AML/KYC Policy

AML Policy (Anti-Money Laundering)

1. General Provisions

1.1. This AML Policy regulates the activities of the online exchange service in terms of combating money laundering and terrorist financing (AML/CFT).

1.2. The Service applies a Risk-Based Approach and undertakes to comply with applicable laws and international AML standards.

1.3. By using the Service, the User confirms acceptance of this Policy.

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2. AML Analysis and Risk Assessment

2.1. The Service uses built-in risk analysis tools of the cryptocurrency exchange Bybit to verify crypto assets.

2.2. The Risk Score is determined based on AML analytics applied by the exchange, including:

• analysis of the source of funds;

• screening for connections with high-risk addresses;

• detection of possible links to illegal activities.

2.3. Depending on the risk level, the following measures are applied:

• low risk — the transaction is processed without restrictions;

• medium risk — additional information may be requested;

• high risk — the transaction is suspended pending verification;

• critical risk — the transaction is blocked.

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3. Identity Verification (KYC)

3.1. The Service applies user identification procedures (KYC).

3.2. As part of the verification process, the following may be requested:

• full name;

• date of birth;

• residential address;

• photo/scan of an identity document;

• selfie with the document;

• proof of address;

• documents confirming the source of funds (SoF), including:

• wallet screenshots;

• transaction history;

• proof of income (if required).

3.3. The Service reserves the right to request additional information in case of increased risk.

3.4. The list and format of documents may be determined by Bybit requirements and their internal AML/KYC procedures.

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4. Verification Procedure

4.1. The verification process may include the following steps:

• automated AML transaction analysis;

• suspension of the transaction if risk is detected;

• request for documents (KYC/SoF);

• analysis of submitted data;

• decision-making.

4.2. Estimated verification timelines:

• initial review — up to 24 hours;

• enhanced review — up to 3 business days;

• in certain cases — up to 7 business days.

4.3. Timeframes may be extended if additional verification is required.

4.4. Verification is carried out in accordance with Bybit procedures and requirements.

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5. Transaction Monitoring

5.1. All transactions are subject to mandatory AML screening.

5.2. If suspicious activity is detected, the Service reserves the right to:

• suspend the transaction;

• request additional documents;

• refuse to process the transaction;

• report information to competent authorities.

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6. Refunds and Fees

6.1. In the event of a transaction being blocked for AML reasons, a refund is possible after verification is completed.

6.2. Refund fee:

• up to 5% of the amount,

• but not exceeding 100 USD (or equivalent).

6.3. For bona fide users whose funds are not confirmed as related to illegal activities:

• only the blockchain network fee is charged.

6.4. Refund timeframe:

• up to 3 business days after verification is completed.

6.5. If funds are subject to verification on the Bybit side, refund timelines may depend on the processing time of that platform.

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7. Processing and Protection of Personal Data

7.1. The Service ensures secure collection, processing, and storage of users’ personal data.

7.2. The following protection measures are applied:

• data encryption;

• restricted access;

• storage on secure servers.

7.3. Personal data is used exclusively for:

• AML/KYC procedures;

• compliance with legal requirements.

7.4. By using the Service, the User consents to the processing of personal data.

7.5. A separate document is published on the website:

“Personal Data Processing and Storage Policy.”

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8. Employee Training

8.1. Employees undergo regular AML/KYC training.

8.2. Training is aimed at identifying suspicious transactions and reducing risks.

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9. Confidentiality

9.1.Information about users and transactions is confidential.

9.2. Disclosure to third parties is permitted only in cases provided by applicable law.

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10. Final Provisions

10.1. The Service reserves the right to amend this Policy.

10.2. The current version is published on the website and becomes effective upon publication.