AML / KYC Policy

1. Our commitment

Emoney Service is committed to preventing the use of the Service for money-laundering, terrorism financing or any other criminal activity. We implement risk-based controls informed by the recommendations of the Financial Action Task Force (FATF), sanctions-screening practices, and public monitoring requirements that may apply to digital exchange services.

This Policy describes the framework. Operational procedures supporting this Policy are maintained internally and are subject to ongoing review.

2. Scope

This Policy applies to:

• All Customers using the Service, whether online or through our OTC channel.
• All Orders processed through the Service, including cryptocurrency-to-cryptocurrency swaps and OTC cash exchanges.
• All employees, contractors and partners participating in the operation of the Service.

3. Risk-based approach

We assess the money-laundering and terrorism-financing risk of each Customer relationship and each Order based on factors that include:

• The Customer's country of residence and the country from which the transaction originates.
• The volume and pattern of the Customer's transactions.
• The nature of the cryptocurrencies and networks involved, including the use of privacy-enhancing technologies.
• The Customer's status as a Politically Exposed Person (PEP) or a related party.
• The presence of any matches against the sanctions screening lists set out in section 7.

Customers and transactions classified as higher-risk are subject to Enhanced Due Diligence (section 6).

4. Customer Due Diligence (CDD)

We apply Customer Due Diligence ("CDD") on a risk-based basis. CDD is triggered when:

• A Customer's cumulative transaction volume in a rolling 30-day period exceeds the threshold displayed in the Service or determined by our risk controls.
• A single Order exceeds the threshold displayed in the Service or determined by our risk controls.
• A risk indicator identified in section 3 is present.
• We are required by a court, a supervisory authority, or by law.

CDD typically requires verification of the Customer's full name, date of birth, nationality and residential address, supported by an identity document and a liveness check, as well as a declaration regarding the source of funds.

5. Customer identification process

Identity verification may be performed through an identity-verification provider. The provider processes identity documents and biometric data on our behalf as described in our Privacy Policy.

By submitting documents to KYC, you confirm that they are authentic, current, and relate to yourself. Providing falsified documents is grounds for immediate termination of the relationship and may result in a report to law enforcement.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is performed for Customers and transactions assessed as higher-risk. EDD may include:

• Verification of the source of funds and source of wealth.
• Senior-management approval before establishing or continuing the relationship.
• Increased monitoring frequency.
• Additional documentation requirements proportionate to the risk identified.

7. PEP and sanctions screening

Every Customer may be screened against sanctions, PEP, watchlist, and risk-screening sources at onboarding and on an ongoing basis. Where a Customer is identified as a PEP or as a sanctioned party, the relationship is escalated for compliance review and may be terminated.

8. Transaction monitoring (KYT)

We monitor cryptocurrency transactions on a Know-Your-Transaction ("KYT") basis. Indicators we monitor include:

• The risk score of the deposit address and the destination address, as reported by chain-analytics providers.
• The presence of funds linked to mixers, darknet markets, sanctioned addresses, or known fraud schemes.
• Transaction patterns that suggest structuring, layering, or use of the Service for purposes inconsistent with the Customer's profile.

Transactions failing KYT checks are paused for review. Where appropriate, funds are refunded under the procedure set out in our Terms of Service and a suspicious-activity report is filed.

9. Crypto-payout controls

In compliance with FATF and OFAC requirements, all cryptocurrency payouts are made:

• To unique, low-risk destination addresses provided directly by the Customer, or
• Through routing partners that perform their own controls on the addresses they handle.

We do not pay out to addresses associated with peer-to-peer (P2P) platforms or unverified third-party services. Where bank details are used in OTC settlement, the bank account must belong to the Customer or to a counterparty whose identity has been verified.

10. Suspicious activity reporting

Where we know or have reasonable grounds to suspect that funds are the proceeds of criminal activity or are related to terrorism financing, we may file a Suspicious Activity Report ("SAR") or otherwise cooperate with a competent authority where required. We do not inform the Customer that an SAR has been filed where doing so is prohibited.

11. Record retention

We retain CDD documentation, transaction records, screening logs and SAR materials in accordance with the schedule set out in our Privacy Policy and applicable record-keeping requirements.

12. Training

All employees and contractors who interact with Customer onboarding, payments, or compliance receive AML training at onboarding and at least annually thereafter. Training covers the obligations of this Policy, the typologies of money-laundering and terrorism financing relevant to cryptocurrency exchangers, and the procedure for raising suspicions internally.

13. AML / MLRO officer

Compliance responsibilities are handled internally. The responsible person or team reviews suspicious activity reports, coordinates lawful authority requests where required, and maintains the ongoing risk assessment of the Service.

14. Cooperation with authorities

We cooperate with competent authorities where required, including responding to lawful information requests, freezing funds when ordered by a competent authority, and assisting investigations into money-laundering, terrorism financing, sanctions evasion or related criminal activity.

15. Customer consent

By creating an Order on the Service you confirm that:

• You have read and understood this AML / KYC Policy.
• The funds involved in the Order are derived from legitimate sources.
• You are not acting on behalf of a sanctioned party and the Order is not intended to evade sanctions, tax obligations or AML controls.
• You will provide CDD and EDD documentation when requested.

16. Updates

We may amend this Policy when laws, supervisory expectations, operational needs, or our risk assessment evolve. The current version is always available in the Service.

17. Contact

For any matter related to this Policy, please use the support channels published in the Service.