AML Policy

AML / KYC / SoF POLICY — EXCHANGE.EXPRESS

1. Purpose of the Policy

This Policy describes how exchange.express prevents the service from being used for:

  • laundering (legalization) of proceeds obtained through criminal activity;

  • terrorist financing;

  • other unlawful actions involving digital assets.

This Policy applies to all transactions and all service users without exception.

2. Informed User Choice Before Payment (on the order page)

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

Option A — run a pre-check of an address/TxID

  • the user clicks “Check address / Tx”,

  • receives a Risk-Score,

  • confirms that they have reviewed the result.

Option B — do not run a pre-check

  • the user explicitly selects “I did not run a check — I accept the risks.”

Important: skipping the pre-check does not отменяет the mandatory AML screening of the incoming transaction after it is received.

3. Risk assessment model (Risk-Score) and blocking threshold

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

Risk levels and service actions:

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

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

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

  • ≥ 80% (Critical risk): as a rule, the order is not processed; a refund or official escalation is applied (see Section 9).

The Risk-Score calculation methodology is internal; however, the pause threshold (≥ 50%) is fixed and stated in this Policy.

4. AML analytics tools used and valid screening results

To analyze addresses and transactions, exchange.express uses AMLBOT data. The results of this analyzer are used for:

  • Risk-Score calculation;

  • detecting links to risky sources;

  • making a decision on the order (process / pause / KYC/SoF / refund / escalation).

Results are considered valid for the service if they are obtained through analyzers listed on the order creation page (including via links in the AML block).

5. Indicators and categories of increased risk

Increased/high-risk operations include transactions showing signs of (direct or indirect) links to categories such as:

  • sanctions restrictions and prohibited jurisdictions;

  • darknet / shadow platforms;

  • mixers / obfuscation services (mixing, tumbling);

  • fraud, scams, phishing, extortion (ransomware);

  • stolen assets / hacks;

  • illegal gambling services and unregulated financial platforms;

  • sources without identification procedures (when significant risk flags are present).

The list of categories may be updated based on analyzer data and compliance assessment.

6. KYC and SoF: what materials may be requested

If an order is paused due to AML reasons, the service may request documents and information.

6.1. KYC (identity verification):

  • passport / ID card / driver’s license;

  • selfie with the document (and current date upon request);

  • proof of residential address (if necessary).

6.2. SoF (source of funds verification):

  • source of the assets (salary, trading, sale, transfer, etc.);

  • sender platform/wallet (name, account/ID if available);

  • date, amount, network, TxID/TxHash;

  • links to transactions in a blockchain explorer;

  • screenshots of transaction/deposit/withdrawal history (if available);

  • additional explanations regarding the origin trail of funds (upon request).

The list of materials is determined individually — based on risk level and transaction type.

7. Verification steps and indicative timeframes

Verification is performed in stages:

  1. automated analysis of the received transaction/address;

  2. manual compliance review if necessary;

  3. KYC/SoF request;

  4. review of the submitted materials;

  5. final decision on the order.

Indicative timeframes:

  • primary automated screening — usually from a few seconds to a few minutes;

  • full AML/KYC/SoF verification — 7 to 14 calendar days (depending on the case and completeness of documents).

8. KYC refusal / failure to provide data: clear process without indefinite holding

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

  • refuses to provide it, or

  • does not provide the data within the установлен timeframe,

the following procedure applies:

  1. the service sends a request to the email specified in the order and/or via support;

  2. the user is given up to 7 calendar days to respond and provide the data (unless another timeframe is specified in the request);

  3. if no data is provided by the deadline, the service chooses one of two permissible outcomes:

    • refund to the sender/payer; or

    • official escalation to competent authorities where legal grounds exist.

Indefinite holding of funds is not applied.

9. Refunds: conditions, timeframes, fee

If a refund is approved (including KYC refusal cases), the following rules apply:

9.1. Where funds are refunded

  • refunds are made to a verified source (as a rule, to the original sender address/wallet);

  • the service may request confirmation of the details.

9.2. Refund timeframes

  • refund processing after a decision: 7–10 business days (depending on the network/provider and technical procedures);

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

9.3. Fees and deductions

  • only the actual network/provider fee required to execute the refund is deducted;

  • additional deductions are possible only for confirmed expenses (e.g., provider/conversion/processing fees) and within a reasonable limit: up to 5% of the amount, but no more than 100 USD (equiv.).

9.4. When refunds may be restricted
Refunds may be restricted only if:

  • there is an official request/order from competent authorities; or

  • seizure/blocking/other legal measures are applied to the assets under applicable law.

In other cases, unjustified holding of funds is not allowed.

10. Processing and storage of personal data

Data is processed exclusively for:

  • performing AML/KYC/SoF procedures;

  • fulfilling obligations under the order;

  • complying with payment system requirements and applicable rules.

The service takes measures to protect confidentiality and integrity of data. The retention period is defined by internal regulations and applicable law.

11. AML Control Officer

exchange.express has appointed a responsible person/unit that ensures:

  • conducting AML/KYC/SoF procedures;

  • transaction monitoring and case handling;

  • maintaining internal reporting;

  • interaction with competent authorities where grounds exist;

  • updating the risk-based approach.

12. Policy updates

The service may amend this Policy. The current version is published on the exchange.express website. Using the service means the user agrees to this Policy.

 

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