1.1. The Service monitors customer transactions (KYT — Know Your Transaction) to detect suspicious activity.

1.2. Verification may be initiated if there are reasonable suspicions of an illegal origin of funds, an attempt at money laundering, or misuse of the service.

1.3. For analysis, the Service uses third-party AML/KYT systems, its own algorithms, and other lawfully obtained information.

2.1. The Service applies a risk assessment model (Risk-Score) based on the analysis of the origin of digital assets.

2.2. Risk levels:

• Low Risk (0–40%) — the operation is processed in standard mode;
• Medium Risk (40–60%) — the operation may be additionally checked;
• High Risk (≥60%) — the operation is suspended and KYC/SoF is initiated;

2.3. At a risk level of ≥60%, the Service reserves the right to:

• suspend the operation;
• request KYC/SoF;
• restrict access until verification is completed;

2.4. When zero-tolerance risk categories are identified, the operation is blocked regardless of the overall Risk-Score.

2.5. The decision is made based on a combination of factors: Risk-Score, risk category, KYC results, and other data.

3.1. AML analyzers used: Rapira AML, CoinKyt, Shard, Bitok.

3.2. Zero Tolerance (0%)

• Child Exploitation — 0%
• Darknet Marketplace — 0%
• Darknet Service — 0%
• Enforcement Action — 0%
• Fraudulent Exchange — 0%
• Illegal Service — 0%
• Mixing Service — 0%
• Ransom — 0%
• Sanctions — 0%
• Scam — 0%
• Stolen Coins — 0%
• Terrorism Financing — 0%

3.3. Increased Risk (up to 50%)

• Gambling — up to 50%
• ATM — up to 50%
• Exchange Unlicensed — up to 50%
• P2P Exchange Unlicensed — up to 50%

3.4. Permitted Categories

• Liquidity Pools — up to 100%
• Exchange Licenced — up to 100%
• Miner — up to 100%
• Online Marketplace — up to 100%
• Online Wallet — up to 100%
• Other — up to 100%
• P2P Exchange Licenced — up to 100%
• Payment Processor — up to 100%
• Seized Assets — up to 100%

4.1. AML analyzers are used for analysis: Rapira AML, CoinKyt, Shard, Bitok.

4.2. The results are used to calculate the Risk-Score and make decisions.

5.1. The Service does not accept funds associated with high-risk sources.

5.2. It does not send funds to risky addresses.

5.3. If risk is detected, the operation is suspended.

5.4. Refunds are made to the original address.

6.1. KYC can be initiated in case of:

• Risk-Score ≥ 60%;
• suspicious activity;
• high-risk sources;
• regulatory requests;

6.2. The user provides:

• passport / ID / driver’s license;
• selfie or video with the document;
• proof of address;
• wallet details;
• proof of source of funds;

6.3. The list may be expanded depending on the risk.

1. AML analysis and Risk-Score calculation;
2. Suspension (if necessary);
3. User notification;
4. Provision of documents;
5. Data verification;
6. Decision making;

Timelines:

• submission of documents — up to 3 days;
• verification — 1–7 business days (up to 10 in complex cases);

• KYC request;
• suspension of operations;
• blocking;
• transfer of data to authorities;

9.1. Submission deadline — up to 3 days.

9.2. In case of refusal, the operation is canceled.

9.3. Possible outcomes:

• refund of funds;
• escalation;

10.1. Refunds are made to the original address.

10.2. Period — up to 7 days (up to 10 business days).

10.3. When refunding cryptocurrency, only the network fee is withheld.

10.4. When refunding fiat funds, a processing fee may be charged, but not more than 5% and not more than 100 USD.

10.5. No additional fees are charged.

11.1. Indefinite retention of funds is not permitted.

11.2. Possible outcomes:

• completion of the operation;
• refund;
• escalation;

12.1. Operations may be suspended in case of risks.

12.2. The term is limited by the verification time.

12.3. After verification — completion or refund.

13.1. The Service reserves the right to refuse service.

13.2. Use constitutes agreement.