AML Policy

Section 1: Introduction

1.1 Purpose of the Policy

The purpose of this Policy is to develop and implement effective measures aimed at preventing money laundering (AML), terrorist financing (CTF), and other illegal activities related to the use of digital assets. The Policy is intended to ensure compliance with legislation and international standards in the field of AML and KYC.

The main objectives of this Policy are:

• Compliance with legislative and international standards for combating money laundering and terrorist financing;
• Protecting the company's reputation by implementing transparent and effective customer verification and transaction monitoring procedures;
• Minimizing financial and legal risks associated with potential sanctions and fines;
• Ensuring the security and confidentiality of client data, which is especially important when working with digital assets;
• Preventing illegal cryptocurrency operations that may be used for money laundering or terrorist financing.

Thus, this Policy serves not only as a tool for legal compliance, but also as a basis for protecting the company from involvement in illegal activities and for creating a trustworthy and secure environment for our clients.

1.2 Legislative and Regulatory Requirements

The company's AML/KYC Policy is based on compliance with international and national legal norms and standards aimed at preventing money laundering, terrorist financing, and protecting customer data.

The company is required to comply with the following main legislative and regulatory requirements:

1. International standards:
   • Recommendations of the Financial Action Task Force (FATF), which serve as a foundation for creating effective measures to combat money laundering and terrorist financing at the international level;
   • Principles and standards established by the Basel Committee on Banking Supervision, which regulate financial activities and risk management;
   • European Union recommendations on combating money laundering and terrorist financing.
2. National laws and regulations: The Policy is aimed at compliance with national legislation governing issues of money laundering, terrorist financing, and personal data protection. The company must follow all applicable regulations related to digital asset operations.
3. Industry standards and best practices: These include obligations for customer verification, transaction monitoring, data protection, and fraud prevention. These practices align with international AML and KYC standards.
4. Regulation of exchange services and financial institutions: The company complies with all requirements applicable to exchange platforms and financial institutions operating in the digital asset sphere, including internal controls and reporting obligations.

This approach ensures regulatory compliance and aims to create a safe, transparent, and lawful business environment for our clients.

1.3 Company Responsibilities Regarding AML, CTF, and KYC

As part of its operations, the service commits to comply with international standards and national requirements in the field of:

• AML (Anti-Money Laundering) — counteracting the laundering of proceeds from criminal activities;
• CTF (Combating the Financing of Terrorism) — preventing terrorist financing;
• KYC (Know Your Customer) — identifying and verifying users’ identities.

The company must take all necessary measures to comply with these standards and prevent the use of the service for purposes that contradict the law or financial security norms. Specifically, the company is obliged to:

• Develop and implement internal procedures: The company must develop and implement internal procedures that comply with AML, CTF, and KYC requirements, aimed at preventing illegal use of the service. These procedures must be regularly updated in line with changes in legislation and practice.
• Customer identification and verification (KYC): All clients must undergo thorough identification and verification before starting cooperation. The company must collect and verify client personal data, as well as check documents using available technologies and services to confirm authenticity.
• Customer screening against sanction lists and other checks (AML, CTF): The company must regularly check clients against international sanctions and risk-related lists. If potentially risky clients are identified, the company must take appropriate measures.
• Risk assessment and decision-making based on a risk-based approach: The company must use a risk-based approach to assess each client’s risk based on their profile, location, activity type, and transaction volume. Depending on the risk level, the company must apply additional verification and monitoring measures.
• Transaction monitoring and detection of suspicious activity: The company must continuously monitor all transactions processed through the service to detect suspicious operations that may indicate money laundering or terrorist financing.
• Data retention and reporting: The company must ensure the security of all customer-related data and operations in accordance with legal requirements. All suspicious transactions and client activities must be documented and ready for submission upon request from regulators.
• Staff training: All employees working with clients or operations must undergo regular AML, CTF, and KYC training to maintain high awareness of potential risks and prevention methods.
• Cooperation with government authorities: The company must cooperate with government and regulatory bodies, provide them with necessary information on suspicious activity, and assist in investigations related to money laundering or terrorist financing.
• Internal audit and system evaluation responsibilities: The company must regularly conduct internal audits to evaluate the effectiveness of AML/KYC/CTF procedures and adapt them in a timely manner according to changing conditions and legal requirements.

Section 2: Principles and General Provisions

2.1 General Provisions

The company is firmly committed to the principles of Anti-Money Laundering (AML), Combating the Financing of Terrorism (CTF), and compliance with all Know Your Customer (KYC) requirements. We understand the importance of protecting our service from being used for illegal purposes and therefore commit to upholding high compliance standards.

