AML Policy
This AML Policy (hereinafter referred to as the Policy) regulates the activities of
changeex.eu in relation to anti-money laundering and its involvement in combating money laundering and financing of terrorist activities.
money laundering and financing of terrorist activities.
1. Terms and definitions
Service Changeex (Service) - a system of Internet services provision
on exchange, sale and purchase of electronic assets and electronic money.
funds.
Service website - changeex.eu
User - any natural person using the services of the Changeex Service and accepting the terms of the Privacy Policy
Changeex Service and accepts the terms and conditions of the Privacy Policy, as well as
Cookies policy of the Changeex Service.
Digital currency - Bitcoin, Litecoin, Ethereum and any other
blockchain-based currencies.
Electronic currency - monetary funds held in the accounts of the
users of electronic payment systems.
Card verification is a verification that the card (or account) belongs to its owner.
card (or account) belonging to its owner, it is performed once for each new card
of the User. Terms of verification are set by the Service.
Money laundering - actions aimed at returning to the financial and economic market money or other securities of the illegal
money or other securities of illegal origin into the financial and economic market.
money or other securities of illegal origin, presenting their acquisition and possession as perfectly
legal and normal, as well as the conduct of other transactions of an illegal nature.
illegal nature. In accordance with international legislation
changeex.eu adheres to a number of rules and implements a number of procedures
aimed at preventing the use of the Service for the purpose of conducting money laundering operations.
money laundering operations. Our anti-money laundering policy
money laundering policy is aimed at increasing the security of customers and services provided by the Service.
services provided by the Service.
Terrorist financing is the willful provision or collection of
by any means, directly or indirectly, of funds with the intention of utilizing
those funds for the commission of terrorist acts.
2. Activities undertaken in the framework of compliance with the AML Policy.
The management of the changeex.eu service, realizing the social danger of
of crimes related to money laundering and terrorist financing.
financing of terrorist activities, has developed a set of
organizational and legal measures in order to comply with the provisions of the
national legislation, as well as the requirements
of the intergovernmental organization FATF.
2.1 Application of KYC policy (know your customer - know your customer).
know your customer). Mandatory identification of Users
performing exchange operations on our Service. For verification
User Administration has the right to require the following
data:
- to take a photo ("selfies") with an identification document
A scan copy of the front and back sides of an official ID card with a photo.
A scan of the front and back of an official photo ID, i.e. a valid passport, driver's license or other national identity card
driver's license or other national identity card;
- confirm the place of residence: an official document issued within the last 3 months
the last 3 months, clearly indicating the name and address of the client specified
when registering at changeex.eu. It can be a utility bill
utility bill (for water, electricity or landline phone) or a bank statement.
bank. The copy must include: full name, full residential address,
the date of issue (within the last 3 months), the name of the issuing authority, with the official logo or logo of the bank.
document, with the official logo or stamp;
- provide a copy of the front and back of your bank card and/or
a photo of your bank card taken against the background of the main page of the Service.
Service. To ensure privacy and security, only the last 4 digits of your card
only the last 4 digits of your card. It is allowed to hide the CVV code (3 digits on the back of the card).
back of the card).
The administration of the changeex.eu service will take steps to confirm
authenticity of documents and information provided by Users.
Also the identification information will be verified with the help of
secondary sources, and the Administration of the service reserves the right
right to further investigate cases in order to obtain full
confidence in the authenticity of the documentation provided.
The administration of the changeex.eu service reserves the right to conduct
monitoring of the User's data on a permanent basis, especially in those cases when his/her identification information has been changed.
in cases when his/her identification information has been changed
or his activity seems suspicious (unusual for a particular User).
particular User). In addition, the Administration reserves the right to
The Administration reserves the right to request from Users up-to-date documents, even if they have been authenticated in the past.
if they have been authenticated in the past.
2.2 Continuous monitoring of operations,
passing through the Service.
We maintain constant
control over all requests created on the site changeex.eu.
The administration of the service notifies Users about the ban on
exchange operations from third parties using their account.
their account.
2.3. Increasing the professional skills and knowledge
employees of the changeex.eu team in terms of compliance with the requirements of the Policy.
Policy.
2.4. Interaction with state bodies in
in cases prescribed by law. In the event of
In the event of a formal request from law enforcement or judicial authorities, we are
we will be obliged to provide them with the requested information. Also
Administration of the service has the right to provide the data requested by
official representatives of payment systems.
2.5. Improving the security of the service software
changeex.eu. We care about the safety and security
of the transactions made on our service. In this regard, we are constantly
improve our IT-department, the main task of which is to
protection of the site from unauthorized access of intruders.
