1. General Provisions
1.1. This Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML/KYC Policy”) regulates the actions of the Btc-obmennik.info service to reduce the risk of using the service for the following purposes:
-money laundering;
-financing of terrorism;
-trafficking in narcotics and human trafficking;
-proliferation of weapons of mass destruction;
-corruption and bribery;
-other illegal operations.
1.2. Btc-obmennik.info implements a risk-based approach and implements internal AML/KYC procedures in accordance with generally accepted international standards and recommendations of relevant organizations, as well as taking into account methodological recommendations for assessing the Risk-Score of cryptocurrency sources.
1.3. This AML/KYC Policy applies to all users of the Btc-obmennik.info service (hereinafter referred to as the “User”) and to all transactions conducted through the Btc-obmennik.info website.
1.4. By using the Btc-obmennik.info service, the User confirms that they are familiar with this AML/KYC Policy and accept its terms.
2. Elements of the AML/KYC systеm
2.1. The AML/KYC systеm of the Btc-obmennik.info service includes, among other things, the following elements:
-customer identification and verification procedures (KYC);
-confirmation of the source of funds (SoF – Source of Funds);
-application of a risk-based approach and the Risk-Score model;
-use of external AML analysis of blockchain transactions;
-continuous monitoring of transactions;
-appointment of an official responsible for AML/KYC compliance;
-storage and accounting of documentation and transaction logs;
-interaction with competent authorities in cases provided for by law and applicable requirements.
2.2. The Btc-obmennik.info service has the right to updаte and improve its internal AML/KYC procedures without prior notice to the User, if necessary to enhance the effectiveness of the control systеm or comply with legal requirements and monitoring regulations.
3. User Identification and Verification (KYC)
3.1. In order to comply with AML/KYC requirements, Btc-obmennik.info may request reliable and independent documents and information from the User in order to establish the User’s identity and assess the risk level of transactions.
3.2. As part of the standard KYC procedure for individuals, Btc-obmennik.info may request the following documents and information:
-Identity document: passport (main page with photo and basic information) and/or national ID card and/or foreign passport;
-Selfie of the User holding the document (the User’s face and document information should be clearly visible);
-A piece of paper with a handwritten note (for example, “For Btc-obmennik.info, date …”), held in the frame along with the document and the User’s face;
-Residential address (at least: country, city, and street);
-Document confirming the residential address (if necessary): utility bill / bank statement / rental agreement / other document containing the User’s name and address;
-Contact information: a valid phone number and email address (e-mail).
3.3. Btc-obmennik.info may conduct additional identification and re-verification of the User, including in the following cases:
-Changes in previously provided data;
-Changes in the nature and volume of transactions;
-Identification of signs of increased risk based on Risk-Score or other monitoring;
-Reasonable suspicions of possible illegal activities.
3.4. Btc-obmennik.info takes reasonable measures to verify the authenticity of the submitted documents and information, including the use of external services and open sources, if necessary.
4. Risk Assessment Model (Risk-Score)
4.1. For cryptocurrency transactions, Btc-obmennik.info applies a risk assessment model for the source of funds based on the Risk-Score indicator, which is calculated based on external AML analysis of blockchain transactions.
4.2. Risk-Score is a conditional numerical indicator (typically ranging from 0 to 100), which reflects the degree of connection between an address or transaction and:
-darknet marketplaces;
-mixers and anonymizing services;
-exchanges and services with a low level of regulation;
-fraud schemes and well-known scam projects;
-services associated with compromised (stolen, hacked) assets;
-sanctioned entities;
-other high-risk categories.
4.3. As part of its risk-oriented approach, Btc-obmennik.info uses the following approximate gradation of risk levels based on the Risk-Score numerical indicator:
-Low risk: 0-24
-Moderate risk: 25-49
-Increased risk: 50-74
-High/critical risk: 75-100
4.4. When evaluating transactions, Btc-obmennik.info takes into account not only the overall Risk-Score, but also the risk structure by category (labels). “Dangerous labels” (high-risk categories) are of key importance, indicating, among other things, the connection of funds with darknet marketplaces, hacked/stolen assets, extortion, sanctioned entities, and other high-risk sources.
4.5. A transaction is considered high-risk and is subject to blocking with the launch of KYC/SoF procedures if: -dangerous labels are present in the transaction structure and/or addresses, regardless of the overall Risk-Score; and/or -the overall Risk-Score and a combination of other factors (label type and weight, customer profile, and nature of the transaction) indicate a high risk.
