AML / KYC policy

1.1. This AML/KYC Policy governs the measures applied by the PureChange cryptocurrency exchange service (hereinafter referred to as the “Service” or the “Provider”) to prevent money laundering, terrorist financing, fraud, sanctions violations, and other unlawful activities.

1.2. By creating an Order or using the Service, the User confirms that they have read and agreed to this Policy, the Service Terms of Use, the Privacy Policy, and any other documents published on the Service’s website.

1.3. The Service applies a risk-based approach to the verification of Users and transactions. The scope of verification measures is determined by the nature of the transaction, the assets involved, the source and intended use of funds, geographic factors, automated-analysis results, and other circumstances affecting the level of risk.

1.4. The Service may conduct AML/KYC checks before, during, or after the creation of an Order, as well as before the execution, suspension, cancellation, or refund of funds under an Order.

1.5. The Service may refuse to provide services, suspend the processing of an Order, restrict access to certain functions, or request additional information and documents where a transaction or User presents an elevated risk, or where required by applicable law, the Service’s internal procedures, or the requirements of counterparties.

1.6. The Service does not provide advisory services regarding the preliminary assessment of the “cleanliness” of cryptocurrency, the likelihood of funds being blocked, the permissibility of a particular transaction, or the likelihood of passing an AML review. The User is solely responsible for the lawful origin and use of funds sent to the Service.

2.1. The Service may conduct automated and manual analysis of incoming and outgoing cryptocurrency transactions using its own tools, as well as the tools of liquidity providers, cryptocurrency exchanges, payment providers, blockchain analytics services, and other technology counterparties.

2.2. For AML analysis, the Service may use its own tools and the tools of liquidity providers, cryptocurrency exchanges, payment providers, blockchain analytics services, and other engaged technology counterparties. The Service may change the list of tools and providers used without prior notice to the User.

2.3. When assessing the level of risk, the Service may take into account information from blockchain analytics systems, publicly available sources, and information received from banks, cryptocurrency exchanges, payment providers, KYC providers, government authorities, and other lawful sources.

2.4. A transaction may be classified as high-risk if AML analysis identifies a direct or indirect connection between the assets and any of the following categories:

• Mixer;

• Sanctions;

• Ransomware;

• Gambling;

• Scam;

• Malware;

• Dark Market;

• Dark Service;

• Stolen Coins;

• Terrorism Financing;

• Fraudulent Exchange;

• Illegal Service;

• Child Exploitation;

• Fraud Shop;

• Enforcement Action;

• High-Risk Jurisdiction;

• Special Measures;

• Online Pharmacy;

• Any other categories that the Service or its provider reasonably classifies as high-risk.

2.5. The Service may suspend a transaction and initiate an additional review, including where:

• The exposure to high-risk categories is 0.1% or more;

• The overall risk level determined by the analysis system is 25% or more;

• Indicators of transaction structuring, the use of multiple related wallets, unusual activity, or other circumstances suggesting potentially unlawful activity are identified;

• There are grounds to believe that the transaction violates sanctions restrictions, AML/CFT requirements, or applicable law.

2.6. The threshold values specified in Clause 2.5 are internal risk-management criteria and do not automatically mean that a transaction is unlawful. The Service may decide to conduct additional checks, refuse service, or apply other restrictive measures even where the risk level is lower, if the circumstances of the relevant transaction so require.

3.1. Where a transaction is suspended, elevated risk is identified, there are indicators of fraud or sanctions restrictions, or other suspicious circumstances arise, the Service may request that the User undergo KYC verification.

3.2. KYC verification may be carried out by the Service itself or through a specialized third-party identity verification provider.

3.3. Within the timeframe set by the Service, the User must provide accurate, current, and legible documents and information required for verification, including, where necessary:

• An identity document;

• A selfie, video selfie, or another liveness-verification procedure;

• Proof of residential address;

• Proof of ownership of a cryptocurrency wallet or payment details;

• Proof of the source of funds;

• Documents confirming the economic purpose of the transaction;

• Bank statements, receipts, agreements, invoices, documents evidencing the purchase of crypto-assets, and other supporting materials.

3.4. The Service may request repeated KYC verification, additional documents, or explanations if the information previously provided is insufficient, inconsistent, outdated, or does not allow the Service to assess the level of risk.

3.5. Providing forged, altered, inaccurate, or third-party documents, as well as refusing to provide the required information, may result in refusal of service, cancellation of the Order, extension of the review, or other measures permitted by this Policy and applicable law.

3.6. Personal data provided during KYC verification is processed in accordance with the Service’s Privacy Policy. If a third-party identity verification provider is engaged, such provider processes the data in accordance with its privacy policy and applicable law.

