AML Policy

 

1. GENERAL PROVISIONS
The Anti-Money Laundering (AML) policy defines a set of principles, procedures and measures applied by the exchange.express service to prevent the use of the platform for money laundering, terrorist financing and other illegal activities. The service is guided by the international AML/CFT practice and applies a risk-based approach, in which the depth and volume of checks depend on the level of identified risk of a particular transaction or user. By creating an exchange request, the user confirms that:

• I am familiar with the terms of the exchange and this AML policy;
• is aware of the possibility of suspending the operation;
• agrees to conduct AML/KYC/SoF checks if necessary.

2. Blocking funds from platforms included in the sanctions lists
Exchange.Express does not accept deposits from Garantex, DuelBits, FreeBitcoin exchanges, Gandhiji.io , Hydra, NVSPC, Roobet, Tornado, WEX Exchange, Yolo Group, SommEh, Black Sprut, BTC-e, Chip Mixer, Stake, 1xBit, OMG!OMG!, DuckDice, Primedice, MEGA DARKNET MARKET, Wasabi Wallet, Bitzlato, Darknetone, Payeer, EXMO and DoubleWay. All funds credited to our account from these resources will be blocked free of charge. The list of high-risk platforms will be updated in accordance with the current situation in the cryptocurrency market.

 

 

4. RISK ASSESSMENT AND AML MONITORING To analyze transactions, the service uses licensed and validated blockchain AML analyzers that ensure:

• tracking of transaction chains;
• identification of links to illegitimate sources;
• categorization of asset risks;
• formation of a transaction risk profile.

The results of AML analysis are used exclusively for the following purposes:

• assessing the admissibility of executing an exchange;
• determining the necessity of conducting KYC/SoF checks;
• making a final decision on the transaction.

In addition, AML monitoring is carried out on an ongoing basis throughout the entire lifecycle of the transaction.

 

5. HIGH-RISK AND SANCTIONED SOURCES The service does not accept or process funds associated with:

• sanctioned platforms;
• darknet marketplaces;
• mixers and obfuscation services;
• fraudulent, illegal, or unregulated sources;
• platforms focused on anonymity and concealment of the origin of funds.

Transactions linked to such sources are automatically classified as high-risk and are subject to suspension until the completion of the review. The list of high-risk sources is formed based on data from AML analyzers and may be updated without prior notice to users.

 

6. KYC PROCEDURES AND SOURCE OF FUNDS VERIFICATION In order to comply with AML requirements, the service establishes the following mandatory conditions:

• the sender and the recipient of funds under an exchange request must be the same person;
• transfers and exchanges in favor of third parties are prohibited;
• the user must use only their own wallets, bank accounts, and payment instruments;
• all provided personal and contact information must be accurate and up to date;
• the use of anonymous proxies, VPNs, or other methods of concealing network identification is prohibited.

Violation of the above requirements may serve as grounds for suspending the operation or refusing to provide services.

 

7. VERIFICATION PERIODS AND CONDITIONS FOR FUND RETURNS
If an elevated or high risk level is detected, the service may initiate a verification process, which may include:
7.1. Identity Verification (KYC):

• Passport, ID card, or another official document;
• Selfie of the user holding the document;
• Confirmation of the accuracy of the provided information.

7.2. Source of Funds Verification (SoF):

• Information on how the funds were obtained;
• Name of the platform or counterparty;
• Transaction details (date, amount, TxID);
• Screenshots of transaction history;
• Confirmation of the business or other lawful basis for obtaining the funds.

The list of requested materials is determined individually and depends on the risk level.

 

8. PROCESSING AND STORAGE OF PERSONAL DATA
AML verification is carried out in stages:

• Initial automated transaction analysis;
• Additional manual review if necessary;
• Request and verification of user documents;
• Re-analysis based on the submitted information;
• Making the final decision.

The estimated verification period is from 1 to 14 calendar days. In certain cases, this period may be extended if additional analysis is required.

 

9. USER CONSENT
Refunds are only possible after the AML verification is fully completed and a decision is made by the service. Refund conditions:

• Refunds are made to the verified source of funds;
• A fee of up to 5% may be withheld to cover operational, administrative, and analytical costs;
• The refund processing period is up to 7 calendar days from the date the decision is made;
• The user must confirm the accuracy of the provided account details.

Refunds are not possible if the assets are blocked at the request of competent authorities or are recognized as material evidence.