2.6. The administration of the changeex.eu service, in cases,
prescribed by law, may impose a regulatory requirement to
verification of the source of fiat money and/or cryptocurrency, to
ensure that the sources of the Funds that Customer uses for the exchange are legitimate.
exchange are legitimate. As a document confirming
source of origin of the Funds may be a bank statement for fiat money or a video showing details of a wallet transaction.
fiat money or a video showing details of a wallet transaction for cryptocurrencies.
for cryptocurrencies.
In accordance with this
Policy the Service Administration, will:
- monitor all transactions. The administration reserves the right
the right to ensure that suspicious transaction reports are passed on
to the appropriate law enforcement authorities through the Responsible Official;
- request any additional information and documents from the User in case of suspicious transactions.
in case of suspicious transactions, as well as at the request of the regulator (the regulator may be an exchange, a state exchange, or a governmental organization).
regulator (the regulator may be an exchange, governmental agency or other organization with appropriate legal status).
an exchange, governmental agency or other organization with appropriate legal grounds); and
legal grounds);
- Suspend or terminate a User's account if
there is reasonable suspicion that such User is engaging in illegal activity.
activities.
However, the above list is not exhaustive, transactions of
user transactions will be monitored regularly to determine their risk level.
2.
KYT (Know Your Transaction) Policy
Know Your Transaction or KYT is a phrase used in the financial sector to
to describe the process of evaluating cryptocurrency transactions for fraudulent or
suspicious activity such as money laundering. KYT is one of the
component of anti-money laundering policies and helps to assess the risks of
transactions and identify transactions related to financial crimes such as money laundering and terrorist financing.
such as money laundering and terrorist financing.
It is KYT's policy to identify a customer's transaction in case of precedent,
when the Service has reasonable suspicion that a customer is attempting to
to use the Service and its services for the purpose of carrying out illegal transactions
or money laundering.
Such precedent can arise, if the Service suspects the Client in illegal
actions, which may be qualified as laundering or attempt to
laundering of digital assets obtained illegally or funds are of
frankly criminal origin. For these purposes, the Service is entitled to use
any lawful information, third-party means of analyzing the origin of digital assets, as well as its own developments of the script.
assets, as well as its own developments of the screening system.
In this case, the changeex.eu Service reserves the full right:
- Require the Client to provide additional information disclosing the
the origin of the digital assets and/or confirmation that the assets have not been
have been obtained by criminal means;
- Block the account and any transactions related to the Customer, transfer to the
controlling financial activity and/or law enforcement authorities at the
the place of registration of the Service and, if necessary, the address of registration of the Customer, all information and documents available on the incident
Client's registration address all information and documents available on the incident;
- Require from the Client documents confirming the identity, physical existence, registration address, solvency; and
existence, registration address, solvency;
- Return digital assets only to the account from which the transfer was made or change to other accounts after full verification.
to the account from which the transfer was made or to other accounts, after full verification by the security service of the Service
by the security service of the Service, if it was possible to verify the legal origin of the Client's funds
of the Client's funds;
- Refuse to allow the Customer to withdraw funds to a third party account without explanation
reasons;
- Withhold Client funds until the incident has been fully investigated;
- The Service reserves the right to monitor the entire chain of transactions, in order to
for the purpose of revealing suspicious transactions;
- The Service reserves the right to refuse to provide the Customer with the service,
if the Service has reasonable suspicions about the legitimacy of the origin of the
digital assets and to withhold funds on special accounts of the Service;
- The Service reserves the right to refuse to provide the Customer with the service,
if the Service has reasonable suspicions about the legitimacy of the origin of the
digital assets and to withhold funds on special accounts of the Service, in case it is impossible to trace the whole chain of movement of digital assets with the Service.
in case it is impossible to trace the whole chain of movement of digital assets from the moment of their appearance.
from the moment of their appearance.
Terms of return of funds stopped for verification, based on the results of AML analysis
transaction:
- Refunds are made after a full security check of the Service
security of the Service, which may include detailed
verification of the sender. Refunds are made after
deducting a commission of up to 10% of the transaction amount to cover
labor costs of processing the request and organizing the refund.
- The refund, subject to approval by the Service, will be
processed by the Service within 7 (seven) calendar days, starting from the date on which the User was notified of the Service's decision.
from the date on which the User was notified of the Service's decision on his/her refund request.
regarding their request for a refund.
- When issuing a refund, after passing
verification, the user is obliged to confirm the requisites
to receive the refund.