ANTI-MONEY LAUNDERING AND ILLEGAL OPERATIONS POLICY (KYC/AML Policy)

Last updated: 04.04.2026

1. In accordance with legal requirements and internal compliance rules, the Service follows a set of rules and procedures aimed at preventing the use of the Service for money laundering and other illegal operations, including:

1.1. The Service sets certain requirements for all Orders created by the User:

1.1.1. The sender and recipient of the Transaction under the Order must be the same person. Transfers to third parties through the Service are strictly prohibited.

1.1.2. All contact details provided by the User in the Order, as well as any other personal data submitted to the Service, must be current and accurate.

1.1.3. Creating an Order using anonymization tools or services is strictly prohibited, including anonymous proxy servers, VPN services, hosting/VPS solutions, TOR, and any other anonymous internet connections.

1.2. The Service checks Transactions received from the User using several specialized analytical tools that assess the risk level based on the Transaction's connections to various source categories:

Crystal Blockchain (crystalblockchain.com)
Chainalysis (chainalysis.com)
Elliptic (elliptic.co)
GetBlock (getblock.net)
Match Systems (matchsystems.com)

1.3. The Service reserves the right to suspend an Order and temporarily hold a Transaction in order to conduct an in-depth verification of the User's identity and confirm the source of funds in the following cases:

1.3.1. If the Transaction has connections to certain categories exceeding the allowed thresholds:

0% for Terrorism, Enforcement Action, Child Abuse, Human Trafficking;
1% for Dark Market, Illegal Activity, Scam, Fraud, Mixer, Malware, Ransomware, Stolen Funds, Hacking, Exploit, Drainer Wallet, Blackmail, Sextortion, Ponzi, HYIP;
4% for Sanctions;
20% for Gambling, Adult Services, High-Risk Exchange, Decentralized Exchange, Cross-Chain Bridge.

1.3.2. If the Transaction has connections to any of the following platforms, including platforms that have ceased operations: Payeer, Capitalist, Yobit, Exmo, FunPay, Heleket, NixMoney, BTC-e, Garantex, Grinex, Rapira, WebMoney, BitPapa, Netex24, as well as any platform from Iran or other sanctioned jurisdictions.

1.3.3. If the Transaction has connections to privacy coins such as Monero (XMR), Zcash (ZEC), Dash (DASH), or similar.

1.3.4. If any of the requirements under clause 1.1 have been violated.

1.4. Prior to creating an Order, the User must independently assess the risks associated with the origin of the funds being sent using publicly available specialized services, including a preliminary AML check of the cryptocurrency address to be used, as well as verify that it has no connections to the platforms and services listed in clause 1.3.2 of this Policy.

2. If an Order is suspended and a Transaction is held:

2.1. The Service will send the User a request within one business day asking for information and documents needed to verify the User's identity and confirm the source of funds for this Order and, if necessary, for previous Orders. The requested information and documents may include:

2.1.1. A photo of one of the following documents: passport, ID card, or driver's license.

2.1.2. A selfie of the User holding the document together with a handwritten note showing the current date and the User's signature, and if necessary, a video verification.

2.1.3. Proof of the User's residential address (utility bill, bank statement, or another document containing address information).

2.1.4. Information about what goods or services the User received the funds for.

2.1.5. Information about how the Transaction was sent to the Service's address, including:

2.1.5.1. if the Transaction was sent from the User's personal wallet — information about the origin of the funds that were in the personal wallet before the Transaction, and if requested by the Service, proof of withdrawal from a third-party platform to the personal wallet;

2.1.5.2. if the Transaction was sent directly from a third-party platform — proof of withdrawal from that platform to the Service's address;

2.1.5.3. if the Transaction was sent by an acquaintance, relative, client, or other third party — proof of communication with that person confirming the Transaction was sent, for example screenshots of correspondence.

2.1.6. Information about the User's employment status and sources of income.

2.2. Upon the Service's request, the User must either:

2.2.1. provide all requested information and/or documents in full; or

2.2.2. send a clear written refusal through the official communication channel (the email address provided when creating the Order).

3. If the User has provided all requested information and/or documents in full, the Service may temporarily hold the Transaction while reviewing the submitted materials. Following the review, the Service must:

3.1. either release the Transaction and resume the Order within 7 business days from the moment the last requested item was provided; or

3.2. return the Transaction within 7 business days from the moment the last requested item was provided, in accordance with clause 5 of this Policy; or

3.3. act in accordance with clause 6 of this Policy.

4. If the User has refused to provide the requested information and/or documents through the official communication channel, the Service may temporarily hold the Transaction while conducting an internal compliance review. Following the review, the Service must:

4.1. either return the Transaction within 30 business days from the moment the refusal was received, in accordance with clause 5 of this Policy; or

4.2. act in accordance with clause 6 of this Policy.

5. Transaction return procedure.

5.1. The Transaction will be returned exclusively to the original cryptocurrency address from which it was received.

5.2. The Transaction will be returned less the network fee required to send the return transaction.

6. Where required by applicable law, the Service may disclose information, documents, and other details related to the Order to law enforcement and/or other authorized authorities. In such cases, the Service may hold the Transaction until the interaction with such authorities is officially concluded and/or until holding the Transaction is no longer required under applicable law.

7. The Service is not liable for any losses, costs, damages, lost profits, or other negative consequences suffered by the User as a result of the Service lawfully holding a Transaction in cases provided for by this Policy and applicable law, including consequences caused by changes in the market value of digital assets (exchange rate volatility).

8. Disclosure of Information to Government Authorities and Other Organizations.

8.1. Information and/or documents provided by the User, as well as other details related to the Order, may be disclosed to government authorities, law enforcement agencies, banks, payment systems, liquidity providers, and/or other authorized organizations in the following cases:

upon an official request from law enforcement and/or other competent authorities;
based on a court order or other legally binding act;
upon a request from banks, payment system administrators, liquidity providers, and/or regulatory or supervisory authorities within their powers;
at the Service's own initiative, when such disclosure is required to comply with applicable law, including AML/CFT obligations and/or regulatory requirements.

9. Changes and updates to the Policy.

9.1. The Service may amend and/or supplement this Policy. The current version of the Policy is published on the Service's website with the date of the last update.

9.2. Changes take effect upon publication, unless a different effective date is explicitly stated in the new version of the Policy.

9.3. Continued use of the Service after changes take effect means the User agrees to the updated Policy. If the User does not agree with the changes, they must stop using the Service.

10. In case of any discrepancies, inconsistencies, or differences in interpretation between versions of this Policy in different languages, the Ukrainian language version shall prevail.