AML, KYC and KYT Policy

1. Introduction

1.1. The Anti-Money Laundering Policy (AML), Know Your Customer (KYC) procedures, and Know Your Transaction (KYT) procedures have been developed to prevent and protect the AvanChange digital currency exchange service from being involved in any form of illegal activity. This Policy describes the procedure for customer identification, transaction monitoring, and protection against the use of the platform for money laundering, terrorist financing, and other unlawful acts.

2. Purpose of Internal Regulation

2.1. The AvanChange Service has established a set of procedures and rules in the field of anti-money laundering and counter-terrorist financing (AML/CFT). The primary purpose of these measures is to demonstrate our commitment to combating any attempts to use the Service for illegal purposes and to ensure user safety and business integrity.

3. Warning

3.1. The AvanChange Service urges users to exercise due diligence and to prevent the use of the platform for the following purposes:

Laundering illegally obtained funds.
Financing terrorist activities.
Fraud of any kind.
Purchasing prohibited goods and services.

3.2. If signs of illegal activity are detected, AvanChange will immediately take appropriate measures, including suspending transactions and forwarding information to law enforcement authorities.

4. Requirements for Exchange Transactions

4.1. AvanChange imposes the following requirements for conducting transactions:

The sender and the recipient of the payment must be the same person. Transfers in favor of third parties are prohibited.
All contact and personal data must be current and accurate. Providing false information may result in account suspension and cancellation of the exchange request.
Submitting exchange requests using anonymizers and anonymous browsers (VPN, Tor, etc.) is prohibited. Such connections will automatically result in denial of service.

5. Verification Procedures

5.1. The customer verification procedure is a key component of the KYC/KYT policies and is implemented in accordance with international standards and the laws of the Russian Federation.

5.2. One of the international standards for preventing illegal activity is proper customer due diligence (hereinafter referred to as “Verification”). For this purpose, AvanChange implements its own verification procedures in strict compliance with anti-money laundering standards and the Know Your Customer and Know Your Transaction procedures.

5.3. The AvanChange Service may require the User to provide reliable, accurate, and independent source documents, data, or information to complete verification and confirm the origin of funds. The required materials may include:

A photo with a passport opened, where the photo and full name are clearly visible;
A scan or photo of the passport (the first and second pages, as well as the registration page, in good quality);
Confirmation of the source of funds (photos, screenshots, statements);
A video showing the person who sent the funds holding an opened passport where the photo and full name are clearly visible, stating that they created exchange request ID (request number) at the AvanChange exchange service, that the sent funds are their personal funds, and that they bear full legal responsibility for the cryptocurrency. The video must also mention the source of the funds;
A video recorded from the platform from which the funds were sent. The video must show the hash, sender and recipient addresses, the amount with ticker, and the transaction date. The video duration must be at least 10 seconds.

5.4. The average review time for verification data is up to 7 days. In rare cases, more time may be required depending on the degree of involvement in illegal activity.

5.5. In cases of blocking due to high risk or an official investigation, funds will be held until verification is completed or the investigation is concluded. For such purposes, the AvanChange Service reserves the right to collect the User’s identification information for compliance with the AML/KYC Policy.;

5.6. The AvanChange Service will take steps to confirm the authenticity of documents and information provided by Users. All lawful methods for double-checking identification information may be used, and the AvanChange Service reserves the right to investigate certain Users whose identities have been identified as dangerous or suspicious.

5.7. The AvanChange Service reserves the right to verify the User’s identity on an ongoing basis, especially when their identification information has changed or their activity appears suspicious or unusual for that specific User. In addition, the AvanChange Service reserves the right to request up-to-date documents from Users even if they have passed authenticity verification in the past.

5.8. User identification information will be collected, stored, shared, and protected strictly in accordance with the AvanChange Service Privacy Policy and applicable rules.

5.9. After confirming the User’s identity, the AvanChange Service may refuse to provide services to the User if the AvanChange Service is being used for illegal activity.

5.10. Users who intend to use payment cards to access services must complete card verification in accordance with the instructions available on AvanChange.com.

5.11. The AvanChange Service is subject to regulatory requirements to verify the source of fiat funds or cryptocurrency in order to ensure that the sources of funds used by Users for trading are lawful.

6. Responsible Officer

6.1. The appointed responsible officer of AvanChange is responsible for implementing all AML/KYC procedures and monitoring compliance with regulations and internal rules. 6.2. The responsibilities of the responsible officer include:

Monitoring and analyzing suspicious transactions.
Approving and implementing internal procedures.
Training employees.
Interacting with law enforcement authorities.

7. Risk Assessment System

7.1. Risk Assessment Algorithm (Risk Score). All incoming and outgoing transactions undergo mandatory checks based on the Risk Score model, designed to prevent the use of the Service for illegal purposes. The overall risk is determined within a range from 0% to 100%, where:

Up to 25%: The wallet or transaction is clean.
25–50%: Moderate risk, enhanced monitoring.
50%+: High risk, requires additional review.

The acceptable risk level is up to 50%. Transactions with a higher risk level are automatically blocked and sent for additional review.

7.2. Handling high-risk labels

Certain categories of high-risk labels, such as Sanctions, Scam/Fraud, Illegal Services, and others, are blocked regardless of the overall risk level. If such labels are detected:
The transaction is automatically blocked.
In case of doubt, the system may request additional KYC verification to confirm the legitimacy of the assets.

7.3. Recognition of Risk Score Procedure Results

The AvanChange Service determines the risk level (“Risk Score”) using specialized tools and external services, such as Rapira, BitOK, and Getblock. If the risk assessment performed by the relevant tools identifies an elevated risk, even in the absence of risk indicators according to other sources or verification tools used by the User, priority shall be given to the results obtained through our internal analysis methods.

