Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CTF), as well as KYC/SoF Procedures

International and local regulations require the implementation of effective internal procedures to prevent any illegal activity. The AnyExchange service strictly complies with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) legislation. Within the framework of this policy, we carry out automated and manual transaction checks, as well as mandatory KYC/SoF procedures in accordance with international standards.

The AML/CTF Policy and KYC/SoF procedures cover the following:

• Transaction and user risk assessment

• KYC/SoF verification procedures

Transaction and user risk assessment

In accordance with international requirements, we check transactions and users for risk using AML services.

To minimize the risks of clients receiving high-risk funds, we use the practice of unique one-time crypto addresses for each request, followed by consolidation of funds. To assess transaction and user risk, we use automated checks via the amlbot.com service. This service analyzes transaction data and provides a Risk Score, which serves as the basis for decisions on blocking or additional verification.

Each user has the opportunity to undergo a free preliminary AML check of their address via the amlbot.com analyzer. 

The formation of the Risk Score is based on data such as country, transaction type, user activity history, as well as the results of automated checks against AML databases.

Based on the report from amlbot.com, a Risk Score is formed, indicating the level of risk of a specific transaction or user. The threshold value for automatic blocking or suspension of a transaction is 50%, as well as if the risk exceeds 1.5% in the following categories:

• Dark Service — coins related to child abuse, terrorism financing, or drug trafficking;

• Dark Market — coins that were used for purchases on the darknet;

• Scam — coins that were obtained through deceiving clients;

• Mixer — coins that have passed through a mixer to make tracking difficult or impossible, often used for money laundering;

• Illegal Service — coins related to illegal activities;

• Ransom — coins obtained through extortion or blackmail;

• Exchange Fraudulent — coins from exchanges associated with fraud, illegal activities, or whose funds have been seized by the government;

• Stolen — stolen coins;

• Gambling — coins related to unlicensed online casinos.

If the Risk Score exceeds threshold values, the transaction is suspended or rejected, the relevant information is sent for further analysis, and the funds are returned to the wallet from which the payment was made. The refund is carried out after the client provides all requested data and documents confirming the legal origin of the funds. The refund fee consists only of the network fee, we do not charge any additional transaction fees.

Procedure steps when Risk Score thresholds are exceeded:

1. Receipt of payment.
After receiving payment from the client for a request, if the transaction raises suspicion or the Risk Score from amlbot.com exceeds 50%, or if the risk exceeds 1.5% in the categories listed above, the transaction is automatically suspended or blocked.

2. User notification.
We inform the client about the suspension of the transaction and request the necessary data and documents to be forwarded to the payment provider’s security service (see section KYC/SoF Verification Procedures). If the transaction does not raise suspicion and is not automatically blocked, the payment is processed without delays.

3. Processing of suspicious cases.
After receiving the requested data and documents, the security service conducts additional verification. If, based on the results of the check, the transaction should be unblocked, it is unfrozen and the client is notified. If the transaction requires a refund, we request the client’s details for returning the funds.

4. Refund of funds or execution of the request.
If the legal origin of the funds is confirmed, we return the amount to the client’s wallet or offer to complete the request at an updated rate if the payment has been credited.

If the transaction is immediately unfrozen or the payment is returned, we notify the client and request details for a refund or reprocessing of the payment.

When creating a request and making a payment, the client confirms that they have read and accepted the service terms, including the provisions on KYC and AML. We reserve the right to refuse payout or refund if the transaction was frozen or rejected due to a risk level of 50% or higher.
The client has the right to submit a complaint or request a review of the decision related to blocking or refusal via the service email or by contacting a manager directly. Requests are reviewed within 15 business days.

KYC/SoF Verification Procedures

KYC/SoF verification procedures at AnyExchange require the client to provide authentic documents (for example, passport, international passport, bank statement, etc.). For these purposes, AnyExchange reserves the right to collect user identification information within the AML/CTF policy and KYC/SoF procedures. Also, AnyExchange reserves the right to additionally verify certain users who raise suspicion.

To carry out KYC procedures and confirm the Source of Funds (SoF), the client must provide the following materials:

• Passport or international passport;

• Proof of receipt of funds for the transaction, including correspondence, receipts, contracts confirming payment and origin of funds;

• If necessary — additional documents upon request of the security service.

These materials allow verification of identity, source of funds, and legality of transactions.

The verification process takes up to 30 business days. In case of suspicious transactions or the need for additional verification, the transaction is suspended and the funds are returned to the wallet from which the payment was made. Refund of funds is possible only after the client provides all requested data and documents confirming the origin of funds and identity. 

Refund time — within 3-5 business days after completion of verification and receipt of all necessary documents.

We are committed to protecting the confidentiality and security of our clients’ personal data in accordance with GDPR and other applicable data protection laws.
Personal data provided during KYC procedures is used exclusively for identity verification, risk assessment, and compliance with legal requirements.
Data processing is carried out in accordance with the principles of minimization, confidentiality, and lawfulness. We do not transfer personal data to third parties without the client’s consent, except in cases предусмотренных законом, or for the purpose of complying with AML/KYC requirements.
Detailed personal data processing policy can be found via the link.

Personal data obtained within KYC and AML procedures is stored in our systеm for 3 years from the date of the client’s last activity or termination of the relationship. After this period, the data is destroyed in a standard way — by automatic deletion from databases or physical destruction in accordance with internal regulations and data protection laws.
Data processing is carried out in accordance with the principles of minimization, confidentiality, and lawfulness, in compliance with GDPR and international standards.