1. Conducting AML check

1.1.

All incoming digital assets (title tokens / cryptocurrency funds) received by the Executor in the course of providing services are subject to mandatory AML verification using various blockchain transaction AML analyzers, including GetBlock, RapiraAML and manual transaction analysis, but not limited to them, and risk assessment (Risk Score models).

1.2.

Based on the results of such verification, the Executor assesses the transaction risk level, the source of funds, as well as the presence of direct or indirect links with high-risk categories and/or illegal activity.

1.3.

The results of the AML analysis are used by the Executor to make a decision:

1. to continue processing the application;
2. to suspend processing of the application;
3. to request additional information and documents;
4. to refuse processing of the application;
5. to return the received funds to the sender in the manner prescribed by these Rules.

2. Grounds for operation suspension and request for additional information

2.1.

The Executor has the right to suspend processing of an application and request additional information and/or documents from the Customer if:

1. the transaction Risk Score exceeds 50%;
2. the transaction has a direct or indirect connection with the following high-risk categories:

• Darknet Service
• Darkmarket
• Scam
• Stolen
• Mixer
• Exchange Fraudulent
• Illegal Service
• Ransom
• Gambling
• Sanctions
• Enforcement Action

2.2.

The Executor also has the right to request additional information in other cases if the operation, by its nature, structure, frequency, volume or other characteristics, appears suspicious, atypical or requiring additional verification within the internal compliance control system.

3. List of materials that may be requested from the Customer

3.1.

To pass additional verification and/or KYC/AML verification procedure, the Executor has the right to request from the Customer one or more of the following materials:

1. a photograph or scan of an identity document;
2. video selfie with passport / ID card in hands, where full name, document series and number, date of issue, and issuing authority are readable;
3. confirmation of ownership of the wallet / account from which the funds were sent;
4. unedited and uninterrupted video in which the Customer demonstrates:
   • access to the relevant wallet / account;
   • sender address;
   • transaction hash (if available);
   • date and time of the operation;
   • transfer amount;
   • recipient address;
5. screenshots from wallet / exchange / payment service confirming the sending of funds;
6. documents and information confirming the source of funds (Source of Funds / Source of Wealth), including but not limited to:
   • statements;
   • confirmation of purchase of digital assets;
   • transaction history;
   • income certificates;
   • contracts;
   • other documents reasonably confirming the legality of the source of funds;
7. explanation of the economic purpose of the operation;
8. other documents and information that the Executor reasonably deems necessary to complete the verification.

3.2.

All provided materials must be current, accurate, readable, without signs of editing, forgery, concealment of information or misleading.

4. Verification stages

4.1.

Verification is generally carried out in the following order:

1. automatic AML verification of the received transaction;
2. initial assessment of the result by an employee / authorized representative of the Executor;
3. if necessary — notification of the Customer about suspension of processing and request for additional information;
4. receipt and analysis of materials provided by the Customer;
5. making a final decision:
   • to continue the exchange;
   • to return funds;
   • to refuse service;
   • to transfer information to authorized bodies / fulfill other mandatory requirements, if required by applicable law or internal compliance control procedures.

5. Verification timeframes

5.1.

Initial AML verification is generally carried out automatically at the time of transaction receipt or within 24 hours of its detection by the system.

5.2.

If additional verification is required, the review period for Customer materials is usually 1 to 7 business days from the receipt of the complete set of requested data.

5.3.

In complex cases, including the need for additional analysis of the transaction chain, re-request of documents, verification of the source of funds, interaction with counterparties, analytics providers or authorized bodies, the verification period may be extended to 10 business days, and in case of objective necessity — for a longer period, of which the Customer is notified as far as possible.

5.4.

Verification periods are calculated from the moment the Customer provides a complete set of proper and readable materials. In case of incomplete provision of information, the verification period may be suspended.

6. Consequences of failing the check

6.1.

The Executor has the right to refuse to process the application if:

1. the Customer did not provide the requested information or documents;
2. the provided materials are incomplete, inaccurate, unreadable or raise reasonable doubts about their authenticity;
3. the Customer refused to undergo KYC/AML verification;
4. significant AML/CTF risks remain after verification;
5. there are grounds to believe that the operation is related to illegal activity, violation of sanctions regime or other prohibited sources of funds.

7. Refund conditions

7.1.

A refund may be made after verification based on the Customer's completion of the requested verification procedure and provided that:

1. the Executor was able to identify the sender of the funds;
2. the Executor has no legal prohibitions or restrictions on refund;
3. the refund does not contradict the requirements of applicable law, sanctions regime, requirements of competent authorities and internal policies of the Executor;
4. the Customer has provided sufficient evidence of ownership of the sender address or other refund address, if refund to the original address is technically impossible or unsafe.

7.2.

As a general rule, refunds are made to the sender address from which the funds were received.

7.3.

In exceptional cases, the Executor may agree to a refund to a different address if the Customer documents control over such address, and the refund itself does not contradict security requirements, AML procedures and internal rules of the Executor.

7.4.

The Executor has the right to deduct from the refund amount:

1. blockchain network fees;
2. fees of payment providers and third parties;
3. other actually incurred and documented expenses related to transaction processing and refund, if permitted by applicable service rules.

7.5.

Commission on refund of funds in AML cases

In case of refund of funds blocked / held / not admitted for exchange as a result of AML verification, the Executor has the right to deduct a commission for processing the refund and conducting compliance procedures in the amount of up to 5% of the refund amount, but not more than 100 US dollars equivalent.

7.6.

Commission limit for bona fide customers

If, based on the Customer's completion of the KYC / Source of Funds (SoF) / additional verification procedure, it is not established that the received funds are related to money laundering, terrorist financing, fraud or other illegal activity, the Executor's commission for refund cannot exceed the amount of the actual blockchain network commission and/or other mandatory technical costs for the refund.

7.7.

Procedure for determining the commission amount

The specific amount of the commission within the limits specified in clause 7.5 of these Rules is determined by the Executor taking into account the nature of the AML case, the scope of necessary verification measures, actually incurred expenses, as well as the presence or absence of confirmed high risk of illegal origin of funds.

8. Refund timeframes

8.1.

When a decision is made to refund funds, such refund is generally made within 1–5 business days from the date of the relevant decision and receipt of all necessary data for the refund.

8.2.

In individual cases, the refund period may be extended for reasons beyond the Executor's control, including:

1. technical features of the blockchain;
2. delays from custodial services, exchanges or payment providers;
3. need for additional verification;
4. fulfillment of legal requirements or requests from authorized bodies.

9. Independent preliminary verification

9.1.

Before performing an exchange operation, the Customer has the right to independently perform an AML verification of their wallet and/or transaction using independent blockchain analytics services.

9.2.

Such independent verification is for informational purposes only and does not guarantee a positive decision by the Executor on the application, since the Executor uses its own risk assessment criteria, internal compliance control procedures and data from the applied AML analyzer.