AML/KYC Policy

The policy of countering the legalization of proceeds from crime and the "Know your Customer" policy.

The Anti—Money Laundering and "Know Your Customer" Policy (hereinafter referred to as the "AML/KYC Policy") is designed to prevent and reduce the possible risks of MoscoinExchanger being involved in any illegal activity. In accordance with international and local regulations, MoscoinExchanger implements 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 respond in case of any form of suspicious activity on the part of its Users.

The AML/KYC policy includes the Verification procedure, the presence of an official in the company's staff responsible for compliance with AML standards, Transaction Monitoring, as well as Risk Assessment. One of the international standards for preventing illegal activities is customer due diligence ("CDD"). To this end, MoscoinExchanger implements its own verification procedures in strict standards for countering the legalization of proceeds from crime and the "Know Your Customer" procedure.

The MoscoinExchanger identity identification procedure requires the User to provide MoscoinExchanger with reliable, independent source documents, data or information (for example, a national ID card, international passport, bank statement, utility bill). For such purposes, MoscoinExchanger reserves the right to collect User identification information for the purpose of complying with the AML/KYC Policy.

MoscoinExchanger will take steps to verify the authenticity of documents and information provided by Users. All legal methods for double-checking identification information will be used, and MoscoinExchanger reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious.

MoscoinExchanger reserves the right to verify the User's identity on an ongoing basis, especially when his identification information has been changed or his activity has seemed suspicious (unusual for a particular User). In addition, MoscoinExchanger reserves the right to request current documents from Users, even if they have been authenticated in the past.

After confirming the identity of the user, MoscoinExchanger may waive potential legal liability in a situation where the company's services are used to conduct illegal activities.

The official responsible for AML compliance is a person duly authorized by MoscoinExchanger, whose responsibility is to ensure the effective implementation and enforcement of the AML/KYC policy. The duty of such an official is to monitor all aspects of MoscoinExchanger activities to counteract the legalization of proceeds from crime, including money laundering and terrorist financing, including, but not limited to the following methods:

Collecting user identification information;
Create and update internal policies and procedures for completing, reviewing, submitting and storing all reports and records required by applicable laws and regulations;
Transaction monitoring and investigation of any significant deviations from normal activities;
Implementation of a records management system for the appropriate storage and retrieval of documents, files, forms and journals;
Regular updating of the risk assessment;
Providing law enforcement agencies with information necessary in accordance with applicable laws and regulations.

The official responsible for compliance with AML regulations has the right to interact with law enforcement agencies that are involved in preventing money laundering, terrorist financing and other illegal activities.

Users are verified not only by verifying their identity, but, more importantly, by analyzing their behavior in transactions. Therefore, MoscoinExchanger relies on data analysis as a tool for risk assessment and suspicion detection. MoscoinExchanger performs a variety of compliance-related tasks, including data collection, filtering, record keeping, investigation management, and reporting.

System functions include:

Daily verification of Users for the existence of recognized "blacklists" (for example, OFAC), aggregation of transmissions across multiple data points, placing users on watch lists and denial of service, opening cases for investigation where necessary, sending internal messages and completing mandatory reports, if applicable;

Case and document management.

Regarding the AML/KYC policy, MoscoinExchanger will monitor all transactions and reserves the right to:

Ensure that reports of suspicious transactions are transmitted to the appropriate law enforcement authorities through the official responsible for compliance with AML standards;

request any additional information and documents from the User in case of suspicious transactions;

suspend or terminate a User's account if MoscoinExchanger has a reasonable suspicion that such a User is involved in illegal activities.

The above list is not exhaustive, and the official responsible for AML compliance will monitor user transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or which should be treated as bona fide.

MoscoinExchanger, in accordance with international requirements, applies risk assessment practices to combat money laundering and terrorist financing.

By applying risk assessment practices to combat money laundering, MoscoinExchanger ensures that measures to prevent or reduce money laundering and terrorist financing are commensurate with the identified risks.

As for cryptocurrencies, MoscoinExchanger reserves the right to suspend the exchange operation and require the client to verify his identity in accordance with the above rules, as well as documents confirming the origin of the cryptocurrency sent by the client upon a completed exchange request.

If the client refuses to undergo identity verification and (or) refuses to provide documents confirming the origin of the cryptocurrency sent by the client on a completed exchange request, MoscoinExchanger conducts an additional investigation before receiving information from law enforcement and (or) regulatory authorities containing instructions regarding the funds held.

If the customer has provided all the necessary documents, MoscoinExchanger undertakes to make a refund or complete the exchange within 30 (thirty days) calendar days.

If the acceptance of title signs was carried out on exchange wallets and funds were frozen by the exchange, then if the User refuses verification, the funds remain frozen until an indefinite moment and can be unfrozen by a court decision. All legal claims of the User in the order of recourse must be redirected to the source of blocking funds — the exchange.

If, by a court decision, the return of title signs is carried out by the exchange, through an exchange service, then the latter makes a refund minus 1% of the amount received, as well as other network commissions. The amount of the retention interest is determined by the damage that the user has caused to the exchange service.

Below is a list of countries whose customers from these countries cannot be accepted as Users. Any customers from these countries will be denied service and the funds will be returned to the source. Full list of prohibited jurisdictions:

Afghanistan

Albania

Angola

Algeria

Bangladesh

Bolivia

Botswana

Burma (Myanmar)

Burundi

Fumes

Congo

Conakry

Ivory Coast

Democratic People's Republic of Korea (DPRK)

Equatorial Guinea

Eritrea

Ghana

Guinea-Bissau

Haiti

Guyana

Iraq

Iran

Lao People's Democratic Republic

Lebanon

Libya

Mali

Morocco

Myanmar

Nepal

Nicaragua

North Macedonia

Pakistan

Qatar

Saudi Arabia

Somalia

South Sudan

Sudan

Syria

Tunisia

Uganda

Vanuatu

Yemen

Zimbabwe

AML-KYC