4.6. The Risk-Score threshold value of 70 is applied taking into account the structure of the labels:
– if the Risk-Score is ≥ 70 and there are dangerous labels, the operation is considered high-risk and is blocked until the KYC/SoF procedures are completed;
– if the Risk-Score is ≥ 70, but there are no dangerous labels and only medium-risk labels are present, the operation may be considered acceptable only after additional analysis of the risk structure and other circumstances;
– if the Risk-Score is < 70, but there are dangerous labels, the operation is also considered high-risk and is blocked until the verification is completed.
4.7. In all other cases, the operation can usually be completed as usual. However, Btc-obmennik.info retains the right to conduct additional verification and/or request supporting documents.
5. Use of external AML analysis (providers)
5.1. Btc-obmennik.info uses one or more specialized blockchain analytics services (hereinafter referred to as “AML analyzer”) to analyze the source of cryptocurrency and determine the Risk-Score.
5.2. Btc-obmennik.info uses different AML analytics providers (depending on the network/asset/verification task), including: Chainalysis OFAC Sanctions / CoinKYT / GetBlock / Match Systems / Shard / WamlApp / Merkle Science.
5.3. AML analyzers are used for:
– automatic analysis of addresses and transactions for links to high-risk categories;
– calculation of the Risk-Score for addresses and/or transactions;
– classification of risks by type (fraud, darknet, hacked funds, mixers, sanctions, etc.);
– generation of reports used for decision-making on operations.
5.4. The list of AML analyzers used may be changed by Btc-obmennik.info without prior notice to the User if it is necessary to improve the effectiveness of AML control.
6. Confirmation of the source of funds (SoF)
6.1. When the Risk-Score threshold is reached or exceeded, or when there are dangerous labels, or in other cases where it is necessary to comply with AML requirements, Btc-obmennik.info may request documents and information from the User that confirm the source of funds (SoF).
6.2. An approximate list of documents for SoF confirmation may inсlude:
-screenshots or statements from a cryptocurrency exchange with transaction history and balance display;
-bank statements confirming the receipt of funds used to purchase cryptocurrency;
-loans, purchase and sale agreements, and other contracts related to the receipt of funds;
-documents confirming wages/business income or other legal sources of income;
-tax returns and/or other documents confirming the legality of the source of funds;
-TxID and other data necessary for analyzing the chain of funds receipt;
-any other documents and information that Btc-obmennik.info deems necessary as part of the transaction assessment.
6.3. If the User refuses to provide SoF documents or if there are significant discrepancies/signs of forgery, Btc-obmennik.info may refuse to execute the transaction and/or continue to hold the funds until instructions are received from the competent authorities (if applicable).
7. Transaction monitoring and suspicious transactions
7.1. Btc-obmennik.info continuously monitors transactions, including but not limited to:
-analyzing the frequency, volume, and structure of transactions;
-identifying atypical patterns of behavior;
-monitoring signs of payment fragmentation and limit circumvention;
-checking transactions for high-risk levels according to Risk-Score and other AML analytics methods;
-considering sanctions lists and other high-risk lists (if necessary).
7.2. Based on the results of monitoring, Btc-obmennik.info may:
-suspend the execution of the transaction;
-request additional documents and information;
-restrict or block the User’s access to the service;
-take other actions within the framework of AML procedures.
8. Stages and deadlines for KYC/SoF verification
8.1. If a verification (KYC/SoF) is required, Btc-obmennik.info generally follows the following steps:
-Automatic transaction analysis: checking the TxID/addresses through AML analyzers, determining the Risk-Score and labels.
-Request for documents: if there are risk triggers, Btc-obmennik.info sends a request for KYC and/or SoF documents.
-Manual verification and decision: analyzing the documents and comparing them with AML analytics data; the final decision is to proceed with the transaction, request additional information, reject it, or refund it (if applicable).
8.2. The standard time for manual verification of documents and transactions is up to 24 hours from the moment the full set of requested documents and information is received.
8.3. In some cases, the verification time may be extended (due to the large volume of documents, additional requests, external checks, etc.). If possible, the User is informed about the delay through available communication channels.
9. Terms and conditions for the return of funds (transparently)
9.1. In cases where, based on the results of the Btc-obmennik.info verification, it is decided not to perform the exchange operation, the funds may be returned to the User in compliance with the AML/KYC requirements and taking into account the technical and legal capabilities.
9.2. The standard return period is up to 48 hours from the moment:
– the decision to return is made;
– and (if necessary) the correct return details are received from the User.
