AML/CFT Policy — Safe and Legal Transactions
We prevent money laundering, terrorism financing, and sanctions evasion. All fiat operations undergo strict AML checks. All cryptocurrency deposits without exception undergo on-chain screening.
FATF Compliant
International standards compliance
100% Fiat Screening
All fiat transactions checked
100% Crypto Analysis
Every deposit analyzed on-chain
Table of Contents
Scope and Regulatory Framework
We comply with applicable AML/CFT and sanctions compliance requirements in our operating jurisdictions, guided by FATF recommendations. The policy covers clients (individuals/legal entities), counterparties, payment and exchange operations, including fiat payments and crypto assets.
Key sources: FATF recommendations, local AML legislation, sanctions regimes (e.g., OFAC/EU/UK), banking rules and industry standards.
AML/CFT Risks and Why It Matters
Money laundering, terrorism financing, corruption schemes, sanctions evasion, fraud, use of mixers/anonymizers, shadow markets — all undermine the financial system and carry legal risks. Strict checks protect our clients, partners and company, while ensuring sustainable service operation.
Our Risk-Based Approach
We apply a risk-based approach (RBA), adapting the depth of checks to the risk level of the client and transaction:
Customer Identification (KYC), PEP & Sanctions
KYC Requirements
Collection and verification of identification data, address, date of birth/registration, beneficial owners (for legal entities), source of funds/capital.
Sanctions Screening
Screening against international/local sanctions lists; matches → stop or EDD.
PEP Checks
Verification of politically exposed persons and their associates; matches require EDD and limits.
Adverse Media
Negative media and adverse media screening: accounting for reputation and enforcement risks.
Fiat Transaction Checks (Strict!)
Important
All fiat operations undergo strict AML checks. We may request additional documents and delay crediting until verification is complete.
All fiat transactions are subject to strict AML checks:
Bank SWIFT/SEPA Payments
Name/IBAN/purpose matching, source of funds verification, counterparty/correspondent bank analysis.
Card Operations
3-D Secure, risk pattern monitoring, return-to-source processing.
Risk Triggers
Fiat Transaction Flow
AML for Cryptocurrencies: 100% On-Chain Screening
Important
Every crypto deposit undergoes on-chain screening. High-risk funds may be delayed, sent for EDD, or returned (if technically possible).
Every crypto deposit undergoes blockchain analysis:
Blockchain Analytics
Address and path risk scoring, identifying connections to mixers, darknet markets, hacks, sanctioned addresses and high-risk exposure.
Addresses and Assets
We only accept supported networks/tokens; unknown/suspicious networks/bridges are blocked.
Risk Thresholds
When risk threshold is exceeded — delay/EDD/return (where possible).
Travel Rule & VASP
Information exchange between VASPs for transactions above regulatory thresholds (where applicable).
Crypto Deposit Flow
Monitoring, EDD, Freezing & Reporting
Continuous Monitoring
Ongoing transaction and behavior monitoring with automated risk detection systems.
Enhanced Due Diligence (EDD)
Additional documents/information: source of funds/capital, tax returns, contracts, statements.
Freezing/Blocking
Temporary blocking for legal reasons, sanctions matches, or suspicions until verification completion.
STR/SAR Reporting
Suspicious activity reports to competent authorities as required by law.
What We'll Need from You
Possible document/information requests:
Identity & Address Verification
Passport/ID, utility bills, bank statements for address confirmation.
Source of Funds/Capital
Employment contract, income certificate, tax declaration, period statements, asset sale documents, etc.
For Crypto
On-chain asset origin explanation (transaction history/screenshots), sender addresses (if via VASP — provider data).
Format & Quality
Color scans/photos of good quality, PDF/JPG/PNG; translation to Russian/English (notarized if required).
Timelines, Statuses, Delays & Rejections
Processing Statuses
Typical Timeframes
Common Delay Causes
Communication
We notify via Personal Account/email; for complex cases we recommend contacting compliance.
Privacy and Data Storage
Legal Basis
Fulfillment of AML/CFT legal obligations and legitimate interests (where applicable).
Retention Periods
KYC/AML documents and transaction records — for periods prescribed by law (usually 5-10 years after relationship termination).
Security
Encryption, access control on "minimum necessary" principle, audit trails.
Cross-border Transfer
When necessary — with legal safeguards (e.g., SCC/IDTA).
Country Restrictions and Sanctions
Important
We comply with sanctions regimes. Operations from/to prohibited jurisdictions and addresses are blocked.
Prohibited Jurisdictions
We do not serve residents/operations from countries/territories under full sanctions and from high-risk list (specified by company policy).
Contact compliance for current listSanctions Compliance
OFAC/EU/UK and local lists compliance: operations with matches are blocked or investigated.
Frequently Asked Questions
Compliance Contacts & Support
AML/CFT Questions
General Support
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This document is for informational purposes and does not constitute legal advice. Processes may change in accordance with legal and regulatory requirements. Service availability depends on jurisdiction and client status.
We reserve the right to request additional documents and information.