4.1. Where high risk, inconsistencies in the information provided, suspicious activity, or other grounds for review are identified, the Service may, without prior notice:

• Suspend the processing or execution of an Order;

• Temporarily block the transfer of funds;

• Request KYC verification, additional documents, and explanations;

• Restrict the User’s access to the Service;

• Refuse to process a transaction or provide further services;

• Disclose information to competent government authorities where required or permitted by applicable law.

4.2. The Service independently determines the sufficiency of the documents, explanations, and verification results provided, taking into account applicable legal requirements, counterparty requirements, blockchain analytics data, and internal risk-management procedures.

4.3. The Service is not required to disclose to the User the analytical methods applied, sources of information, internal decision-making criteria, sanctions-screening results, information relating to requests from government authorities, or other confidential information, unless disclosure is required by applicable law.

4.4. The review period for a suspended transaction depends on the circumstances of the particular case, the completeness of the information provided by the User, review timeframes of third parties, and requirements of competent authorities. The Service does not guarantee execution of an Order or a refund within a fixed timeframe for Orders undergoing AML/KYC review.

4.5. To process an Order, the Service may use the services of third-party counterparties, including cryptocurrency exchanges, liquidity providers, payment services, and other organizations. Such counterparties may independently apply AML/KYC procedures, sanctions screening, and other compliance measures in accordance with their internal rules and applicable legal requirements.

4.6. If the User’s funds are suspended, blocked, or otherwise restricted by a third-party counterparty as part of an AML/KYC, sanctions, or other compliance review, the Service may request from the User any information, documents, and actions necessary to interact with such counterparty.

4.7. Upon the Service’s request, the User agrees to undergo identity verification and provide documents concerning the source of funds, the economic purpose of the transaction, ownership of a wallet, or any other information requested by a third-party counterparty as part of its compliance procedures.

4.8. The User understands and agrees that review timeframes, the list of requested documents, the decision-making process, and the timeframes for unblocking funds, executing an Order, or returning funds are determined by the relevant third-party counterparty. The Service does not guarantee a favorable decision, a refund, or a specific completion date for the review if the funds are being reviewed by such counterparty.

4.9. The Service shall not be liable for the decisions, actions, or omissions of a third-party counterparty, including suspension, blocking, transaction restrictions, refusal of service, requests for documents, changes in Order processing times, or the inability to return funds, where such circumstances did not arise through the fault of the Service.

5.1. The possibility, procedure, and timeframe for refunding funds under a suspended Order are determined by the Service, taking into account the results of the AML/KYC review, applicable legal requirements, technical feasibility of the refund, and the existence of restrictions imposed by competent authorities, banks, exchanges, payment systems, or other counterparties.

5.2. If the User has successfully completed the required KYC verification, and a refund is not prohibited by law and is technically feasible, the Service may return funds:

• To the cryptocurrency wallet address from which the assets were received;

• To the payment details from which the fiat payment was made;

• To another address or payment details confirmed by the User and approved by the Service following an additional review.

5.3. The Service may deduct from the refunded amount actual expenses incurred, including blockchain network fees, bank fees, payment-system fees, liquidity-provider fees, verification expenses, and other expenses directly related to the processing and refund of funds, where permitted by applicable law.

5.4. A refund may be impossible or delayed if:

• The User has not passed or has refused to undergo KYC verification;

• The User has not provided the required documents or information within the specified period;

• There are grounds to believe that the funds are connected with unlawful activity;

• The Service has received an order, instruction, request, or other restriction from a competent authority;

• The refund is prohibited or restricted by sanctions requirements;

• The funds have been suspended, blocked, or are undergoing a compliance review by a cryptocurrency exchange, liquidity provider, bank, payment system, or other third-party counterparty;

• It is technically impossible to identify the sender, determine a return address, or ensure the secure execution of the refund.

5.5. If the User fails to provide the information and documents required for verification, the Service may retain the funds and transaction information for the period established by applicable law and the Service’s internal procedures. Such retention does not constitute a transfer of ownership of the funds to the Service.

5.6. The User understands that a refund to an address other than the sending address may require additional verification of ownership of the new address and is not guaranteed.

6.1. The Service may screen Users, transactions, wallet addresses, payment details, and other related data for sanctions, geographic, and other restrictions.

6.2. The Service may refuse service, suspend a transaction, or take other measures if a transaction is directly or indirectly connected with a person, organization, territory, address, or asset subject to applicable sanctions restrictions.

6.3. The User agrees not to use the Service to circumvent sanctions restrictions, geographic restrictions, AML/CFT requirements, or other applicable rules.

7.1. The Service may amend this Policy at any time. A new version shall take effect upon publication on the Service’s website, unless another effective date is specified.

7.2. Continued use of the Service after the updated version of this Policy takes effect constitutes the User’s acceptance of its terms.

7.3. This Policy applies together with the Service Terms of Use, the Privacy Policy, and other documents published on the PureChange website.