AML/KYC Policy

The Service applies an automated risk assessment system (Risk-Score) to analyze incoming transactions in order to prevent operations potentially associated with violations of Anti-Money Laundering (AML) requirements.

The Risk-Score is formed based on data obtained from payment providers, third-party analytical systems, as well as internal algorithms for assessing transactional activity.

How the Risk-Score is formed

Each transaction undergoes an automated review, during which the following factors are taken into account:

• the presence of risk tags (risk-tags) assigned to addresses or transactions;
• transaction history and connections with high-risk sources;
• behavioral characteristics of the transaction (frequency, volume, structure);
• data from external analytical services;
• other factors applied within the Service’s AML policy.

The final Risk-Score is expressed as a percentage from 0% to 100%.

Thresholds and Processing Procedure

Depending on the Risk-Score level, the following scenarios apply:

• 0% – 49% (low risk):
  the transaction is processed in a standard manner without additional checks.
  
• 50% – 79% (elevated risk):
  the transaction may be temporarily suspended for additional review.

  The user may be requested to provide additional information, including:

  • proof of source of funds;
  • identity verification documents;
  • proof of ownership of the address;
  • any other information required to complete the verification.
  
  
• 80% and above (high risk):
  the transaction may be suspended or rejected until the completion of verification.

  In such cases, execution of the transaction is possible only after successful completion of KYC (Know Your Customer) procedures or upon a decision based on the analysis.

High-Risk Tags (risk-tags)

The presence of certain categories of risk tags may result in suspension or rejection of a transaction regardless of the final Risk-Score.
Such categories include, but are not limited to:

• sanctioned addresses (Sanctions);
• addresses associated with fraudulent activity (Scam / Fraud);
• illegal services;
• financing of prohibited activities;
• darknet services;
• mixers and anonymization services;
• other high-risk categories in accordance with AML provider requirements.

Additional Verification (KYC)

In case of detection of elevated or high risk, the Service reserves the right to request completion of KYC (Know Your Customer) procedures.

The timeframe for providing the requested data is determined individually and communicated to the user via the transaction interface or by email.

Actions in Case of Inability to Complete Verification

If the user fails to provide the requested data or if the provided data is insufficient to complete the verification, the following outcomes shall apply:

1. 1. Refund to the sender
   processed within a reasonable timeframe (typically within 7–10 business days) with confirmation of the refund;
2. 2. Official escalation
   where applicable, information may be transferred to competent authorities in accordance with applicable laws.

Indefinite retention of funds without legal grounds and without formal escalation is not permitted.

Note

The Service reserves the right not to disclose detailed parameters and internal algorithms of the Risk-Score model in order to prevent circumvention of control mechanisms.

KYC verification may be requested in the following cases:

• detection of elevated or high risk (in accordance with the Risk-Score model);
• presence of suspicious transaction characteristics or risk tags (risk-tags);
• necessity to verify the source of funds;
• request from payment providers or partners.

Verification Procedure

The verification process includes the following steps:

• notifying the user of the need to undergo verification;
• requesting documents and information;
• submission of data by the user;
• verification of the provided data (automated and/or manual);
• decision-making regarding the transaction.

Timeframes

• initial verification — up to 24 hours;
• additional verification — up to 3 business days.

Verification Results

Based on the results of KYC, one of the following decisions is made:

• execution of the transaction;
• refund of funds to the sender (typically within 7–10 business days);
• official escalation to competent authorities where applicable.

Refusal to Complete KYC

In case of refusal to undergo verification or failure to provide the required data, the transaction cannot be executed, and one of the предусмотренных outcomes shall apply: refund of funds or official escalation.

Indefinite retention of funds is not permitted.

AML (Anti-Money Laundering) is a set of measures applied by the Service to identify and prevent transactions associated with an elevated level of risk.

AML procedures are implemented through the Risk-Score model and, where necessary, through KYC verification.

Application of AML

Within the framework of the AML policy, the Service:

• analyzes transactions and assigns a risk level;
• identifies suspicious transactions and risk tags (risk-tags);
• requests additional information through KYC procedures when necessary;
• makes decisions regarding the transaction in accordance with the assessed level of risk.

Results of AML Analysis

Based on the results of AML analysis, and in accordance with Sections 1 and 2, one of the following outcomes is applied:

• execution of the transaction;
• additional verification (KYC);
• refund of funds to the sender;
• official escalation to competent authorities.

The Service does not perform indefinite retention of funds. Each suspended or rejected transaction is resolved through one of the following actions:

1. 1. Refund to the sender — within a reasonable timeframe (typically 7–10 business days) with transaction confirmation (TXID).
   
   • The Service may deduct a processing fee of up to 5% of the refund amount, but not exceeding $100.
   • Refunds are available only to verified users who have successfully completed KYC through a third-party provider and for whom no substantiated links to money laundering or other illegal activities have been identified.
   
   
2. 2. Official escalation — transfer of information to competent authorities or a third-party KYC/AML provider where applicable; refunds may only be processed after a decision is made by such authority or provider.

Grounds for Refund or Escalation

• refusal to undergo KYC verification through a third-party provider;
• failure to provide the required data to a third-party provider within the установленный timeframe;
• high risk identified through AML/Risk-Score by third-party systems;
• other cases where execution of the transaction is not possible.

Principle Only one outcome shall apply in each case: возврат или эскалация Indefinite retention of funds is not permitted.

If a transaction is assigned a High Risk status and falls into categories that do not indicate confirmed illegal activity:

• an internal analysis is conducted;
• if no connection to high-risk entities is confirmed, the transaction is not executed, and the funds are refunded only to the original sender’s payment details;
• KYC is not required for processing the refund;
• the refund is processed within 7–10 business days, taking into account applicable network or payment infrastructure fees;
• this procedure applies only in the absence of intentional attempts to bypass compliance procedures or other circumstances requiring enhanced due diligence.