AML/CTF и KYC Policy

money laundering

AML

(anti-money laundering policy)

Date of entry into force: 01.11.2021.

Updated on May 27, 2022.

This AML Policy (hereinafter referred to as the Policy) regulates the activities of BTCCHANGE24 in relation to the fight against money laundering and its involvement in the fight against money laundering and the financing of terrorist activities.

Terms and Definitions

BTCCHANGE24 is a trademark of a system that provides Users with the ability to exchange digital and electronic currencies.

Service - a system for providing Internet services for the exchange, sale and purchase of digital and / or electronic currencies.

A user is any natural person using the services of the BTCCHANGE24 service.

Digital currency - Bitcoin, Litecoin, Ethereum and any other blockchain-based currencies.

Electronic currency - funds held on the accounts of users of electronic payment systems (Qiwi, Yandex Money, etc.).

Service Services - assistance in conducting peer-to-peer transactions between individuals for the purchase and sale and exchange of digital currencies, as well as other services, information about which is posted on the Service window.

Card verification is a verification that the card (or account) belongs to its owner. The conditions for verification of ownership are established by the Service and are carried out at a time for each new account (card) of the User.

Money laundering is the legalization of the possession, use or disposal of money or other property obtained as a result of a crime. BTCCHANGE24 strictly follows laws that prohibit us or any of our employees from knowingly engaging in or attempting to engage in any type of activity that is in any way related to money laundering. Our anti-money laundering policy is aimed at improving the security of customers and the services provided by the Service.

Financing of terrorism is the intentional provision or collection by any means, directly or indirectly, of funds with the intent to use those funds or on the condition that they be used to carry out terrorist acts.

2. Activities taken in compliance with the AML Policy

The administration of the BTCCHANGE24 service, realizing the public danger of crimes related to money laundering and terrorist financing, has developed a set of organizational and legal measures in order to comply with the provisions of national legislation, as well as the requirements of the intergovernmental organization FATF.

The European regulation of AML is based on a number of legislative directives. Namely, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which came into force on December 02, 2018.

Other legislative acts aimed at combating the legalization of proceeds from crime and the financing of terrorism are the following acts:

5th AML Directive ((EU) 2018/843);

Proceeds of Crime Act 2002;

Terrorism Acts 2000 and 2001;

Anti-Terrorism Act 2008;

Treasury sanctions notices;

Application of KYC (know your customer) policy. Mandatory identification of Users who are allowed to make transactions on our Service. To verify the User, the Administration has the right to require the following data to be provided:

take a photo (“selfie”) with a citizen’s identity document: a scanned copy of the front and back of an official photo ID, i.e. a valid passport, driver’s license or other national identity card;

proof of residence: an official document issued within the last 3 months, clearly indicating the name and address of the client provided during registration on the BTCCHANGE24 website. This could be a utility bill (for water, electricity, or a landline phone) or a bank statement. The copy must include: full name, full address of residence, date of issue (within the last 3 months), name of the issuing authority, with official logo or seal;

provide a copy of the front and back sides of the bank card and / or a photo of your bank card taken against the background of the main page of the Service (showcase with services). For privacy and security, only the last 4 digits of your credit card should be visible. It is allowed to hide 3 digits on the back of the card (CVV code).

The administration of the BTCCHANGE24 service will take steps to confirm the authenticity of documents and information provided by Users. Identification information will also be verified using secondary sources, and the Service Administration reserves the right to continue investigating cases in order to obtain full confidence in the authenticity of the documentation provided.

The administration of the BTCCHANGE24 service reserves the right to monitor the User's data on an ongoing basis, especially in cases where his identification

the information has been changed or his activity seemed suspicious (unusual for a particular User). In addition, the Administration reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.

Implementation of continuous monitoring of transactions passing through the Service. We exercise constant control over all applications created on the BTCCHANGE24 website. The administration of the service notifies the Users of the ban on the implementation of exchange transactions from third parties using their account.

Appointment of a responsible person (MLRO - Money Laundering Reporting Officer), exercising control and supervision powers for the implementation of the provisions of this Policy.

Application of a risk-based approach (RBA - Risk-Based Approach). We implement different levels of verification, depending on the volume and number of transactions performed by the User.

Improving the professional skills and knowledge of the BTCCHANGE24 team in terms of compliance with the requirements of the Policy.

Interaction with state authorities in cases established by law. In the event of a formal request from law enforcement or judicial authorities, we will be required to provide them with the requested information. Also, the Service Administration has the right to provide the data requested by official representatives of payment systems.

Improved security of the BTCCHANGE24 service software. We care about the reliability and security of your transactions. In this regard, we are constantly improving our IT department, whose main task is to protect the site from unauthorized access by intruders.

The administration of the BTCCHANGE24 service, in cases prescribed by law, may require a regulatory requirement to verify the source of fiat money and / or cryptocurrency in order to ensure that the sources of Funds that the Client uses for exchange are legal. As a document confirming the origin of the Funds, it can be a bank statement for fiat money or a video showing the details of a cryptocurrency wallet transaction.

