AML Policy

AML / KYC / SoF POLICY OF EXCHANGE.EXPRESS

1. Purpose of the Policy

This policy describes how exchange.express prevents the use of the service for:

  • legalization (money laundering) of proceeds obtained by criminal means;

  • terrorism financing;

  • other unlawful actions with digital assets.

The policy applies to all operations and all users of the service without exceptions.

2. Informed User Choice Before Payment (on the Order Page)

Before making a payment, on the order creation form, the user sees an AML check warning and makes an informed choice:

Option A — undergo a preliminary address/TxID check

  • the user clicks "Check address / Tx",

  • receives a Risk-Score,

  • confirms acknowledgment of the result.

Option B — do not undergo a preliminary check

  • the user explicitly selects "I did not perform a check — I assume the risks."

Important: opting out of the preliminary check does not cancel the mandatory AML check of the incoming transaction after it is received.

3. Risk Assessment Model (Risk-Score) and Blocking Threshold

The service uses a Risk-Score (0–100%) — a percentage risk assessment for a wallet/transaction based on AML analyzer data.

Risk levels and service actions:

  • 0–39% (Low risk): the order is processed in standard mode.

  • 40–49% (Increased risk): the order may be processed, or clarifications may be requested (depending on the situation).

  • ≥ 50% (High risk): order execution is temporarily suspended for AML control and KYC/SoF procedures.

  • ≥ 80% (Critical risk): the order is generally not processed; a refund or official escalation is applied.

The Risk-Score calculation methodology is internal; however, the suspension threshold (≥ 50%) is fixed and specified in this policy.

4. AML Analyzers Used and Valid Audit Results

For analyzing addresses and transactions, exchange.express uses AMLBOT data. Analyzer results are used for:

  • Risk-Score calculation;

  • identifying links to risky sources;

  • making a decision on the order (execution / suspension / KYC/SoF / refund / escalation).

Audit results obtained through the analyzers specified on the order creation page are considered valid for the service.

5. Signs and Categories of Increased Risk

Increased/high risk operations include transactions with signs of connection (direct or indirect) with categories such as:

  • sanctions restrictions and prohibited jurisdictions;

  • darknet/shadow platforms;

  • mixers/obfuscation services (mixing, tumbling);

  • fraud, scam, phishing, ransomware;

  • stolen assets / hacks;

  • illegal gambling services and unregulated financial platforms;

  • sources without identification procedures.

Additionally, high-risk operations include transactions related (directly or indirectly) to the following platforms, services, exchangers, mixers, marketplaces, entities, and infrastructure:

  • bitpapa.com

  • rapira.net

  • peer.com

  • payeer.com

  • capitalist.net

  • grinex.io

  • meer.kg

  • nobitex.ir

  • 1xbet and all related entities

  • aifory.pro

  • terminal.cash

  • skycrypto.net

  • flashobmen.com

  • 60cek.net

  • hd-change.com

  • coinblinker.com

  • metka.cc

  • alfabit.org

  • Garantex

  • Hydra

  • Blender.io

  • Lazarus Group

  • Genesis Market

  • ChipMixer

  • Sinbad

  • Bitzlato

  • netex24.net

  • BTC-e / FinCEN

  • weiss.bet

  • CryptoCloud

  • xRocket.tg

  • heleket.com

  • WebMoney

  • arvix.pro (abcex.io)

  • Prostocash

  • Cripta

  • CoinStart

  • kassa.cc

  • freekassa.ru

  • OFSI Huobi Global S.A. (HTX.com)

The presence of a direct or indirect link with the specified entities may lead to an additional AML check, KYC/SoF request, temporary suspension of the operation, refusal to complete the order, or a refund of funds.

6. KYC and SoF: Materials That May Be Requested

If an order is suspended for AML reasons, the service is entitled to request documents and information.

6.1. KYC (Identity Identification):

  • passport / ID card / driver's license;

  • selfie with the document;

  • proof of residential address (if necessary).

6.2. SoF (Source of Funds Confirmation):

  • source of asset acquisition;

  • sender's platform/wallet;

  • date, amount, network, TxID/TxHash;

  • links to transactions in the blockchain explorer;

  • screenshots of transaction history;

  • additional explanations on the origin of funds.

7. Verification Stages and Estimated Timelines

The check is conducted in stages:

  1. automatic analysis of the incoming transaction/address;

  2. manual compliance analysis (if necessary);

  3. KYC/SoF request;

  4. verification of the provided materials;

  5. final decision on the order.

Estimated timelines:

  • initial automatic analysis — from a few seconds to a few minutes;

  • AML block — up to 24 hours to receive final status;

  • full AML/KYC/SoF check — from 7 to 14 calendar days.

8. Refusal of KYC / Failure to Provide Data

If KYC/SoF data is required to complete the verification, and the user:

  • refuses to provide them, or

  • does not provide data within the established timeframe,

then the following procedure applies:

  1. the service sends a request via email or through support;

  2. the user is provided with a period of up to 7 calendar days to respond;

  3. in the absence of data, the service chooses one of the following options:

    • refund of funds to the sender;

    • official escalation to competent authorities.

Indefinite retention of funds is not applied.

9. Refund of Funds: Conditions, Timelines, Commission

9.1. Where funds are returned

  • the refund is performed to the confirmed source;

  • the service may request confirmation of payment details.

9.2. Refund Timelines

  • refund period after the decision is made: 7–10 business days;

  • the user is provided with a refund confirmation (TxHash/ID of the operation).

Additional processing timelines:

  • Refund of payments without memo — up to 3 business days from receipt of the refund wallet.

  • Refund of payment in an unsupported currency / network — up to 7 business days.

  • Crediting of payments returned to our hot wallet — up to 7 business days.

  • AML block — up to 3 business days for the refund.

9.3. Fees and Deductions

  • only the actual network/provider fee is deducted;

  • additional deductions are possible only with confirmed expenses — up to 5% of the amount, but not more than 100 USD.

9.4. When a refund may be restricted

  • upon an official request from competent authorities;

  • in case of seizure/blocking of funds within the framework of legislation.

10. Processing and Storage of Personal Data

Data is processed exclusively for:

  • carrying out AML/KYC/SoF procedures;

  • fulfilling obligations under the order;

  • complying with legal requirements.

The service takes measures to protect the confidentiality and integrity of data.

11. Person Responsible for AML Control

A responsible person/department is appointed at exchange.express to ensure:

  • execution of AML/KYC/SoF procedures;

  • monitoring of operations;

  • maintenance of internal reporting;

  • interaction with competent authorities;

  • updating the risk approach.

12. Policy Updates

The service is entitled to change this policy. The current version is published on the exchange.express website. Use of the service constitutes user consent to this policy.

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