Description of the anti-money laundering (AML) and Customer identification (KYC) policy used in the CRYPTOSELL service.
CRYPTOSELL AML/CFT Policy (Anti-Money Laundering & Counter-Terrorist Financing Policy)
1. General provisions
1.1. This AML/CFT Policy (hereinafter referred to as the Policy) establishes a set of measures implemented by the CRYPTOSELL service in order to prevent the legalization (laundering) of proceeds from crime, as well as the financing of terrorism.
1.2. The Policy is an internal regulatory document of CRYPTOSELL and is mandatory for all employees involved in processing applications and conducting operations.
1.3. The document has been developed taking into account the Risk-Based Approach, FATF recommendations, as well as monitoring requirements and current legislation.
1.4. Using the CRYPTOSELL service means that the user fully agrees with the provisions of this Policy.
2. Terms and definitions
2.1. CRYPTOSELL is a trademark of the digital asset exchange service.
2.2. Service is a CRYPTOSELL software and information systеm that provides services for the exchange of digital assets.
2.3. The User is an individual using the CRYPTOSELL service functionality.
2.4. Digital assets — cryptocurrencies and other digital forms of value based on blockchain technology.
2.5. AML verification — automated analysis of addresses and transactions using specialized AML tools.
2.6. Risk Score — the final numerical indicator of the transaction risk level.
2.7. KYT (Know Your Transaction) is a procedure for analyzing and monitoring transactions.
2.8. SoF (Source of Funds) — a procedure for confirming the source of funds.
2.9. KYC (Know Your Customer) is a user identification procedure.
2.10. MLRO is the person responsible for compliance with AML/CFT requirements.
3. Organization of AML control
3.1. The implementation of AML, KYT, SoF and KYC procedures is carried out by CRYPTOSELL’s internal Security Service.
3.2. The tasks of the Security Service inсlude the analysis of AML reports and Risk Score, interaction with users, recording and documenting checks, as well as making decisions on operations.
4. AML analysis and providers
4.1. All incoming transactions are subject to mandatory KYT verification using the Heleket AML AML tool.
4.2. CRYPTOSELL does not manually adjust the Risk Score and does not apply alternative risk assessment models.
4.3. The final Risk Score is a key criterion for assessing the level of risk. Risk tags are taken into account exclusively in conjunction with other parameters and are not used separately.
4.4. Risk Score Formation
4.4.1. The overall Risk Score is calculated by the AML provider based on a risk-based transaction analysis model.
4.4.2. It is an aggregated numerical value formed on the basis of a set of risk factors.
4.4.3. The calculation may take into account:
— the history of asset movement and their origin in the blockchain;
— the presence and proportion of risk labels (for example: Scam, Dark Market, Enforcement Actions, etc.);
— the structure and sequence of transactions;
— temporal and behavioral characteristics of operations;
— other parameters used by the provider.
4.4.4. Risk labels are taken into account only as part of the overall assessment and are not applied separately.
4.4.5. CRYPTOSELL does not affect the Risk Score calculation methodology and uses the results unchanged.
4.4.6. The received Risk Score is used to determine the further scenario of transaction processing.
5. Preliminary AML verification
5.1. Before making an application, the user can independently perform a preliminary AML check of the cryptoaddress.
5.2. The corresponding functionality is available on the website and leads to the BestChange monitoring verification page.:
https://www.bestchange.ru/report/
5.3. Verification can be performed by the user on a paid basis using third-party AML services.
5.4. Based on the results of the verification, the user has the right to:
— transfer the results to the operator for a preliminary assessment;
— or refuse to transfer, assuming the risks of a possible suspension of the transaction.
6. KYT, SoF and KYC procedures
6.1. KYT applies to all transactions and is aimed at determining the level of risk.
6.2. Additional control measures may be applied when:
— Risk Score above 60%;
— the presence of significant risk labels;
— lack of information about the origin of funds;
— using anonymous communication channels;
— other high-risk factors.
6.3. First of all, the SoF procedure is used to confirm the source of funds without identification.
6.4. Explanations, transaction hashes, links, extracts, and other materials without personal data may be requested within the SoF.
6.5. If the information provided is sufficient, the KYC procedure is not required.
6.6. KYC is applied only if it is impossible to confirm the source of funds or if there is a high level of risk.
6.7. CRYPTOSELL requests only relevant information strictly within the framework of KYT, SoF and KYC procedures.
6.8. Sequence of actions when the Risk Score is above 60%
— temporary suspension of the transaction;
— request information within the framework of the SoF;
— if necessary, conduct KYC.
6.9. Documents for KYC
The Service has the right to request:
— identification card;
— photo/video with the document and the application;
— video confirmation of the operation;
— information about the source of funds;
— supporting documents of income;
— other materials confirming the legality of the origin of the funds.
All requests are formed according to the principles of sufficiency and proportionality.
6.10. KYC Terms
Verification takes up to 7 business days after receiving the full set of documents. The time limit may be extended if the data is insufficient or contradictory.
7. Suspending transactions
7.1. If the Risk Score is above 60%, CRYPTOSELL has the right to temporarily suspend the operation until the verification is completed.
8. Refund of funds and fees
8.1. Based on the results of the verification, the service may perform an exchange, refund funds, or refuse service.
8.2. Upon refund, it is possible to deduct a commission of up to 5% (but not more than 100 USDT).
8.3. For bona fide users, refunds are carried out without additional deductions (except for the network commission).
8.4. The refund period is up to 10 business days after the verification is completed.
9. Restrictions on jurisdictions and sources
CRYPTOSELL does not serve users from high-risk jurisdictions according to FATF recommendations and sanctions lists (UN, EU, etc.).
Funds from prohibited countries are subject to refund in the absence of legal restrictions.
(the list of countries remains unchanged)
Sources of funds with restrictions:
— WhiteBit
— Payeer
— Grinex
CRYPTOSELL has the right to change the list of jurisdictions without prior notice.
10. Data storage
10.1. All data is stored in a secure systеm with limited access.
10.2. Information may be provided to the competent authorities upon official request in accordance with the legislation.
11. Final provisions
11.1. CRYPTOSELL has the right to change the Policy in order to updаte and comply with legal requirements.
11.2. The updated version comes into force from the moment of publication on the website.