The company guarantees that:

• All transactions conducted through the service comply with legal requirements and transparency principles;
• We adhere to a zero-tolerance policy towards any illegal activity related to money laundering, terrorist financing, and other criminal acts;
• We are obligated to minimize the risks associated with money laundering and terrorist financing, and take the necessary steps to effectively monitor customer activity, track transactions, and conduct appropriate checks;
• Responsibility for complying with this policy lies at every level of the organization, from management to employees involved in customer service and transactions;
• The 'Know Your Customer' principle is the foundation of all our procedures, allowing us to exercise proper due diligence with each client;
• We commit to regularly reviewing and updating our internal procedures to comply with legislative changes and adapt to new threats and risks.

The company fully understands its role in ensuring the security of financial transactions and is committed to integrity, transparency, and legality in all its operations.

2.2 Principles of Anti-Money Laundering and Counter-Terrorist Financing

The company builds its operations on the following principles to effectively combat money laundering and terrorist financing:

• Compliance with laws and international standards: We are obligated to follow all applicable laws and international standards, such as FATF recommendations, regulatory requirements, and global best practices in AML and CTF.
• Know Your Customer (KYC) principle: We ensure thorough identification and verification of all customers using KYC standards. Each client must provide accurate information that will be verified using available tools and technologies to prevent misuse of the service.
• Risk-based approach: We apply a risk-based approach when dealing with clients and their transactions. Depending on the risk level, the company may apply enhanced due diligence and monitoring measures.
• Prevention of service misuse: The company must prevent any attempts to use the service for money laundering or terrorist financing. We have implemented transaction monitoring, sanctions screening, and advanced technologies to detect suspicious activity.
• Transparency and reporting: We are obliged to maintain full transparency in our operations and promptly report any suspicious transactions or clients potentially involved in money laundering or terrorist financing. All such actions will be documented and passed to the relevant authorities for further investigation.
• Staff training: All employees involved in client interaction and transaction processing must regularly undergo AML and CTF training. This helps maintain awareness and competence, and improves effectiveness in combating illicit activities.
• Client data confidentiality: The company must ensure the protection and confidentiality of customer personal data in accordance with applicable laws. This includes robust security measures to prevent data leaks and ensure compliance with data protection regulations.
• Request for additional verification data: If necessary, the company may request additional client data or documents to verify the purpose and legality of the transaction. This may include:
  • What the received funds were to be exchanged for (currency and amount);
  • Payout wallet address (if paid in cryptocurrency);
  • Bank, card number, currency, and amount (if fiat payout was planned);
  • Client’s email;
  • Client’s IP address;
  • Additional information from the request (client’s phone number, messenger/social network contact, full name, and other details).

These measures are designed to ensure transaction transparency and prevent the service from being used for illegal or suspicious activities.

2.3 Definition of Terms

Within this policy, it is essential to clearly define the key terms used in implementing AML/KYC procedures. These definitions ensure that all parties (company staff, clients, and partners) understand the meanings and concepts used. It is important that these definitions are accurate and aligned with international practices and standards. Each of the following terms plays a crucial role in ensuring regulatory compliance and in creating an effective system for protection against financial crimes.

2.3.1 AML (Anti-Money Laundering)

AML (Anti-Money Laundering) is an international term that encompasses various measures and procedures aimed at preventing the laundering of illicit funds. Money laundering is the process of turning illegally obtained money into seemingly legitimate assets. These funds may come from drug trafficking, corruption, or other crimes. Under AML, companies are required to implement internal procedures for monitoring operations, identifying clients (via KYC), and blocking suspicious transactions. The goal is to prevent financial services from being used for criminal purposes.

2.3.2 CTF (Combating the Financing of Terrorism)

CTF (Combating the Financing of Terrorism) is a set of procedures aimed at identifying and blocking financial flows that could be used to support terrorist activities. It is crucial that financial services do not facilitate transfers to terrorist organizations. CTF includes client identification, transaction monitoring, and screening for links to terrorist groups. This involves sanction list checks and source-of-funds analysis. The main goal is to prevent terrorism financing through the financial system.

2.3.3 KYC (Know Your Customer)

KYC (Know Your Customer) is the process through which a company verifies and identifies its client base. The primary objective is to ensure the company knows who its clients are and understands the purpose and nature of their financial operations. This involves collecting personal data (name, date of birth, address) and verifying it through various sources (e.g., passport or other official documents). KYC helps prevent working with clients involved in money laundering or terrorism financing and fosters trust between the company and its clients.

