ANTI-MONEY LAUNDERING AND ILLEGAL OPERATIONS POLICY

Last updated: December 24, 2025

1. In accordance with international law and applicable regulatory standards, Service follows a set of rules and implements procedures aimed at preventing use of Service for money laundering, terrorist financing, sanctions evasion, and other unlawful activities.

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

1.1.1. Sender and recipient of Transaction under Order must be same person. Transfers to third parties using Service are strictly prohibited.

1.1.2. All contact details entered by User in Order, as well as any other personal data provided by User to Service, must be accurate, up to date, and complete.

1.1.3. It is strictly prohibited to create Order using anonymizing technologies and services, including (but not limited to) anonymous proxy servers, VPN services, hosting/VPS solutions, TOR, and any other anonymous Internet connections.

1.2. Service conducts AML screening of all cryptocurrency transactions received from User.

1.3. Service reserves right to suspend Order for User verification in accordance with applicable AML/CTF requirements and FATF recommendations in following cases:

1.3.1. If transaction is identified as high-risk by any specialized risk scoring/assessment service (including, but not limited to: Crystal Blockchain, AMLBot, CoinKit, GetBlock) and/or contains any of following labels: Sanctions, Terrorism, Darknet, Ransomware, Malware, Mixing, Cross-Chain Bridge, Decentralized Exchange, Child Abuse, Stolen Funds, Scam, Fraud, Gambling.

1.3.2. If transaction is identified as high-risk by wallet, exchange, or other liquidity provider used by Service to receive and/or process cryptocurrency transactions.

1.3.3. If transaction is associated with any of following platforms (including those that have ceased operations): Payeer, Capitalist, Yobit, Exmo, FunPay, Heleket, NixMoney, BTC-e, Garantex, Grinex, Rapira, WebMoney, BitPapa, Netex24, as well as any platform located in Iran or other sanctioned jurisdictions.

1.3.4. If transaction is associated with any anonymous cryptocurrencies, such as XMR (Monero), ZEC (Zcash), DASH, MWC (MimbleWimble Coin), or similar assets.

1.3.5. If unusual activity has been detected, such as deposit splitting.

1.3.6. If any of requirements set out in clause 1.1 (including its subclauses) are breached.

1.3.7. In other cases not covered by clauses above.

2. If Order is suspended for verification, User undertakes, upon Service request, to provide, in full, information and documents required for identity verification, as well as information on source of funds, both for specific Order and, where relevant, for previous Orders, including:

2.1. Photo/scan of one of following documents: passport, national ID card, or driver’s license.

2.2. Selfie holding document and handwritten note showing current date and User signature.

2.3. Information on what service or product User received funds for.

2.4. Information on platform through which User received funds. Where possible, provide screenshots of sender wallet/platform withdrawal history.

2.5. Through which contact person User communicated with sender of funds. If possible, provide screenshots of correspondence with sender where confirmation of sending funds can be seen.

2.6. Information on User employment status and sources of income.

3. If Order is suspended for verification, transaction cannot be refunded until User has completed actions specified in clause 2 and its subclauses (including providing requested information and documents for identity verification and source-of-funds confirmation).

4. Maximum period for reviewing information provided by User for verification is 30 days from date information is submitted (typically no more than 10 days).

5. Cooperation with government authorities, law enforcement agencies, banks, payment systems, and liquidity providers

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

• upon an official request from law enforcement agencies and/or other competent authorities;
• pursuant to a court order or other legally binding instrument;
• upon request of banks, payment system operators/administrators, liquidity providers, and/or regulatory (supervisory) authorities, within scope of their powers.

6. Changes and updates to KYC/AML Policy

6.1. Service may amend and/or supplement this KYC/AML Policy. Current version of KYC/AML Policy is published on Service website and indicates date of last update.

6.2. Any changes take effect upon publication, unless a different effective date is expressly stated in updated version of KYC/AML Policy.

6.3. Continued use of Service after changes take effect constitutes User acceptance of updated KYC/AML Policy. If User does not agree with changes, User must stop using Service.