Decisions on taking precautionary measures are made strictly on the basis of conclusions produced by the AvanChange Service’s tool. The results of other monitoring methods used by Users or third parties are not taken into account.

This Policy applies to all Users and transactions on the AvanChange platform.

8. System Functions

8.1. The AvanChange Service performs multiple compliance-related tasks, including data collection, filtering, record keeping, investigation management, and reporting. System functions include:

daily screening of Users against recognized “blacklists” such as OFAC, aggregating transfers across multiple data points, placing users on monitoring and denial-of-service lists, opening investigation cases where necessary, sending internal messages, and completing required reports where applicable;
case and document management.

9. User Behavior Analysis

9.1. AvanChange continuously monitors user behavior and transactions, identifying suspicious patterns and preventing attempts at money laundering and terrorist financing.

10. Customer Verification Methods

10.1. If there are reasonable suspicions of an attempt to launder money or engage in other illegal activity, the AvanChange administration has the right to:

Block the current transaction.
Request additional information and documents.
Report the suspicious transaction to law enforcement authorities.
Cancel the Request and/or initiate a refund in the cases and in the manner provided for by this Policy and the AvanChange Service Rules.

11. Procedure for Refunds Based on KYC/KYT Review Results:

11.1. In the event of suspension of the execution of a Request or detection of circumstances indicating signs of illegal activity in accordance with the KYC/KYT Policy, the Service has the right to make one of the following decisions:

Execute the Request, provided that no risks are identified;
Request additional documents and information from the User;
Refuse to execute the Request and forward the relevant information to competent authorities if signs of a crime are present;
Cancel the Request;
Refund the funds to the Sender.

11.2. Refunds are made to the original payment details of the Sender from which the funds were received. Refunds to other payment details are permitted only by decision of the Service after additional verification that the account belongs to the User.

Refunds are not made in cases where:

A refund is impossible or prohibited by applicable law;
Official requirements or restrictions imposed by authorized authorities, including law enforcement authorities, are in effect;
An official investigation, whether criminal or administrative, is underway;
The funds are blocked by the rules of cryptocurrency exchanges, the blockchain network, or smart contract terms.

11.3. If the User has not passed verification under this KYC/KYT Policy or has refused to provide the requested documents and information, the Service conducts an additional review of the circumstances of the request and the source of funds. The period for such review shall not exceed 14 (fourteen) calendar days from the moment the failure to pass verification or the User’s refusal to undergo verification is recorded.

11.4. If a decision to refund the funds is made, such refund shall be carried out within 7 (seven) calendar days from the moment such decision is made and all necessary data has been received from the User.

11.5. Refunds are made subject to the following rules:

For bona fide Users: Refunds are made minus network fees (blockchain fees), exchange fees, and other expenses actually incurred by the Service.
In case risks are identified or verification is refused: If verification is not passed, documents are refused, or signs of illegal activity are detected, a refund is not guaranteed. If a refund decision is made, the Service has the right to withhold a fee of up to 5% of the refund amount, but not more than 100 USDT, as well as all actual costs incurred for carrying out the transaction. Refunds are made only if such refund is technically possible and is not prohibited by applicable law, requirements of law enforcement authorities, or the rules of blockchain networks/cryptocurrency exchanges.

11.6. The timeframes specified in Section 11 of this Policy may be extended if the refund is impossible or temporarily restricted due to reasons beyond the control of the Service, including official requirements from authorized authorities, investigations within criminal proceedings, restrictions imposed by exchanges or the blockchain network, incorrect data provided by the User, or the need to obtain additional information from the User or third parties. The Service shall not be liable for the impossibility of carrying out or delay in carrying out a refund caused by the circumstances listed above.

10. Customer Verification Methods

10.1. If there are reasonable suspicions of an attempt to launder money or engage in other illegal activity, the AvanChange administration has the right to:

Block the current transaction.
Request additional information and documents.
Report the suspicious transaction to law enforcement authorities.

11. Refund Procedure

11.1. Refund fees

In the event of a refund based on the results of an AML/KYC review:

Bona fide clients: Refunds are made with only the network fee deducted.
Clients who have not passed KYC or are connected with illegal activity: Refunds are not guaranteed, and, if necessary, a fee of up to 5% of the refund amount, but not more than 100 USDT, may be withheld.

12. Confidentiality

12.1. The AvanChange Service guarantees client confidentiality in accordance with the Service’s Privacy Policy.

12.2. The AvanChange Service and its employees undertake to maintain confidentiality regarding any facts revealed in connection with any suspicious transaction. This obligation also applies to Service users and third parties to whom transaction-related information has been disclosed.

12.3. The obligation imposed on AvanChange Service employees to ensure confidentiality remains in force after termination of their employment or any other contractual relationship with the AvanChange Service, as well as upon transfer of such employees to another position. Disclosure of such information to state authorities, law enforcement authorities, and other entities in cases provided for by law shall not constitute a breach of confidentiality obligations.

12.4. The confidentiality obligation, provided that the use of disclosed information is limited to preventing the legalization of proceeds of crime and terrorist financing, shall not apply to the disclosure of information between financial institutions forming a consolidated group cooperating with the AvanChange Service.

13. Conclusion

Our AvanChange Service is committed to complying with all international and national standards for combating money laundering and terrorist financing. We believe that transparency and security come first, and we guarantee clients high-quality service and protection of their assets.

By making an exchange, the User accepts the exchange rules and agrees to all terms of this Policy and undertakes to comply with them.

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