2.3.4 KYT (Know Your Transaction)

KYT (Know Your Transaction) is the process of monitoring and analyzing transactions to detect suspicious or abnormal financial activities. KYT focuses on the transactions themselves rather than just the clients, enabling early detection of financial crime indicators. It helps spot unusual patterns, such as large transfers within short time frames or attempts to bypass limits. Transaction monitoring is a key part of a comprehensive AML/CTF system.

These definitions form the foundation for developing and implementing AML/KYC procedures and must be understood by all participants. Clear understanding minimizes the risk of illegal activity and ensures compliance with regulations.

Section 3: Client Identification and Verification (KYC)

3.1 Client Identification Procedures

The company undertakes to carry out client identification and verification procedures in accordance with the requirements of Ukrainian legislation, international AML/CTF standards, and FATF recommendations. The purpose of KYC procedures is to properly establish client identity, assess risk level, and prevent the use of the platform for illegal activities. All clients using the digital asset exchange service must undergo mandatory identification before starting operations.

Client identification procedures are carried out prior to granting access to platform services and include the collection, verification, and validation of personal data based on official documents. The client provides an identity document, proof of residence (if required), and undergoes biometric or video identification using automated tools. Verification is performed using specialized KYC services that check document authenticity, data consistency, and—if needed—presence in sanctions or risk lists. Re-identification is conducted when client data changes, the risk level increases, or upon request from regulatory authorities. All received data is stored in encrypted form and is accessible only to authorized personnel under internal security procedures.

3.1.1 Documents Required for Verification

• For Ukrainian residents:
  • Ukrainian passport (old-style book or ID card), or valid driver’s license;
  • International passport;
  • Tax Identification Number (TIN);
  • Proof of residence (e.g., utility bill, bank statement — not older than 3 months).
• For foreign nationals:
  • Passport or other identity document;
  • Residence permit or other documents authorizing stay in Ukraine;
  • Proof of residential address.
• Additionally:
  • Selfie with document or video identification to verify identity match;
  • In certain cases — information on the origin of funds (upon request).

3.1.2 Video Recording and Re-verification

To improve identification reliability and eliminate fraud, the company uses video recording during verification. This is done using automated tools or manually by the compliance team. The client must record a video showing their face and the original identity document according to system instructions.

Re-verification is conducted in the following cases:

• If discrepancies or doubts regarding data authenticity are identified;
• If personal data changes;
• If the client is classified as high risk;
• At the request of regulators or during routine data reviews.

Video verification results are stored in encrypted form and are accessible only to authorized personnel for compliance control and auditing.

3.2 Sanctions List Screening

As part of the identification process, the company must screen all clients against international and national sanctions lists. Screening is performed automatically using specialized tools and may be manually reviewed by compliance officers in case of suspicious matches.

The main sources of sanctions data include:

• Lists approved by the National Security and Defense Council of Ukraine (NSDC);
• Sanctions lists from the UN, EU, OFAC (USA), HMT (UK), and other international bodies;
• Registers of individuals involved in terrorist financing, weapons proliferation, human trafficking, and other illegal activities.

If a match or reasonable suspicion of connection is found, the company:

• Suspends the registration process or blocks the account;
• Notifies relevant state authorities in accordance with Ukrainian law;
• Documents all actions and stores verification results.

The platform does not serve clients included in sanctions lists or those directly or indirectly associated with them.

3.3 Measures for Politically Exposed Persons (PEP)

The service applies enhanced identification and monitoring measures to Politically Exposed Persons (PEPs), their relatives, and individuals closely associated with them.

PEPs include:

• Officials of government, local authorities, law enforcement, and judicial bodies;
• Senior officials of foreign governments;
• Executives of international organizations and central banks.

When a client is identified as a PEP:

• The client must provide additional information about the origin of funds and income sources;
• An extended review for links to corruption or illegal activity is conducted;
• A decision on continued service is made by company management or the designated AML/CTF officer;

Classification as a PEP does not automatically result in service denial but requires a special approach and constant oversight.

3.4 Risk-Based Approach to Client Management

The service applies a Risk-Based Approach (RBA) to client identification and servicing, allowing resources to be focused on the most vulnerable areas and effectively preventing platform misuse.

Within this approach:

• Each client is assigned a risk level (low, medium, high) based on criteria: country of residence, document type, transaction nature and volume, PEP status, transaction history;
• Clients with high risk levels are subject to enhanced verification and ongoing transaction monitoring;
• Risk levels may be revised during the client relationship if their activity changes or new circumstances arise.

