AML policy

Terminology and Definitions

1.1. In this program aimed at countering money laundering and financing of terrorism, the following terms will be used with the meanings indicated below, unless otherwise indicated by the text:

"Money laundering" - the conversion of illegally obtained funds or property into legitimate assets, by giving them a lawful ownership, use, or disposal.

"Service" - the website

"Agreement" - the User Agreement, the text of which can be found at ON THE AGREEMENT.

"User" - a natural person who has reached the age of majority and entered into an Agreement with the Service.

"Program" - this program in the field of countering money laundering and financing of terrorism.

"Public officials" - persons holding public positions, as well as persons serving in state civil service (including heads of states, governments, ministers, heads of departments, heads of central banks, judges of higher courts, prosecutors, ambassadors, heads of state corporations and funds, members of parliaments).

"Financing of terrorism" - the provision or collection of funds or the provision of financial services for the purpose of financing the organization, preparation, and commission of terrorist acts.

1.2. All other terms and definitions used in the text of the Program will be interpreted in accordance with the Agreement and the current legislation of Ukraine.

1.3. The headings (articles) of the Program are used solely for the convenience of using the text of the Program and do not have literal legal meaning.

Using the Program

2.1. All provisions of this program are mandatory for our service and users.

2.2. We provide services only to users who agree to our program.

Refusal of Cooperation

3.1. General Rule

3.1.1. The rules for using our service are very important to us in order to ensure the safety and legality of the actions of all our users. Therefore, we are not responsible to users if we have credible information that they plan to use our service for unlawful purposes. This includes, but is not limited to, using our service to legalize income obtained illegally and to finance terrorist activities.

3.2. Specific Cases We reserve the right to refuse to fulfill our obligations to users in the following cases:

3.2.1. If users are suspected or accused of terrorist or extremist activities, or have been convicted of such actions. In such cases, we cannot guarantee the safety and reliability of our services, and we cannot violate the laws and rules prescribed by the relevant legislative bodies.

3.2.2. If international or regional sanctions have been imposed against users. In such cases, we are obliged to follow the rules established by the competent authorities and cannot provide services that contradict them.

3.2.3. If measures are taken to freeze (block) users' funds and assets. In such cases, we cannot conduct financial transactions and provide services related to money transfers.

3.2.4. If users are public officials found guilty of violating human rights. In such cases, we cannot cooperate with individuals who violate the rights of others.

3.2.5. If users are citizens of states subject to international sanctions. In such cases, we cannot provide services that contradict international rules and sanctions.

3.2.6. If your transaction is identified as high-risk, the exchange office may suspend the exchange operation until a check is carried out in accordance with FATF recommendations (

3.3 If the client refuses to undergo verification, the funds must be returned or exchanged within seven calendar days from the moment the exchange point receives the transaction, provided that the exchange point has not received a notification from law enforcement or regulatory authorities containing instructions regarding the withheld funds.

3.4. Within two calendar days after verification, the funds must be returned or exchanged. A commission fee may be charged for the return, not exceeding the total cost of processing the request and organizing the return of funds. Our company strictly adheres to the legislative norms and rules established by the relevant competent authorities. Therefore, we reserve the right to refuse to fulfill our obligations in cases where our activities may contradict laws and regulations, as well as the principles of safety and reliability of our services.

Restrictions on conducting operations

4.1. If the Service has grounds to believe that the User is engaged in unlawful activities in accordance with paragraph 3.1.1 of the Program, the Service reserves the right to terminate any actions related to such User at any time.

4.2. A User who wishes to conduct an operation for an amount exceeding 100,000 (one hundred thousand) hryvnias must provide documents for the verification procedure in accordance with Article 5 of the Program. A User who conducts operations for an amount not exceeding 100,000 (one hundred thousand) hryvnias is not required to undergo identification procedures in accordance with the provisions of Article 5 of the Program. For such unidentified Users, the maximum total value of operations is set at 100,000 (one hundred thousand) hryvnias per month. If a User exceeds this maximum total value of operations, they must undergo identification procedures in accordance with the provisions of Article 5 of the Program.

4.3. The Service may block the conduct of operations until the User, identified by the Service in accordance with the provisions of Article 5 of the Program, provides additional documents to identify the beneficial owner or beneficiary owner, as well as until the reasons for conducting the operation and other circumstances are clarified (the Service establishes the necessary package of documents in each specific case). This rule applies if:

4.3.1. The User must provide additional documents if the amount of the operation is equal to or exceeds 400,000 (four hundred thousand) hryvnias.

4.3.2. The Service has the right to consider the operation conducted by the User as suspicious or unusual and request additional documents.

4.4. If the User did not provide the necessary documents or if the Service has doubts about the authenticity of the documents provided, the Service has the right not to conduct the operation or suspend its conduct until the necessary documents are provided.

4.5. The Service may require the User to provide documents, even if the operation is one-time and does not exceed 100,000 (one hundred thousand) hryvnias or the total amount of operations does not exceed 100,000 (one hundred thousand) hryvnias per month, if the Service has grounds to believe that the operation is suspicious or unusual. This also applies to cases where attempts are made to bypass the restrictions set forth in the Program, either by technical means or by collusion with other Users. However, this requirement is an exception to paragraph 4.2 of the Program.

User identification

5.1. To identify users, the service collects the following information: Full name Residential address (registration) Date and place of birth Identification documents credentials.

5.2. The user must provide a scanned copy or photo of their passport or other identification document, as well as a copy or photo of a document confirming their place of residence for identification purposes. The service may request additional documents required to comply with the program's requirements.

5.3. Foreign or Ukrainian public officials, their spouses, or minor children must disclose their user status before any operations with the service begin. If the service discovers that the user has hidden this information, the service has the right to terminate any actions in favor of such users.

Document Requirements:

6.1. All documents required to participate in the program according to sections 4.2-4.3 must be written in Ukrainian or Russian. If the documents are provided in another language, they must be notarized.

6.2. Scanned copies of documents must be submitted in high quality with a resolution of at least 300dpi.

Measures Taken by the Service:

To comply with section 2.1, the service takes the following measures:

7.1. Appoints a responsible employee who is responsible for compliance with the program, its updates, and compliance with international standards and Ukrainian legislative requirements.

7.2. Establishes criteria for identifying suspicious and unusual transactions, as well as methods for detecting them.

7.3. Analyzes the transactions conducted by users for compliance with the criteria for suspicious and unusual transactions.

7.4 Suspends financial operations in cases where the AML check of a transaction submitted by the client shows significant risk. The relevance of the threshold value of the risk level must be confirmed by regulatory recommendations at the time of the check.

7.5 Suspension of financial operations, as well as withholding of additional fees, must be justified by regulatory recommendations for each specific situation in the event that the exchange uses for checks or a service based on information provided by and considers a risk level of less than 70% to be significant.

7.6 Keeps records of transactions conducted by users and retains information about them for 5 (five) years.

7.7 Checks for the presence of individuals listed in section 3.2 of the program among the users at least once every three months.

Change of program conditions

8.1. The service reserves the right to unilaterally change the program, including implementing new requirements and restrictions.

8.2. Notification of a new version of the program will be posted on the service website The new version of the program comes into force within 3 (three) days from the moment of its posting at

8.3. Users are required to familiarize themselves with the new version of the program.

8.4. Continued use of the website will indicate the User's agreement to the terms of the new version of the program. 8.5. If the User does not agree to the terms, they are obliged to stop using the Site and System.