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AML/KYC/KYT Service Policy

1. General Provisions

1.1. This Anti-Money Laundering (AML), Know Your Customer (KYC), and Know Your Transaction (KYT) policy governs the provision of services by the Cryptocurrency Exchange Service Exchnage, registered in Saint Kitts and Nevis.

1.2. The Service operates in accordance with:

  • Guidance for a risk-based approach to virtual assets and virtual asset service providers (FATF);
  • 5AMLD EU Directive (EU) 2018/843;
  • the applicable laws of Saint Kitts and Nevis and international AML/CTF agreements.

1.3. The purpose of this policy is to minimize the risks of money laundering, terrorist financing, fraud, sanctions evasion, and other unlawful activity.

2. Principles of the AML/KYC/KYT Policy

  • Know Your Customer (KYC): identification and verification of all users whose transactions are subject to review.
  • Transaction Monitoring (KYT): automated and manual review of cryptocurrency transactions using specialized services (e.g., AMLBot).
  • Risk Assessment: a risk-based approach in accordance with FATF RBA.
  • Prohibition of servicing unlawful transactions.
  • Transparency: retention of exchange transaction history, verification data, and compliance department decisions.

3. Customer Verification (KYC)

3.1. Customer identity verification may include:

  • submission of a passport/ID card (spread with photo and personal data);
  • a selfie with the document;
  • a photo of the passport against the Service order screen;
  • video confirmation of ownership of funds (see Section 8.9 of the current Exchnage rules).

3.2. The Service reserves the right to request:

  • residential address and supporting document (utility bill, bank statement);
  • information on the source of funds;
  • information on the purpose of using the service.

3.3. The customer must provide accurate information. Documents found to be forged will be rejected.

4. AML and Transaction Monitoring (KYT)

4.1. All incoming and outgoing cryptocurrency transactions undergo automated screening through blockchain analysis systems (e.g., AMLBot).

4.2. The Service may refuse to process an order if it detects:

  • links between funds and darknet markets, fraud, hacks, or sanctioned addresses;
  • a high risk score according to the AML provider;
  • use of anonymizers (Mixers, Tornado Cash, and similar services).

4.3. In the case of a suspicious transaction, the Service may:

  • suspend the transaction;
  • request additional information and documents from the customer;
  • report the data to the competent authorities of Saint Kitts and Nevis.

4.4. When initiating a transaction, the User may:

— provide the results of an independent AML check of a cryptocurrency address or transaction performed using an external service (including AMLBot or via the verification form on the BestChange website) for additional risk assessment by the Service;

— or decline to provide verification results and confirm acceptance of all associated risks, including possible suspension, blocking, or refusal to process the transaction if AML risks are identified.

The Service may take into account the data provided by the User when making a decision, but is not obligated to accept, verify, or rely on such data when assessing risks.

The Service may offer the User the option of a paid preliminary AML check of a cryptocurrency address using a valid analytics tool. The Service is not required to provide a free AML check.

5. Refusal of Service Policy

The Service does not provide services to users:

  • from jurisdictions subject to UN, EU, or OFAC sanctions;
  • who refuse to undergo verification;
  • who provide inaccurate data;
  • suspected of fraud or money laundering.

6. Personal Data Protection

6.1. All customer personal data is processed and stored in accordance with the laws of Saint Kitts and Nevis and the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (CED No. 108).

6.2. Data is used exclusively for AML/KYC purposes and is not transferred to third parties except as expressly required by law.

7. Data Retention

7.1. The Service retains customer, transaction, and verification data for at least 5 years from the date of the transaction.

7.2. In the event of investigations, the retention period may be extended.

8. Rights and Obligations of the Service

The Cryptocurrency Exchange Service Exchnage reserves the right to:

  • request any additional documents from the customer at any stage of a transaction;
  • refuse an exchange without explanation if AML/CTF risks are suspected;
  • block funds pending clarification of circumstances;
  • maintain a log of all AML/KYC/KYT checks.

9. Rights and Obligations of the User

The User agrees to:

  • provide accurate and up-to-date information;
  • not use the service for unlawful transactions;
  • cooperate during additional verification.

10. Final Provisions

10.1. By using the Service, the User confirms acceptance of this policy.

10.2. Any disputes relating to its application shall be resolved through negotiations, and if that is not possible — in accordance with the laws of Saint Kitts and Nevis.