable;
- management of affairs and documents.
8. Behavior analysis
The ExchangeFor.me service verifies Users not only by verifying their identity, but, more importantly, by analyzing their behavior in transactions. Therefore, the ExchangeFor.me Service relies on data analysis as a risk assessment and suspicion detection tool.
9. Risk assessments
ExchangeFor.me, in accordance with international requirements, applies risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, ExchangeFor.me ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks.
10. Performing customer checks
If the administration of the ExchangeFor.me service arises that the user is trying to use the services of the Service for money laundering or for the purpose of carrying out any other illegal operations, the administration has the right to:
10.1. suspend the execution of the user's exchange operation;
10.2. request the User to provide identification documents;
10.3. request from the User any additional information and documents in the event that they carry out suspicious transactions;
10.4. ensure that reports of suspicious transactions are reported to the appropriate law enforcement authorities through the AML Compliance Officer.
11.1. The ExchangeFor.me service and its employees undertake to maintain confidentiality in relation to any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom the information on the transaction has been transferred.
11.2. The confidentiality obligation imposed on the employees of the ExchangeFor.me Service remains in effect after the termination of their work or any other contractual relationship with the ExchangeFor.me Service, as well as when such employees are transferred to another workplace. Disclosure of such information to government, law enforcement agencies and other entities in cases determined by law is not a violation of the confidentiality obligation.
11.3. The obligation to maintain confidentiality, provided that the use of disclosed information is limited to preventing the legitimization of proceeds of crime and terrorist financing, may not apply to disclosures between financial institutions that form a consolidated group that cooperates with the ExchangeFor.me Service.
In connection with the foregoing, the ExchangeFor.me service does not bear any legal responsibility for its use for the purpose of money laundering, terrorism financing or the purchase of prohibited goods and services, but undertakes to take all possible and available actions to prevent attempts to use the EExchanger Service .co for the purpose of money laundering, terrorist financing, or the purchase of prohibited goods and services.