Risk profiling is performed automatically using internal algorithms and adjusted manually by the compliance team when necessary.

Section 4: Monitoring and Analysis of Transactions (KYT)

4.1 Transaction Analysis Process

The service continuously monitors users' transactional activity to detect suspicious, atypical, or potentially illegal operations, including signs of money laundering and terrorist financing. All incoming and outgoing transactions are analyzed automatically using risk assessment algorithms and may also be manually reviewed by the compliance team. The analysis covers transaction parameters such as volume, frequency, direction, user behavior, and the presumed source of assets.

Special attention is given to transactions that do not match the user's established transaction profile or show deviations from typical behavior. Transactions involving anonymizers (VPN, TOR), suspicious crypto addresses, or those exceeding threshold limits are subject to additional checks. If signs of suspicion are detected, the transaction may be temporarily suspended until the analysis is complete. If necessary, compliance officers request explanations, supporting documents, or proof of fund origin from the user.

All actions related to transaction analysis, including automatic alerts, staff decisions, and related correspondence, are recorded and stored in the information system for the period required by applicable law. The service ensures a high level of personal data protection and limits access to analytical information to authorized personnel only.

The applied transaction analysis approach is based on the Know Your Transaction (KYT) concept, which requires evaluating each operation for transparency, stated purpose, source of funds, and potential risks. KYT is an integral part of the anti-money laundering system and enables timely detection of suspicious activity in both crypto-fiat and crypto-crypto transactions.

4.2 Use of Blockchain Analytics for Risk Assessment

The service uses blockchain analytics technologies to assess risks associated with the origin of digital assets and to detect potentially illegal or suspicious activity. The analysis is performed using specialized software that allows tracking the history of crypto movements, identifying links to addresses involved in illegal operations, and evaluating the risk level of crypto wallets.

Special attention is given to identifying signs of potential links to darknet markets, fraud, money laundering, terrorist financing, crypto mixers (tumblers/mixers), anonymization services, and sanctioned addresses. The analysis covers both crypto-fiat and crypto-crypto transactions, including cases where both parties are outside of Ukraine's jurisdiction but the operation is processed through the service.

The analytics used allows classifying transactions and addresses by risk level (low, medium, high) and identifying suspicious behavioral patterns. If a high level of risk is detected, the service may suspend the transaction, request additional information from the user, or refuse to process it.

The data obtained from blockchain analysis is used exclusively within the compliance control framework and internal risk management. This information may be shared with state or international regulatory authorities in cases provided by law or upon valid legal requests.

4.3 Issues with Anonymous Cryptocurrencies

The service recognizes the increased risks associated with the use of anonymous cryptocurrencies such as Monero (XMR), Zcash (ZEC), Dash, and other privacy-focused digital assets that hinder transaction traceability. These assets pose particular challenges for conducting proper source of funds checks (KYT) and may be used to conceal money laundering, evade sanctions, or finance illegal activities.

To manage risks, the service may limit or completely prohibit transactions involving anonymous cryptocurrencies. If such assets are allowed for exchange, enhanced verification measures apply to the user, including in-depth source of funds analysis, additional identity verification, and transaction behavior review.

The service reserves the right to reject a transaction or deny service if the use of anonymous assets prevents reliable verification of fund origin or if the transaction shows signs of potential illegal activity. Additionally, the service may report such cases to appropriate regulatory or law enforcement authorities in accordance with applicable laws.

4.4 Procedures for Freezing and Blocking Funds

The service reserves the right to block or freeze user funds in cases where transactions or client actions raise reasonable suspicion of illegal activity, legal violations, or non-compliance with the service’s compliance policy and internal risk management procedures. Blocking may apply to a specific transaction or all assets in the user's account.

Grounds for blocking may include:

• Matches with sanctions lists or high-risk individuals;
• Abnormal transactional activity inconsistent with the user’s profile;
• User's refusal to provide additional information upon compliance request;
• Signs of money laundering, terrorist financing, or other financial crimes.

In the event of blocking, the service notifies the user of the restriction, unless disclosure would interfere with an investigation or conflict with regulatory requirements. If necessary, the service cooperates with relevant authorities and provides all required documentation, including the rationale and timeline of the freeze.

Funds remain frozen until all circumstances are clarified, required documentation is provided, or the investigation is completed. Final decisions regarding the status of funds are made based on internal review results and, if applicable, in accordance with orders from competent authorities.

