Introduction
AnyExchange.Best Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of AnyExchange.Best being involved in any kind of illegal activity.

Both international and local regulations require AnyExchange.Best to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters:

Verification procedures.| Monitoring Transactions.| Risk Assessment.

1. Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, AnyExchange.Best establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification
AnyExchange.Best’s identity verification procedure requires the User to provide AnyExchange.Best with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes AnyExchange.Best reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

AnyExchange.Best will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and AnyExchange.Best reserves the right to investigate certain Users who have been determined to be risky or suspicious.

User verification process includes, but not limited to providing these documents proving his or her identity:

For natural persons:

To confirm the User’s identity the User should provide one of the following documents:

• A civil passport;
• An international passport;
• ID card.

To confirm the User’s residential address the User should provide one of the following documents:

• Bank statement where clearly seen the address of your actual residence;
• Utility bill where clearly seen the address of your actual residence;
• Taxation documents where clearly seen the address of your actual residence;
• A document confirming your residence issued by local authorities where clearly seen the address of your actual residence.

For corporate clients:

To confirm the User’s identity the User should provide one of the following documents:

• A civil passport of a director;
• An international passport of a director;
• ID card of a director;

To confirm the User’s address the User should provide one of the following documents:

• Bank statement where clearly seen the address of actual residence of a director;
• Utility bill where clearly seen the address of actual residence of a director;
• Taxation documents where clearly seen the address of actual residence of a director;
• A document confirming your residence issued by local authorities where clearly seen the address of actual residence of a director.

To confirm that the User is an authorized representative of an entity the User should provide all of the following documents:

• A document confirming a company’s residential address;
• А document of incorporation;
• An order on the appointment of the director;
• A scanned copy or a photo of a letter of a decision to work with AnyExchange.Best.

Ultimate beneficial owner information and Ultimate beneficial owner’s KYC documentations:

• A civil passport of an Ultimate beneficial owner;
• An international passport of an Ultimate beneficial owner;
• ID card of an Ultimate beneficial owner;
• Prove of residence document.

Ultimate beneficial owner means:

‘Ultimate beneficial owner’, according to Cyprus legislation, means the natural person or natural persons who ultimately own or control the User’s Account and/or the natural person on whose behalf a transactions or activity is being conducted. The beneficial owner shall at least inсlude:

1. in the case of corporate entities:

• the natural person or natural persons who ultimately owns or controls a legal entity through direct or indirect ownership or control over a sufficient percentage of the shares or voting rights in that legal entity, including through bearer share holdings, of a percentage of 10 % plus one share;
• the natural person or natural persons who otherwise exercise control over the management and direction of a legal entity.

2. in the case of legal entities, such as foundations and legal arrangements, such as trusts, which administer and distribute funds:

• where the future beneficiaries have already been determined, the natural person or natural persons who are the beneficiaries of 10 % or more of the property of a legal arrangement or entity;
• where the individuals that benefit from the legal arrangement or entity have yet to be determined, the class of persons in whose main interest the legal arrangement or entity is set up or operates, the natural person or natural persons who exercise control over 10 % or more of the property of a legal arrangement or entity.
  AnyExchange.Best reserves the right to verify User’s identity in an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, AnyExchange.Best reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the AnyExchange.Best Privacy Policy and related regulations.

Once the User’s identity has been verified, AnyExchange.Best is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

1.2. Card verification
The Users who are intended to use payment cards in connection with the AnyExchange.Best Services have to pass card verification in accordance with instructions available on AnyExchange.Best Site.

2. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, AnyExchange.Best relies on data analysis as a risk-assessment and suspicion detection tool. AnyExchange.Best performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

With regard to the AML/KYC Policy, AnyExchange.Best will monitor all transactions and it reserves the right to:

request the User to provide any additional information and documents in case of suspicious transactions;
suspend or terminate User’s Account when AnyExchange.Best has reasonable suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the transactions will be monitored on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

The User will not be able to create a Voucher using funds credited from online payment cards. The funds credited from online payment cards can be spent only on cryptocurrency or returned back to the same card.

3. Risk Assessment
AnyExchange.Best, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, AnyExchange.Best is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.