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Anti-Money Laundering Policy.
The E-Change Service warns users against attempts to use the Service to launder money obtained through criminal activity, finance terrorism, engage in any illegal activity, or to purchase prohibited goods and services.
Money laundering is the concealment of the illegal source of funds by converting them into funds or investments that appear legitimate.
General Provisions
To prevent illegal transactions, the Service establishes certain requirements for all Requests created by the User:
The sender and recipient of the Payment under the Request must be the same person. Transfers to third parties are prohibited using the Service.
All contact information entered by the User in the Request, as well as other personal information provided by the User to the Service, must be current and completely accurate.
The creation of Requests by the User using anonymous proxy servers or any other anonymous internet connections is prohibited.
This Anti-Money Laundering Policy (hereinafter referred to as the "AML Policy") describes the procedures and mechanisms used by the E-Change Service to combat money laundering. The E-Change Service adheres to the following rules:
Do not enter into business relationships with known criminals and/or terrorists;
Do not process transactions that are the result of known criminal and/or terrorist activity;
Do not facilitate any transactions related to known criminal and/or terrorist activity;
reserves the right to restrict or prohibit the use of all or part of the services for citizens of countries such as Afghanistan, Bosnia and Herzegovina, the United States, the Democratic People's Republic of Korea, the Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, the Lao People's Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, and Ukraine;
If, based on the results of the analysis carried out in one of the AML analyzers (Chainalysis, Crystal, AML bot), the risk of cryptocurrency assets is detected to be higher than 60%, or any of the following labels is received: DARK MARKET, DARK SERVICE, SCAM, STOLEN COINS, MIXING (MIXER), SEXTORTION, RANSOM, HACK, PHISHING, TERRORISM FINANCING, FRAUD, BLACKLIST, STILL UNDER INVESTIGATION, CYBERCRIME ORGANIZATION, NARCOTICS, CHILD ABUSE, HUMAN, TRAFFICKING, SANCTIONS, ILLEGAL SERVICE, GAMBLING and other high-risk assets, then the Client's transaction may be frozen for an indefinite period until full identity verification (KYC) is completed. The service does not support transactions from the following platforms: Garantex, Commex, WhiteBIT, Grinex, Bitpapa, NetEx24, Tornado Cash, Hydra, Blender.io, Lazarus Group, Genesis Market, ChipMixer, Shinbad.io, as well as any Iranian platforms and other platforms from prohibited/sanctioned countries.
To complete the KYC procedure, the following information is required:
- Selfie with your passport.
- Photo of your passport.
- Video confirmation of the transfer, including logging into your wallet account and opening the transaction on the blockchain.
- Information about the source of funds with supporting screenshots or documents.
Verification of the provided information takes up to 5 days from the date of submission. Refunds are processed within 30 days from the date the exchange service verifies the provided KYC information.
A network fee is charged for refunds. Return of assets is impossible if a request has been received from competent authorities or if the assets have been seized or blocked by other agencies of any jurisdiction (in this case, the blocked asset may be used as evidence).
The E-Change Service may also request a second document to identify the User: a bank statement or utility bill no older than three months, indicating the User's full name and actual place of residence. The Service also reserves the right to request photo or video verification of the client if there is suspicion of fraudulent information provided.
The E-Change Service verifies the authenticity of documents and information provided by Users and reserves the right to obtain additional information about Users identified as dangerous or suspicious.
If the User's identification information has changed or their activity appears suspicious, the E-Change Service reserves the right to request updated documents from the User, even if they have previously been verified.
AML Policy Compliance Officer
The AML Policy Compliance Officer is an E-Change employee whose responsibilities include ensuring compliance with the AML Policy, including:
Creating and updating internal policies and procedures for writing
Reviewing, providing, and storing all reports required by applicable laws and regulations;
monitoring transactions and analyzing any significant deviations from normal User activity;
regularly updating the risk assessment.
The AML Policy Compliance Officer has the right to cooperate with law enforcement agencies involved in the prevention of money laundering, terrorist financing, and other illegal activities.
Transaction Monitoring
Monitoring User transactions and analyzing the resulting data also serves as a risk assessment tool and helps detect suspicious transactions. If money laundering is suspected, the E-Change Service monitors all transactions and reserves the right to:
report suspicious transactions to the relevant law enforcement agencies;
request the User to provide any additional information and documents;
suspend or terminate the User's account;
suspend the exchange and freeze assets pending clarification;
return funds to the User by canceling the exchange procedure, in accordance with the user agreement.
The above list is not exhaustive. The AML Policy Compliance Officer monitors User transactions daily to determine whether they should be reported and treated as suspicious.
In accordance with international requirements, the E-Change Service applies a risk-based approach to combating money laundering and terrorist financing. This ensures that measures to prevent money laundering and terrorist financing are commensurate with the identified risks.