4.5 Response to Suspicious Transactions

The service responds promptly to any transactions that may show signs of suspicious or potentially illegal activity. A transaction is considered suspicious if it deviates from the user’s typical behavior, has an unusual structure, amount, or direction, or is associated with addresses or counterparties that raise concerns due to origin, location, or links to high-risk sectors.

When such a transaction is detected, the system automatically alerts the compliance team, which promptly analyzes it using available tools, including blockchain analytics and data from open and closed sources. The service may request additional information or documents from the user to confirm the legitimacy of the funds and transaction purpose. The transaction may be suspended until a response is received and analysis is completed.

If suspicion is confirmed, the service documents the event, takes appropriate actions according to internal procedures, and, if necessary, notifies the relevant authorities as required by law. The service follows a zero-tolerance policy regarding attempts to use its infrastructure for money laundering, terrorist financing, or other illegal activities.

Response to suspicious transactions is a vital part of the risk management system and is based on principles of integrity, legal certainty, and confidentiality.

4.5.1 Examples of Suspicious Transactions

To improve the efficiency of detecting and counteracting suspicious actions, the service uses a list of typical indicators that may signal high risk or potential legal violations. Below are examples of transactions considered suspicious and subject to additional compliance analysis:

• Transactions that significantly exceed the user’s usual volume without clear justification or prior activity;
• Frequent small transfers intended to bypass limits or automated checks (structuring);
• Use of previously unregistered wallets, addresses, or payment tools without explanation;
• Sudden change in transaction behavior, such as shifting from infrequent to intense transfers;
• Use of anonymization services such as TOR, VPN, proxy, or crypto mixers;
• Transfers related to addresses listed in sanctions, criminal, or darknet registries;
• Operations on behalf of third parties without transparent justification or clear link to the account holder;
• Attempts to avoid KYC/AML procedures, including refusal to provide documents or concealment of information;
• Transactions inconsistent with the stated purpose of using the service (e.g., private exchange involving business-scale amounts).

This list of suspicious indicators is not exhaustive and may be expanded based on experience, international guidelines, legal updates, and internal risk analysis. Each case is assessed individually based on context, user profile, and transaction nature.

4.5.2 Documentation and Reporting to Regulatory Authorities

The service carefully records all cases of suspicious transactions, service denials, fund blocks, and other risk management and AML/CTF compliance actions. All data is documented, including date, time, event description, actions taken by compliance staff, and supporting materials or correspondence.

Following the analysis of suspicious activity, the service prepares an internal report stored securely in accordance with legislation and information security standards. Only authorized staff or competent authorities with a formal request may access these materials.

If legally required or specified by internal policy, the service shares information about suspicious transactions with authorized national or international bodies overseeing anti-money laundering and counter-terrorism financing. Such transfers comply with all legal requirements, including deadlines, reporting formats, and data confidentiality.

Documentation related to suspicious operations and actions is retained for a legally established period sufficient to support investigations, inspections, or audits. The service ensures the ability to provide reports to regulators promptly and in the required format.

Section 5: Internal Control and Security

5.1 Internal Control Program

The company develops, implements, and maintains an effective internal control system to ensure compliance with anti-money laundering (AML), counter-terrorist financing (CTF), and Know Your Customer (KYC) standards. The internal control program is aimed at minimizing the risks associated with illegal financial operations and must comply with international legislation and national regulators.

The main elements of the internal control program include:

• Risk identification and analysis: Regular assessment of company-related risks involving clients, transactions, and high-risk countries, as well as identifying vulnerable points in operations;
• Monitoring compliance with AML/KYC/CTF procedures: Ensuring that all verification and transaction monitoring procedures are followed in accordance with current regulations, including automated systems for client data verification and transaction tracking;
• Appointment of a responsible person: Designation of an authorized employee or group responsible for implementing, monitoring, and updating AML/KYC/CTF compliance programs;
• Employee training and qualification improvement: A mandatory training program for all company staff involved in client service, operations, and security, in order to maintain a high level of awareness of risks and compliance rules;
• Regular internal audits and reviews: Conducting periodic checks and audits to assess the effectiveness of the internal control system, and timely updating processes in response to new threats and regulatory requirements.

5.2 Appointment of the Responsible Employee for AML/CTF Compliance

The company appoints a responsible employee who will be in charge of ensuring compliance with the Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) policies. This employee must have the necessary authority to implement and monitor all measures related to compliance with AML/KYC/CTF standards and act in the interest of financial operations security on the platform.

