KYC & AML Policy
1. Purpose and Scope
This Know Your Customer (KYC) and Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT) Policy applies to all services provided by the Operators of the Platform (including affiliated entities and engaged providers acting on behalf of and/or in the interest of the Operators; collectively, the «Operators»). The Policy applies to all clients (natural persons and, where applicable, legal entities), transactions, and service channels.
2. Principles
- Risk-Based Approach (RBA). KYC/AML measures are proportionate to the risk profile of the client, transaction, jurisdiction, and products used.
- Ongoing Monitoring. Controls operate throughout the client lifecycle—from onboarding to continuous transaction monitoring.
- Transparency & Privacy. Personal data is processed in accordance with law and the Privacy Policy.
3. Identification and Verification (KYC)
3.1. Mandatory Identification
Services are available only after successful KYC. The Operators may decline service until verification is completed.
3.2. Documents (public list)
To complete identification, the Client provides:
- a passport issued by a governmental authority;
- a national identification card;
- a residence permit;
- a driver’s license;
- where necessary, proof of address (e.g., utility bill or bank statement issued no more than 6 months ago);
- up-to-date contact details.
As part of verification, the Operators conduct liveness checks and biometric face-matching against the document photo, as well as document authenticity checks. Additional information may be requested based on risk.
3.3. Enhanced Due Diligence (EDD) — public statement
The Operators conduct EDD as a separate procedure in higher-risk cases. EDD may involve additional information and evidence relevant to assessing the lawful origin of assets and the purpose of transactions.
A conservative approach: applies: where reasonable assurance is lacking, service may be refused and/or the relationship terminated .
4. Screening and Registry Checks
All clients and transactions are screened against all relevant and available sources, including (without limitation): sanctions lists and restrictive measures, politically exposed persons (PEP) and related parties, high-risk jurisdictions and export controls, adverse media, specialized commercial databases, and other registers required by law. Matches/risks trigger manual review and, where appropriate, refusal/blocking.
5. Transaction Monitoring
The Operators perform ongoing monitoring of activity, analyzing anomalies and risk patterns (including blockchain analytics signals for risky addresses, mixers, darknet services, etc.). Where suspicions arise, transactions may be paused/blocked, additional information requested, and, where required, competent authorities notified.
6. Travel Rule
For transfers of EUR 1,000 (equivalent) and above, the Operators collect and transmit originator/beneficiary information to the extent required by applicable law and the technical compatibility of virtual asset service providers involved. For self-hosted (non-custodial) addresses, proof of address/wallet control may be required.
7. Refusal, Suspension, and Freezing
The Operators may refuse or terminate service where KYC/AML requirements are not met or risk is elevated. Where justified (AML/sanctions concerns, authority/partner requests, source-of-funds checks, security/operational incidents), assets/operations may be frozen for up to 30 business days, extendable to 90 business days o complete review/investigation. Notifications are provided within a reasonable time unless prohibited by law or by an authority’s request.
8. Client Obligations
The Client must provide accurate and up-to-date data and documents, update them timely, follow the requirements shown in the order/process interface, and comply with the Exchange Rules, List of Prohibited Countries and Territories and Prohibited/Unsupported Services.
9. Data Sharing
On a lawful basis (including contract performance, AML control, fraud prevention, and security), KYC/AML data may be used by all Operators on a strictly need-to-know basis and shared with third parties strictly to the extent necessary, in accordance with the Privacy Policy.
10. Record-Keeping
KYC files, screening/monitoring results, and transaction records are retained for at least 6 years after the relationship ends, or longer if required by law/investigation. Appropriate technical and organizational security measures are applied.
11. Training and Internal Control (public statement)
The Operators provide regular training to staff on KYC/AML and sanctions compliance and conduct internal effectiveness controls over applied measures. Detailed procedures are set out in internal documentation.
12. Regulatory Interactions
The Operators fulfill statutory reporting obligations regarding suspicious activity and respond to competent authority requests in accordance with applicable law.
13. Policy Updates
This Policy is reviewed and updated as laws, regulatory practice, and risk profiles evolve. The current version is published on the website.