Политика противодействия отмыванию денежных средств и финансированию незаконной деятельности

1. Contents

1. General Provisions
2. Core AML Control Principles
3. AML Tools Used
4. Transaction Risk Assessment Model (Risk Score)
5. AML Verification Procedure
6. User Identification Procedure (KYC)
7. Verification Timeframes
8. Possible Outcomes of the Verification
9. Funds Return Procedure
10. Prohibited Sources of Funds
11. Quality of Outgoing Digital Assets
12. Final Provisions

2. General Provisions

This Anti-Money Laundering and Countering Illegal Activity Policy (hereinafter referred to as the “AML Policy”) defines the principles and financial monitoring procedures applied by the HASchange service when providing digital asset exchange services.

The main purpose of this policy is to prevent the HASchange platform from being used for the legalization (laundering) of proceeds obtained through criminal activities, the financing of illegal activities, or other actions that contradict internationally accepted AML/CTF practices.

HASchange adheres to the principles of responsible and fair business conduct and takes the necessary measures to identify, analyze and prevent transactions that may be associated with unlawful sources of funds.

This policy applies to all transactions carried out through the HASchange platform.

3. Core AML Control Principles

Within the framework of financial monitoring, the HASchange service follows these principles:

• analysis of the origin of digital assets received by the service addresses;
• transaction risk assessment using specialized blockchain analytics tools;
• application of a risk-based approach when evaluating user operations;
• implementation of additional verification procedures if an elevated risk level is detected;
• prevention of processing transactions associated with illegal activity.

The service reserves the right to temporarily suspend operations and perform additional verification if the risk evaluation systеm identifies suspicious indicators.

4. AML Tools Used

To analyze transactions and evaluate risk levels, the HASchange service uses specialized blockchain analytics tools.

In particular, transaction analysis is performed using the AML service:

AML Bot | mexm.io

This tool allows digital assets to be checked for potential connections with:

• illegal activities;
• sanctions lists;
• darknet marketplaces;
• cryptocurrency mixing services;
• fraudulent schemes;
• other high-risk sources.

The analysis results are used to generate a Risk Score for the transaction.

5. Transaction Risk Assessment Model (Risk Score)

Each transaction received by HASchange service addresses undergoes an automated analysis procedure.

Based on the results of the analysis, the transaction is assigned a Risk Score — an indicator of the transaction’s risk level.

The Risk Score is determined based on the following factors:

• history of digital asset movement;
• connections of addresses with high-risk services;
• participation of addresses in suspicious transactions;
• association of funds with sanctioned or prohibited sources;
• other parameters obtained from blockchain data analysis.

The service applies the following risk evaluation model:

• 0–40% — low risk level. The transaction is considered safe and processed normally.
• 40–70% — medium risk level. The operation may be subject to additional verification.
• 70% and above — high risk level. The transaction may be temporarily suspended for additional financial monitoring procedures.

In certain cases, the service may conduct additional manual analysis if the user provides information confirming the lawful origin of funds.

6. AML Verification Procedure

If a transaction is identified as having an elevated risk level, the HASchange service may initiate an AML verification procedure.

The verification process may inсlude the following steps:

• analysis of the transaction using AML tools;
• additional review of the transaction history;
• a request to the user for information confirming the lawful origin of funds;
• user identification procedure (KYC);
• evaluation of documents and information provided by the user.

During the verification period, the transaction may be temporarily suspended.

7. User Identification Procedure (KYC)

As part of the AML verification process, the HASchange service may request the user to complete a Know Your Customer (KYC) identity verification procedure.

The verification may inсlude providing the following materials:

• a photograph of an identity document;
• a selfie of the user holding the identity document;
• proof of residential address;
• confirmation of the source of funds;
• other documents required to complete the verification.

The list of required documents may vary depending on the risk level of the transaction.

8. Verification Timeframes

The review period for AML cases depends on the complexity of the situation and the completeness of the information provided by the user.

The estimated verification period may take up to 7 (seven) business days.

In some cases, the verification period may be shortened or extended depending on the circumstances.

9. Possible Outcomes of the Verification

• Transaction approval — if the origin of funds does not raise suspicion.
• Return of funds to the sender — if the exchange operation cannot be completed.
• Escalation to competent authorities — if signs of illegal activity are detected.

10. Funds Return Procedure

If a decision is made to return funds, the HASchange service returns the digital assets to the sender.

A fee related to the actual costs of processing the AML case may be charged. However, the fee will not exceed:

5% of the transaction amount and no more than the equivalent of 100 USD.

If the user successfully completes the verification and the funds are deemed legitimate, no additional service fee is charged except for blockchain network transaction fees.

11. Prohibited Sources of Funds

• darknet marketplaces;
• cryptocurrency mixing services;
• fraudulent schemes and financial pyramids;
• sanctioned addresses;
• addresses associated with cybercrime;
• addresses linked to terrorism financing;
• other high-risk sources.

If such connections are detected, the transaction may be blocked for additional verification.

12. Quality of Outgoing Digital Assets

The HASchange service takes measures to ensure the quality of digital assets sent to users.

Before sending, digital assets may undergo additional verification to ensure they meet acceptable risk levels.

The service strives to provide users with assets that do not have an elevated risk level according to the AML tools used.

13. Final Provisions

The HASchange service reserves the right to amend this AML Policy if AML/CTF practices or internal financial monitoring procedures change.

The current version of the policy is always available on the official website of the service.

By creating a digital asset exchange request, the user confirms that they have read and agree to this AML Policy.