The main responsibilities of the responsible employee include:

• Monitoring compliance with legislation and internal procedures: The responsible employee ensures that all processes related to customer verification, transaction monitoring, and sanctions list screening meet current regulatory requirements and the company's internal standards;
• Updating and adapting policies: Regular review and updating of policies and procedures in line with changes in legislation, new threats and risks, and recommendations from international bodies;
• Training and mentoring: Conducting training programs for employees, raising awareness on AML/KYC/CTF topics, and ensuring correct application of standards at all levels;
• Interaction with external bodies: The responsible employee works with government and regulatory authorities, including financial monitoring bodies, providing necessary information upon request and coordinating actions in the event of investigations or audits;
• Monitoring system effectiveness: Evaluating the performance of the internal control system and monitoring compliance with AML/KYC/CTF policies, including reviewing automated systems and procedural actions.

The responsible employee must be independent of other operational processes to ensure impartiality and a high level of compliance. All actions related to their duties are documented to ensure transparency and traceability.

5.3 Employee Training

The company implements a mandatory employee training program on compliance with Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) policies. Training is conducted regularly and covers all key aspects necessary for effectively identifying and preventing potentially illegal or suspicious activity.

The training program includes:

• Introduction to regulatory requirements: Familiarization of employees with the basics of legislation, international standards, and internal procedures related to AML/CTF/KYC;
• Identification of suspicious activities: Training on recognizing signs of money laundering, use of anonymous services, evasion of controls, structuring of operations, and other forms of illegal behavior;
• Use of monitoring and analysis systems: Instruction on how to work with automated transaction analysis tools, customer verification, and maintaining internal documentation;
• Practical cases and scenarios: Studying real-life examples, including industry mistakes and methods for preventing them;
• Employee responsibilities: Understanding the role of each employee in the internal control system, the importance of following procedures, and the consequences of non-compliance.

Training is conducted upon hiring, and regularly thereafter—at least once a year or whenever significant procedural changes occur. Additional unscheduled training may be held in case of newly identified threats, legal updates, or internal policy changes.

All training records are documented and stored in the employee’s HR and compliance file as proof of their awareness and qualification in accordance with the current company security policy.

5.4 Client Data Protection and Cybersecurity

The company takes all necessary measures to ensure the security of clients' personal data and to protect information systems from unauthorized access, data loss, cyberattacks, and other threats. A comprehensive approach to cybersecurity is an integral part of the company’s compliance and internal control policy.

The main areas of protection include:

5.4.1 Information Security Policies

The company develops and implements internal regulations and policies for information security management, including:

• Access control to personal and critical data;
• Use of secure communication channels and encryption for data transmission and storage;
• Implementation of multi-factor authentication and regular software updates;
• Intrusion detection and prevention systems, as well as security event logging;

All data storage and processing systems comply with local and international personal data protection legislation.

5.4.2 Protection Against Unauthorized Access

The company implements technical and organizational measures to prevent unauthorized access to infrastructure, including:

• Role-based access control (RBAC);
• User activity monitoring and automatic alerting for suspicious behavior;
• Access control over third-party contractors and IT service providers;
• Incident response plan including immediate notification of authorized staff and suspension of operations in case of threats.

Client data protection is considered a priority in building trust in the service and ensuring compliance with AML/KYC/CTF requirements.

Section 6: Risk and access restriction

6.1 Risk Management in Client Relations

The service applies a risk-based approach when interacting with clients, aimed at identifying, assessing, and mitigating potential risks related to money laundering, terrorist financing, and other unlawful activities. This approach allows for differentiated levels of control and verification depending on the individual characteristics and activity of each client.

The main elements of risk management include:

• Client profile assessment: During registration and service usage, the platform analyzes the source of funds, geolocation, type of activity, transaction behavior, and other factors influencing the risk level;
• Client risk classification: All users are categorized (low, medium, high risk) based on a combination of factors. Depending on the assigned risk level, appropriate KYC, monitoring, and verification measures are applied;
• Additional measures for high-risk clients: If high-risk indicators are identified (e.g. PEP status, use of anonymization tools, origin from high-corruption countries), enhanced due diligence and increased monitoring are implemented;
• Dynamic reassessment: A client's risk level may be revised in case of changes in transaction behavior, updated information, emerging new risks, or at the initiative of the compliance team.

The risk management approach is constantly improved based on recommendations from international organizations, legislative changes, and accumulated practice.

6.2 Restrictions for Clients from High-Risk Countries

As part of implementing a risk-based approach, the service sets specific restrictions for users who are registered or operate in jurisdictions classified as high-risk.