In accordance with this Policy, the Service Administration will:

- monitor all transactions. The Administration reserves the right to ensure the transmission of reports about the suspicious nature of transactions to the appropriate law enforcement agencies through the Responsible Official;

— request from the User any additional information and documents in case of suspicious transactions, also at the request of the regulator (The regulator may be an exchange, a government agency or other organization that has the appropriate legal grounds.);

— suspend or terminate the User's account if there is a reasonable suspicion that such User is involved in illegal activities.

However, the above list is not exhaustive and the Responsible Officer will monitor User transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or should be treated as bona fide.

Country of residence. This Policy sets out our risk criteria for AML/CTF. To reduce this risk, the BTCCHANGE24 Service Administration does not accept customers who live in the following countries with an increased risk criterion:

Sources used for categorization:

Transparency International;

Know Your Country;

FATF High Risk Jurisdiction List;

List of high risk EU jurisdictions;

Countries where digital assets are prohibited or there are restrictions on trade;

Countries where digital assets are not prohibited;

Countries subject to UN Security Council sanctions.

All customers residing in the countries listed below are prohibited from serving on the BTCCHANGE24 service and cannot be accepted as Users.

Any customers from these countries will be denied service and any funds will be returned to the source.

Full list of prohibited jurisdictions:

USA

Afghanistan

Albania

Angola

Algeria

Bangladesh

Barbados

Bolivia

Botswana

Burma (Myanmar)

Burundi

Cambodia

Central African Republic

Chad

Congo

Conakry

Ivory Coast

Crimea, Ukraine)

Cuba

Democratic People's Republic of Korea (DPRK)

Ecuador

Egypt

Equatorial Guinea

Eritrea

Ghana

Guinea-Bissau

Haiti

Guyana

Iran

Iraq

Lao People's Democratic Republic

Lebanon

Libya

Mali

Morocco

Myanmar

Nepal

Nicaragua

North Macedonia

Pakistan

Panama

Qatar

Saudi Arabia

Somalia

South Sudan

Sudan

Syria

Tunisia

Uganda

Vanuatu

Venezuela

Yemen

Zimbabwe

Jamaica

The administration of the BTCCHANGE24 service also does not accept clients from disputed territories, as they do not provide generally recognized official documents, including:

Donetsk People's Republic (DPR) / Lugansk People's Republic (LPR)

Pridnestrovian Moldavian Republic

Nagorno-Karabakh Republic

Republic of Abkhazia

Republic of Somaliland

Republic of South Ossetia

Turkish Republic of Northern Cyprus

Republic of China (Taiwan)

Passports issued by the Russian Federation in Crimea and passports issued to residents of the Donetsk and Lugansk regions of Ukraine are not subject to verification

Republic of Kosovo

Saharan Arab Democratic Republic

Republic of Artsakh

KYT Policy

(Know Your Transaction)

Date of entry into force: 01.11.2021.

Updated on May 27, 2022.

The KYT (Know Your Transaction) policy aims to identify the client of a transaction in the event of a use case where the Service has reasonable suspicion that the Client is using BTCCHANGE24 inappropriately.

Such a precedent may arise if the Service suspects the Client of illegal actions that can be qualified as laundering or attempted laundering of illegally obtained digital assets or the funds are of overtly criminal origin. For these purposes, the Service has the right to use any legal information, third-party tools for analyzing the origin of digital assets, as well as its own developments of the screening system.

In this case, the BTCCHANGE24 Service reserves the full right to:

Require the Client to provide additional information disclosing the origin of digital assets and / or confirmation that these assets were not obtained by criminal means;

Block the account and any operations related to the Client, transfer to the financial control and/or law enforcement agencies at the place of registration of the Service and, if necessary, at the address of the Client's registration, all information and documents available on the incident;

Require from the Client documents confirming the identity, physical existence, address of registration, solvency;

Return digital assets only to the details from which the transfer was made or switch to other details, after a full check by the Service's security service, if it was possible to verify the legal origin of the Client's funds;

Refuse the Client to withdraw funds to the account of third parties without explanation;

Hold the Client's funds until the incident is fully investigated;

The service reserves the right to monitor the entire chain of transactions in order to identify suspicious transactions;

The Service reserves the right to refuse to provide the Service to the Client if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and to withhold funds on special accounts of the Service;

The Service reserves the right to refuse to provide the Service to the Client if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and to hold funds on special accounts of the Service if it is impossible to track the entire chain of movement of digital assets from the moment they appear.

Conditions for making a refund of funds stopped for verification based on the results of the AML analysis of the transaction:

Refunds are made after a full check by the Service's security service, which may include detailed verification of the sender. Refunds are made minus a commission of up to 5% of the transaction amount to cover the labor costs for processing the application and arranging a refund.

The return, subject to approval by the Service, will be processed by the Service within 7 (seven) calendar days, starting from the date when the User was notified with the decision of the Service regarding his return request.

When making a refund, after passing the check (verification), the user must confirm the details to receive a refund