9.3. For bona fide Users, for whom, based on the results of the KYC/SoF procedures, it is not established that the funds are associated with illegal activities and high-risk categories, only the relevant blockchain network fee (network fee) and/or objective payment infrastructure fees (if applicable) are deducted upon the return of funds.
9.4. For Users, for whom, based on the results of the completed KYC/SoF procedures, it is established that the funds are associated with illegal activities and/or high-risk categories (including according to AML analytics), the return (if there is no prohibition from the competent authorities) is carried out with the deduction of:
– a service fee of up to 5% of the return amount, but no more than 100 USD in equivalent, and
– the mandatory network fee of the relevant blockchain network (network fee).
9.5. In cases where the User refuses to undergo KYC/SoF, the documents are not provided within a reasonable timeframe, the documents contain signs of forgery/significant inconsistencies, or there are other signs of possible illegal activity, Btc-obmennik.info has the right to suspend the execution of the operation and/or the return until the verification is completed and/or until the instructions of the competent authorities are received (if applicable).
10. Ensuring the “purity” of incoming and outgoing transactions (the quality of assets for the client)
10.1. Btc-obmennik.info performs AML checks on incoming transactions (TxID/addresses) before the funds are credited and records the Risk-Score/labels in the control logs.
10.2. Btc-obmennik.info ensures the quality and legitimacy of the assets transferred to clients, regardless of the direction of the exchange, including the control of outgoing transactions to exclude the transfer of assets with a high level of risk to users.
10.3. As part of the control of outgoing transfers, Btc-obmennik.info applies:
-verification of the outgoing source/transaction through AML analyzers before sending to the client;
-a ban on the transfer of assets in the presence of dangerous labels (high-risk);
-an additional assessment of the Risk-Score of the outgoing operation and its structure.
10.4. Btc-obmennik.info may use:
-tagged (attributed) addresses identified in AML analyzers as belonging to the service;
-addresses of verified platforms/liquidity providers;
-unique (one-time) addresses for each application (if technically applicable in a specific network).
11. Pre-paid AML verification before exchange and user choice
11.1. Btc-obmennik.info provides the User with the opportunity to pre-pay AML verification of the address(es) in one or more valid AML analyzers according to the Risk-Score model.
11.2. The User is given a choice:
-To transfer the verification results to the Btc-obmennik.info operator for assessing the exchange risks before sending funds;or
-To consciously refuse the pre-verification, confirming the consent to take the risks on themselves (including the risk of suspending the operation and requesting KYC/SoF in case of identifying an increased risk).
12. Personal data: processing, storage, terms, protection
12.1. Btc-obmennik.info has the right to collect and process the User’s personal data for the purposes of AML/KYC, fraud prevention, fulfillment of obligations, and ensuring the security of the service.
12.2. The Btc-obmennik.info website publishes a separate Policy on the Personal Data Processing and Storage Policy (Privacy Policy), which discloses:
-the list of collected data (KYC/SoF materials, contact information, technical logs, and AML verification results);
-the purposes of processing;
-the procedure for transferring to third parties (if there are legal grounds/necessity);
-information protection measures;
-the terms of storage and the procedure for deleting/restricting access.
12.3. The period of storage of documents provided as part of KYC/SoF, operation logs, and the results of AML checks is, as a rule, at least 5 (five) years from the date of termination of the relationship with the User or completion of the relevant operation, unless otherwise required by applicable regulations.
12.4. Btc-obmennik.info applies organizational and technical protection measures, including:
-restricting access to data by authorized persons;
-role-based access;
-using multi-factor authentication (2FA) for access to administrative systems;
-encrypting data transmission channels (TLS) and other protection measures provided for by internal security regulations.
13. AML/KYC Officer
13.1. To coordinate and implement this AML/KYC Policy, Btc-obmennik.info appoints an official responsible for compliance with AML/KYC requirements (Compliance Officer / AML Officer).
13.2. The functions of this person inсlude:
-implementing and complying with AML/KYC procedures;
-organizing monitoring of operations and internal checks;
-managing cases and recording decisions;
-interacting with competent authorities on AML/KYC matters (if required);
-organizing training and informing staff on AML/KYC matters.
14. Final Provisions
14.1. This AML/KYC Policy is general in nature and does not provide an exhaustive description of all procedures and technical measures applied by Btc-obmennik.info. Internal regulations may contain additional requirements and procedures that are not subject to full public disclosure.
14.2. Btc-obmennik.info reserves the right to unilaterally modify and supplement this AML/KYC Policy, including in the target