High-risk countries and regions include:

• Jurisdictions included in the official high-risk lists of the FATF (Financial Action Task Force);
• Territories under international sanctions;
• Countries with systemic issues in combating money laundering and terrorist financing;
• Regions lacking proper regulation of the cryptocurrency sector or AML/CTF enforcement.

Restrictions may include:

• Ban on registering new accounts;
• Blocking certain operations or access to specific service features;
• Mandatory Enhanced Due Diligence (EDD);
• Service denial or account closure at the discretion of the compliance department.

The service reserves the right to apply stricter measures depending on the current geopolitical situation, updates to sanctions lists, reports from international organizations, and other external factors.

The list of high-risk countries is regularly updated based on analysis of data from FATF, the EU, the UN, OFAC, and other authoritative sources.

6.3 Prohibited Transactions and Activities

The service strictly prohibits transactions that may be associated with money laundering, terrorist financing, sanctions evasion, or other illegal activities. This includes both client actions and the use of third-party platforms located in high-risk zones.

In accordance with enhanced AML/CTF international standards and the internal compliance policy, the service imposes restrictions on transactions involving the sending or receiving of digital assets through certain resources deemed high-risk.

Transactions are prohibited if they involve the following platforms or organizations:

• Lazarus Group;
• Lazarus Group;
• Hydra;
• Garantex;
• Tornado Cash;
• Blender.io;
• Genesis Market;
• ChipMixer;
• Trocador.app;
• Shinbad.io;
• Anonexch.io;
• Bitpapa;
• Nobitex;
• Grinex.io;
• Rapira.net;
• CommEx;
• Capitalist.net;
• BitMart;
• Gate.io;
• BitMEX;
• MEXC;
• UniSwap.

Important: If a client conducts a transaction using any of the above-listed platforms, the operation may be immediately suspended, and the funds frozen indefinitely. The service may also request additional documents and explanations as part of enhanced due diligence.

The service reserves the right to:

• Update and expand the list of prohibited platforms without prior notice;
• Deny service to users who directly or indirectly interact with the listed resources;
• Report such actions to competent authorities in accordance with applicable law.

The current list of prohibited resources is available on the service's website and is updated regularly. Clients are required to monitor changes and comply with these restrictions when conducting transactions.

6.4 Fraud Prevention System

The company develops and implements a fraud prevention system aimed at minimizing risks associated with illegal activities and protecting clients' interests. This system must include several key elements:

1. Real-time transaction monitoring The system must ensure automated monitoring of all transactions processed through the service. Special attention is given to high-value transactions and those that may be associated with fraud or other illegal activities;
2. Use of algorithms to detect suspicious transactions To detect abnormal and suspicious transactions, the company applies modern algorithms and machine learning models that analyze user behavior, transaction frequency and amount, and other risk factors;
3. Check for possible fraud schemes Special attention is paid to operations associated with typical fraud schemes, such as phishing, scams, double payments, unauthorized transfers, and manipulation of cryptocurrency addresses.
4. Transaction suspension and blocking process If a transaction raises suspicion, the system automatically suspends it and notifies the compliance team for further analysis. If fraud is confirmed, the transaction may be blocked and funds frozen until all circumstances are clarified;

The company is obligated to continuously improve the fraud prevention system and update it in line with new threats and protection methods.

6.5 Suspension of Transactions with Suspicious Characteristics

The company is required to implement mechanisms for the immediate suspension of transactions that exhibit signs of suspicious or illegal activity. This includes operations potentially related to money laundering, terrorist financing, fraud, or violations of applicable laws.

The process of suspending transactions with suspicious characteristics includes the following steps:

1. Steps include:
   • High-value transfers without an apparent economic reason;
   • Operations associated with high-risk regions or countries;
   • Transactions using anonymous cryptocurrencies or services;
   • Mismatch between the source of funds and the client’s expected actions.
2. Compliance team notification When suspicious operations are detected, the system automatically notifies the responsible compliance staff for further analysis.
3. Transaction suspension All transactions classified as suspicious must be suspended until a final review is completed. This includes both incoming and outgoing transactions.
4. Documentation of all suspended transactions All suspended transactions must be properly recorded in the system, and information about them must be available for internal audit and external inspections.
5. Additional verification measures If necessary, the company may request additional documents or information from the client to clarify transaction details and identify possible signs of fraud or violations.
6. Periodic review and update of suspicious transaction criteria The company regularly reviews and updates suspicious activity criteria to reflect current threats and security standards.

If a client continues to perform high-risk or suspicious transactions, the company may decide to block their account.

Section 7: Legal Consequences

7.1 Liability for Violating the Policy

The company strictly adheres to all legal requirements and international standards in the fields of AML, CTF, and KYC. If violations of the policy by a client are detected, including providing false information, attempting to bypass identification procedures, or using the service for illegal purposes, the company may apply the following measures:

1. Blocking the client's account — in case of serious violations, the client’s account may be blocked to prevent further illegal actions;
2. Refusal to provide services — if the violation is significant, the company may refuse to provide further services to the client;
3. Documenting the violation — all cases of policy violation must be documented and made available for internal audits and possible inspections by regulatory authorities.

The company also reserves the right to report violations to law enforcement agencies if required for investigation.

7.2 Interaction with Government Authorities

The company is obligated to cooperate with government bodies, regulatory agencies, and law enforcement authorities in combating money laundering and terrorism financing. If there is suspicion of criminal activity or legal violations, the company must:

1. Provide information upon request from regulators — including on suspicious transactions, clients, or operations;
2. Assist in investigations — the company must provide necessary information and documents to investigate suspicious or illegal activities;
3. Ensure data is available for inspection — all company actions related to compliance with AML, CTF, and KYC requirements must be transparent to regulators.

7.3 Termination of Service and Account Blocking

The company reserves the right to terminate services for a client in the following cases:

1. Detection of legal or policy violations — if the client uses the service for illegal purposes, such as money laundering or terrorism financing;
2. Suspicion of fraud or deception — in case of providing false or incomplete information to bypass identification and verification procedures;
3. Violation of terms of use — if the client violates the agreement or transaction requirements.

In such cases, the client’s account may be blocked and transactions frozen until the investigation is completed.

7.4 Reporting and Data Transfer Obligations to Law Enforcement

The company must comply with all reporting requirements in accordance with local legislation and international standards. This includes:

1. Suspicious transaction reports — the company must submit reports on suspicious operations to law enforcement and regulatory bodies if such transactions indicate money laundering or terrorism financing;
2. Regular reporting on AML/CTF compliance — the company must regularly provide information on the fulfillment of AML, CTF, and KYC requirements if mandated by law.

The company is also required to promptly inform regulators about any changes that may affect compliance with laws in this area.

Section 8: Appendices and Additional Resources

8.1 References to Laws and Regulations

This section provides a list of all applicable international and national laws, regulations, and legal acts that govern the company's activities in the field of Anti-Money Laundering (AML), Combating the Financing of Terrorism (CTF), and Know Your Customer (KYC). All these documents are mandatory for compliance and ensure alignment with both international and local requirements.

Examples of regulatory documents that may be included in this section:

1. FATF (Financial Action Task Force) international standards — recommendations for countries on combating money laundering and terrorist financing;
2. European Union AML/CTF directives — regulatory acts governing anti-money laundering and terrorism policy for all EU member states;
3. U.S. Bank Secrecy Act — legislation regulating financial institutions in the United States;
4. Laws and regulations of local regulators — depending on the jurisdiction in which the service operates.

8.2 Sanctions Lists

This section lists the sanctions lists used by the company to screen its clients and their transactions. These lists can be national or international and are used to ensure compliance with anti-money laundering and counter-terrorist financing requirements.

Examples of sanctions lists:

• United Nations Sanctions List;
• EU and other international sanctions;
• U.S. OFAC Sanctions List — Office of Foreign Assets Control of the U.S. Treasury Department;
• UK HM Treasury Sanctions List;
• List of persons associated with terrorist financing and international criminal activity.

8.3 Templates and Document Submission Forms

The company may request that clients submit additional documents or information as part of the identification and verification process, and to fulfill AML, CTF, and KYC obligations. Requests will be sent in accordance with established procedures and legal requirements. All necessary forms and instructions for submitting documents will be provided to the client during the interaction process. The company guarantees that all submitted data will be used solely for the purposes of security and legal compliance.

8.4 Recommended Data Security and Protection Standards

The company is committed to adhering to strict security standards and protecting client data from unauthorized access, leaks, and other threats. This section outlines general security principles that may be applied internationally.

Examples of security measures:

• Data encryption in transit — protecting all client data using modern encryption algorithms;
• Security protocols for data storage — applying secure methods of data storage and leak prevention;
• Measures to prevent unauthorized access — implementing effective data protection systems;
• Recommendations for two-factor authentication (2FA) — additional protection for client accounts.